Chapter 1 General Principles
Article 1
To standardize the management of insider information at Beijing Jinyi Cultural Development Co., Ltd. (hereinafter referred to as "the Company"), ensure confidentiality of insider information, uphold the principles of openness, fairness, and justice in information disclosure, effectively prevent insider trading and other violations of securities laws, and protect the legitimate rights and interests of investors, this "Insider Information Insider Person Registration Management System" (hereinafter referred to as "this System") is formulated in accordance with the "Securities Law of the People's Republic of China," "Regulations on the Disclosure of Information by Listed Companies," "Shenzhen Stock Exchange Stock Listing Rules," "Self-Regulatory Guidelines No. 1 for Main Board Listed Companies," "Regulatory Guidelines No. 5 for Listed Companies on Insider Information Insider Person Registration Management System," and other laws, regulations, and the "Articles of Association" of the Company.
Article 2
This System applies to the Company and its subordinate departments, branches, subsidiaries (including subsidiaries directly or indirectly controlled by the Company with over 50% ownership and other subsidiaries included in the Company's consolidated financial statements), as well as associated companies where the Company can exert significant influence.
Article 3
The Company's board of directors is the management body for insider information, with the chairman being the primary responsible person for the confidentiality management of insider information. The board secretary is responsible for the registration and filing of insider information personnel, while heads of other departments, branches, and subsidiaries are responsible for confidentiality within their management scope, including reporting and transmitting insider information. The board office is the daily management department for the registration and filing of insider information, specifically responsible for the registration, disclosure, filing, and management of insider information personnel. The chairman and board secretary must sign written confirmations regarding the authenticity, accuracy, and completeness of the insider information personnel files. The audit committee of the Company shall supervise the implementation of this System.
Article 4
The Company's directors, senior management, and heads of various departments, branches, and subsidiaries must ensure confidentiality of insider information and actively cooperate with the board secretary in the registration and reporting of insider information personnel. Insider information personnel have a confidentiality obligation before the public disclosure of insider information and must not disclose such information, use insider information to trade the Company's securities and derivatives, or engage in insider trading or collude with others to manipulate the trading price of the Company's securities and derivatives.
Article 5
The Company shall enhance education and training for insider information personnel to ensure they understand their rights, obligations, and legal responsibilities, and urge relevant personnel to strictly fulfill their confidentiality duties, firmly preventing insider trading and other violations of securities laws.
Chapter 2 Scope of Insider Information and Insider Information Personnel
Article 6
Insider information as referred to in this System means information that has not been publicly disclosed and is related to the Company's operations, finances, or has a significant impact on the market price of the Company's securities, as defined in Article 52 of the Securities Law. Major events listed in Article 80, Paragraph 2, and Article 81, Paragraph 2 of the Securities Law are considered insider information. This includes but is not limited to:
- Significant changes in the Company's operational policies and scope;
- Major investment actions by the Company, such as purchasing or selling significant assets exceeding 30% of the Company's total assets within a year, or mortgaging, pledging, selling, or scrapping major operational assets exceeding 30% of those assets;
- Entering into important contracts, providing significant guarantees, or engaging in related party transactions that may significantly affect the Company's assets, liabilities, equity, and operational results;
- Significant d