Shanghai Hehui Optoelectronics Co., Ltd

Information disclosure management system

(Draft)

(Applicable after the listing of H-share issuance)

Shanghai Hehui Optoelectronics Co., Ltd

Information disclosure management system

Chapter I: General Provisions

Article 1 In order to strengthen the information of Shanghai Hehui Optoelectronics Co., Ltd. (hereinafter referred to as "the Company").

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 Rules for the Listing of Stocks on the Science and Technology Innovation Board of the Shanghai Stock Exchange (hereinafter referred to as the "Listing Rules"), and the Self-Regulatory Guidelines for Listed Companies on the Science and Technology Innovation Board of the Shanghai Stock Exchange No. 1 - Standardized Operation(hereinafter referred to as the "Regulatory Guidelines"), the Rules Governing the Listing of Securities on The Stock Exchange of Hong Kong Limited (hereinafter referred to as the "Hong Kong Listing Rules") and other laws, administrative regulations, normative documents and the relevant provisions of the Articles of Association of Shanghai Hehui Optoelectronics Co., Ltd. (hereinafter referred to as the "Articles of Association"), combined with the actual situation of the Company, this system is hereby formulated.

Article 2 The information referred to in this system mainly includes:

(1) The periodic reports publicly released by the Company in accordance with the law, including quarterly reports, semi-annual reports and

Annual report;

(2) The interim report of the company publicly released to the public in accordance with the law, including the announcement of the resolution of the general meeting of shareholders and the directors

Announcement of the resolution of the meeting, announcement of the resolution of the board of supervisors, announcement of the acquisition and sale of assets, announcement of related party transactions, supplementary announcement and other major announcements, etc., as well as other matters that the stock exchange in the place where the company's shares are listed deems necessary to disclose;

(3) The prospectus published in the company's issuance of new shares, the allotment prospectus published in the allotment of shares, and the stocks

Municipal announcements, prospectuses, and announcements on the issuance of convertible bonds, etc.;

(4) The Company shall distribute to the China Securities Regulatory Commission (hereinafter referred to as the "CSRC") and its distribution

Reports and requests for instructions submitted by the issuing institutions, the stock exchange where the company's shares are listed and relevant government departments that may have a significant impact on the company's stock price;

(5) It may have a greater impact on the trading price of the company's shares and its derivatives and the decision-making of investors

including but not limited to:

1. Information related to the company's performance, profits, etc., such as financial results, profit forecasts and profit shares

allocation and capital reserve to increase share capital, etc.;

2. Information related to the company's mergers and acquisitions, asset restructuring, major investments, external guarantees, etc.;

3. Information related to the company's stock issuance, repurchase, equity incentive plan and other matters;

4. Information related to the company's business matters, such as the development of new products, new inventions, and the establishment of future major events

camp plan, approved by government departments, signed major contracts;

5. In accordance with the Administrative Measures for Information Disclosure of Listed Companies, the Listing Rules and the Hong Kong Listing Rules

Information related to the identified major events;

6. Information related to the company's major litigation and arbitration matters;

7. Information related to transactions and related party transactions that should be disclosed;

8. Relevant laws, regulations, departmental rules, normative documents, "Listing Rules" and the company's stocks

Information on other matters that should be disclosed as stipulated in other relevant regulations of the municipal stock exchange.

Article 3 This system shall apply to the Company and the following persons and institutions (hereinafter referred to as the "Information Disclosure Principle").

Servant"):

(1) Directors and the board of directors of the company;

(2) Supervisors and the Board of Supervisors of the Company;

(3) Senior management of the Company;

(4) Heads of various departments of the company;

(5) Controlling shareholders and shareholders holding more than 5% of the shares of the company;

(6) The company's core technical personnel;

(7) Other personnel and departments of the company who are responsible for information disclosure.

