Chapter 1 General Principles
Article 1
To strengthen the management of information disclosure affairs at Hangzhou Tianyuan Pet Products Co., Ltd. (hereinafter referred to as "the Company"), further standardize the Company's information disclosure behavior, and protect the legitimate rights and interests of the Company, investors, and other stakeholders, this system is formulated in accordance with the Company Law of the People's Republic of China, the Securities Law of the People's Republic of China (hereinafter referred to as "the Securities Law"), the Administrative Measures for Information Disclosure of Listed Companies, the Shenzhen Stock Exchange GEM Listing Rules (hereinafter referred to as "the Listing Rules"), and the Shenzhen Stock Exchange Self-Regulatory Guidelines No. 2 - Standard Operation of GEM Listed Companies (hereinafter referred to as "the Guidelines"), as well as relevant provisions of the Articles of Association of Hangzhou Tianyuan Pet Products Co., Ltd. (hereinafter referred to as "the Articles of Association").
Article 2
The Company shall timely and lawfully fulfill its information disclosure obligations. The disclosed information must be true, accurate, complete, concise, clear, and easily understandable, without any false records, misleading statements, or significant omissions.
Article 3
This system applies to the information disclosure behaviors of the following personnel and institutions:
- The Company’s board secretary and the information disclosure management department;
- The Company’s directors and board;
- The Company’s senior management;
- Heads of various departments and subsidiaries of the Company;
- The Company’s controlling shareholders and shareholders holding more than 5% of the shares;
- Other personnel and departments responsible for information disclosure.
Article 4
The Company’s directors and senior management shall faithfully and diligently perform their duties, ensuring that disclosed information is true, accurate, complete, timely, and fair.
Article 5
The information disclosed by the Company shall be disclosed simultaneously to all investors. Prior to the lawful disclosure of insider information, insiders and those who illegally obtain insider information shall not publicly disclose or leak such information, nor use it for insider trading. No unit or individual may illegally request the information disclosure obligor to provide information that is required to be disclosed but has not yet been disclosed.
The term "insiders" as used in this system refers to internal and external personnel who can access or obtain insider information, including but not limited to:
- The Company and its directors, senior management; enterprises controlled or actually controlled by the Company and their directors, supervisors, senior management; personnel involved in major planning, demonstration, decision-making, etc.; financial personnel, internal auditors, information disclosure staff, etc. who are aware of insider information due to their positions.
- Shareholders holding more than 5% of the Company’s shares and their directors, supervisors, senior management; the Company’s controlling shareholders, largest shareholders, actual controllers, and their directors, supervisors, senior management; acquirers or parties related to major asset transactions and their controlling shareholders, actual controllers, directors, supervisors, senior management (if any); proposing shareholders and their directors, supervisors, senior management (if any); personnel from securities regulatory agencies, securities trading venues, securities companies, securities registration and settlement institutions, and securities service institutions who can access insider information due to their statutory duties regarding the issuance, trading of securities, or management of listed companies and their acquisitions or major asset transactions; other external personnel who obtain insider information from the Company; other external personnel involved in major planning, demonstration, decision-making, approval, etc.
- Other personnel who are aware of the Company’s insider information due to familial relationships, business relationships, etc. with the personnel mentioned in (1) and (2).
- Other personnel as stipulated by the China Securities Regulatory Commission.