002429SZSE

Management System for Information Disclosure Deferral and Exemption (April 2026)

Shenzhen MTC Co., Ltd.·

✨ AI Summary

This document outlines the procedures for deferring or exempting information disclosure by Shenzhen Topband Electronics Co., Ltd. It establishes rules for handling information related to state secrets and commercial secrets to protect national security and business interests. The system details application processes, internal management, and accountability measures to ensure compliance with laws and regulations.

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Management System for Information Disclosure Deferral and Exemption

Chapter 1 General Provisions

Article 1 To regulate the deferral and exemption of information disclosure by Shenzhen Topband Electronics Co., Ltd. (hereinafter referred to as the "Company"), to urge the Company to fulfill its information disclosure obligations in accordance with laws and regulations, to protect the legitimate rights and interests of investors, and in accordance with the "Securities Law of the People's Republic of China," the "Measures for the Administration of Information Disclosure by Listed Companies," the "Regulations on Deferral and Exemption of Information Disclosure by Listed Companies," the "Stock Listing Rules of the Shenzhen Stock Exchange," the "Shenzhen Stock Exchange Listed Company Self-Regulation Guidelines No. 1 - Standardized Operation of Main Board Listed Companies," and other laws, administrative regulations, departmental rules, normative documents, and the "Articles of Association" and the "Information Disclosure Management System," this system is formulated in conjunction with the Company's actual situation.

Article 2 When the Company handles information disclosure deferral and exemption matters in accordance with the provisions of relevant laws, administrative regulations, departmental rules, and normative documents, this system shall apply.

Article 3 The Company and other information disclosure obligors shall disclose information truthfully, accurately, completely, timely, and fairly. They shall not abuse deferral or exemption of disclosure to evade information disclosure obligations, mislead investors, or engage in insider trading, market manipulation, or other illegal activities.

Chapter 2 Scope of Information Disclosure Deferral and Exemption

Article 4 Where the information intended for disclosure by the Company and other information disclosure obligors is confirmed to involve state secrets or other matters that may violate national secrecy regulations or management requirements if disclosed (hereinafter collectively referred to as "state secrets"), such information shall be exempted from disclosure in accordance with relevant laws, regulations, and this system.

The Company and relevant information disclosure obligors shall comply with national secrecy laws and regulations and fulfill their confidentiality obligations. They shall not disclose state secrets in any form, including through information disclosure, investor interaction Q&A, press releases, or interviews, nor shall they use the pretext of information being classified as secret for business promotion.

The Company's Chairman and Secretary of the Board of Directors shall enhance their awareness of the legal implications of preserving state secrets and ensure that disclosed information does not violate national secrecy regulations.

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