Article 4 The public disclosure referred to in this system refers to the disclosure of the company and related information in accordance with the law and administration

Laws and regulations, departmental rules, normative documents, "Listing Rules", "Hong Kong Listing Rules" and other relevant regulations of the stock exchange where the company's shares are listed shall be announced in the media designated by the China Securities Regulatory Commission.

Chapter II: Basic Principles of Information Disclosure

Article 5 Principles of Information Disclosure:

(1) Perform information disclosure obligations in a timely manner in accordance with laws, regulations, rules, and relevant provisions such as measures and notices issued by the stock exchange where the company's shares are listed;

(2) Timely and fair disclosure of all matters that may have a greater impact on the trading price of the company's shares and its derivatives or have a greater impact on investment decisions;

(3) Ensure that the content of the information disclosed is true, accurate, complete, concise, clear, and easy to understand

may contain false records, misleading statements or material omissions;

(4) Disclose to all investors at the same time, and shall not disclose it to any unit or individual in advance. But

Except as otherwise provided by laws and administrative regulations.

Before the inside information is disclosed in accordance with the law, the insiders of the inside information and the person who illegally obtains the inside information shall not disclose or disclose the information, and shall not use the information to conduct insider trading. No unit or individual shall illegally require the company to provide information that needs to be disclosed in accordance with the law but has not yet been disclosed.

Article 6 The company's announcement manuscript should be focused, logical, plain, concise and easy to understand, and avoided

Avoid using a large number of professional terms, overly obscure expressions and foreign languages and their abbreviations, avoid vague, templated and redundant and repetitive information, and do not contain words of congratulations, publicity, advertising, compliments, slander, etc.; The company guarantees that users can obtain information in a cost-effective and convenient way (e.g. securities, newspapers, the Internet).

Article 7 The directors, supervisors and senior managers of the company shall ensure that the company discloses the letter in a timely and fair manner

and the information disclosed is true, accurate and complete, and there are no false records, misleading statements or material omissions. If directors, supervisors and senior managers have objections to the content of the announcement, they shall make a corresponding statement and explain the reasons in the announcement.

Article 8 In addition to disclosing information in accordance with mandatory regulations, the company shall take the initiative to disclose all possible pairs in a timely manner

Information that has a significant impact on the decisions of other stakeholders and guarantees equal access to information for all stakeholders.

Article 9 In addition to the information that needs to be disclosed in accordance with the law, the company may voluntarily disclose the value of the investment with investors

Information related to judgment and investment decision-making, but shall not conflict with the information disclosed in accordance with the law, and shall not mislead investors.

The information voluntarily disclosed by the company shall be true, accurate and complete. Voluntary information disclosure shall comply with the principle of fairness, maintain the continuity and consistency of information disclosure, and shall not make selective disclosures.

The company shall not use the information disclosed voluntarily to improperly affect the trading price of the company's securities and its derivatives, and shall not use voluntary information disclosure to engage in market manipulation and other violations of laws and regulations.

Article 10 The company shall disclose information in accordance with the law on the website of the stock exchange where the company's shares are listed

It shall be published by the media in accordance with the conditions stipulated by the China Securities Regulatory Commission, and at the same time shall be placed on the stock exchange where the company's domicile and the company's shares are listed for public inspection.

The full text of the information disclosure documents shall be disclosed on the website of the stock exchange where the company's shares are listed and the websites of newspapers and periodicals that meet the conditions stipulated by the China Securities Regulatory Commission in accordance with the law, and the summary of information disclosure documents such as periodic reports and acquisition reports shall be disclosed on the website of the stock exchange where the company's shares are listed and newspapers and periodicals that meet the conditions stipulated by the China Securities Regulatory Commission.

Persons with information disclosure obligations must not substitute for their reporting or announcement obligations by means such as press releases or answering reporters' questions. Periodic reports shall not be used as a substitute for interim reporting obligations.

Chapter III: Management of Information Disclosure Matters and Approval Procedures

Article 11 The chairman of the board of directors is the first person responsible for the company's information disclosure.

Article 12 The directors of the company shall understand and continue to pay attention to the company's production and operation, financial status and public affairs

The major events that have occurred or may occur in the Division and their impacts, and take the initiative to investigate and obtain the information needed for decision-making.

Article 13 The supervisors of the company shall perform the duty of information disclosure to the directors and senior management of the company

for supervision; Pay attention to the company's information disclosure, and if it is found that there are violations of laws and regulations in the information disclosure, an investigation shall be conducted and suggestions shall be put forward.

Article 14 The senior management personnel of the company shall report to the board of directors on the operation or financial affairs of the company in a timely manner

Significant events, progress or changes in disclosed events, and other relevant information.

Article 15 The secretary of the board of directors is the specific executor of the company's information disclosure, and is the company and the company's stock

The designated contact person of the municipal stock exchange is responsible for coordinating and organizing the company's information disclosure, including improving and improving the information disclosure system, ensuring that the company discloses information in a true, accurate, complete and timely manner, collecting the information that the company should disclose and reporting to the board of directors, continuing to pay attention to the media coverage of the company and actively verifying the true situation of the report. The secretary of the board of directors has the right to attend the general meeting of shareholders, the board of directors, the board of supervisors and the relevant meetings of senior management, and has the right to understand the financial and operational conditions of the company, and to inspect all documents related to information disclosure. The secretary of the board of directors is responsible for handling the company's information disclosure and other related matters.

Article 16 The office of the board of directors is the management department of the company's information disclosure, and is responsible for the specific implementation of information collection

Collection, sorting, submission and disclosure, handling the company's review procedures at all levels before the formal disclosure of documents, receiving investors to consult disclosed documents, and responding to investor inquiries.

Article 17 The person in charge of each functional department and each branch (subsidiary) of the company shall be responsible for the information disclosure in accordance with the regulations

Disclosure is obligated to report relevant information in a timely manner and is responsible for the truthfulness, accuracy and completeness of the information and materials provided.

Article 18 When the shareholders and actual controllers of the company have any of the following events, they shall take the initiative to inform the directors of the company

and cooperate with the company to fulfill its information disclosure obligations:

(1) There is a major change in the situation in which a shareholder or actual controller holding more than 5% of the company's shares holds shares or controls the company, and there is a major change in the situation in which the actual controller of the company and other enterprises under its control engage in the same or similar business as the company;

(2) The court rules to prohibit the controlling shareholder from transferring its shares, and more than 5% of the shares of the company held by any shareholder are pledged, frozen, judicial auction, trusteeship, set up a trust, or have voting rights restricted in accordance with law, or there is a risk of compulsory transfer;

(3) Plans to carry out major asset or business restructuring of the company;

(4) Other circumstances stipulated by the China Securities Regulatory Commission or the stock exchange at the place of listing.

If the relevant information has been disseminated in the media or there is an abnormal transaction of the company's securities and its derivatives before the information that should be disclosed in accordance with the law, the shareholder or actual controller shall make a written report to the company in a timely and accurate manner, and cooperate with the company to make a timely and accurate announcement.

The shareholders and actual controllers of the company shall not abuse their shareholder rights and dominant position, and shall not require the company to provide them with inside information.

Article 19 When a company issues shares to a specific target, its controlling shareholder, actual controller and issuing pair

The company shall provide relevant information to the company in a timely manner and cooperate with the listed company in fulfilling its information disclosure obligations.

Article 20 The directors, supervisors, senior management personnel and shareholders holding more than 5% of the shares of the company and their directors

The persons acting in concert and the actual controllers shall promptly submit to the board of directors of the company a list of the company's related persons and an explanation of their related relationships. The company shall perform the review procedures for related party transactions and strictly implement the system of recusal from voting on related party transactions. Parties to a transaction shall not circumvent the Company's related party transaction review procedures and information disclosure obligations by concealing related party relationships or adopting other means.

Article 21 The company shall be equipped with office facilities such as communication equipment and computers necessary for information disclosure

to ensure that the computer can be connected to the Internet and the telephone is unimpeded.

Article 22: The following approval procedures shall be strictly followed for information disclosure:

(1) The information manuscripts for public information disclosure shall be written or reviewed by the secretary of the board of directors;

(2) The secretary of the board of directors shall comply with the relevant laws and regulations, the securities regulatory authority of the place where the company's shares are listed and

The relevant regulatory rules of the stock exchange and the provisions of the Articles of Association of the Company shall disclose the periodic report and the resolutions of the general meeting of shareholders, the board of directors and the board of supervisors after the statutory approval procedures have been performed;

(3) The secretary of the board of directors shall complete the following approval procedures before publicly disclosing the resolution of the general meeting of shareholders,

Interim reports other than resolutions of the Board of Directors and the Board of Supervisors:

1. The interim report issued in the name of the board of directors shall be submitted to the chairman of the board of directors for review and signature;

2. The interim report issued in the name of the Board of Supervisors shall be submitted to the Chairman of the Board of Supervisors for review and signature;

3. Within the scope of the authorization of the board of directors, the general manager has the right to approve the business matters that need to be publicly disclosed

The announcement of the item shall be submitted to the general manager for review first, and then submitted to the chairman for review and approval, and issued in the name of the board of directors;

4. If the major business matters of the holding subsidiary or the shareholding company need to be publicly disclosed, the announcement of the matter shall first be submitted to the chairman of the holding subsidiary or the director of the shareholding company dispatched by the company for review and signature, and then submitted to the general manager of the company for review and approval, and finally submitted to the chairman of the company for review and approval, and released in the name of the board of directors of the company.

(4) The reports, requests for instructions and other documents submitted by the company to the China Securities Regulatory Commission, the stock exchange where the company's shares are listed or other relevant government departments, as well as the publicity information manuscripts involving the company's major decisions and economic data published in the news media, shall be submitted to the chairman of the company for review and approval, and published in the name of the company or the board of directors of the company;

(5) No one shall disclose any information about the company without review and approval.

Article 23 When the relevant departments of the company study and decide on matters involving information disclosure, they shall notify the board of directors

The secretary attends the meeting as an observer and provides him with the information required for information disclosure.

Article 24 When the relevant departments of the company have any doubts about whether the information involved is disclosed, they shall report to the relevant departments in a timely manner

The secretary of the board of directors or through the secretary of the board of directors shall consult with the stock exchange where the company's shares are listed.

Article 25 The company discovers the disclosed information (including the announcement issued by the company and reprinted in the media

If there are errors, omissions, misleading or abnormal fluctuations in the trading of the company's shares and its derivatives, the secretary of the board of directors of the company shall report to the chairman of the board of directors and the stock exchange where the company's shares are listed in a timely manner, and promptly issue a correction announcement, supplementary announcement or clarification announcement.

Article 26 The secretary of the board of directors is responsible for the file management of the company's information disclosure documents and materials, and the board of directors

The secretary assigns special personnel to be responsible for the specific work of maintaining and managing information disclosure documents.

Article 27 The secretary of the board of directors is responsible for the prospectus, listing announcement, periodic report and interim report

As well as related contracts, agreements, resolutions and records of the general meeting of shareholders, resolutions and records of the board of directors, resolutions and records of the board of supervisors, and other original materials, special personnel shall be appointed to file them synchronously in accordance with the company's document management system, and the storage period shall not be less than ten years. If laws, regulations or normative documents provide otherwise, follow those provisions.

Article 28 The secretary of the board of directors receives inquiries or inquiries from the securities regulatory authorities in the place of listing

If the matters involved in such inquiries or inquiries constitute matters to be disclosed, the secretary of the board of directors shall immediately contact the functional departments of the company involved on such matters, coordinate with the relevant parties to actively prepare the proposals for the matters to be disclosed that are subject to the approval of the board of directors and the general meeting of shareholders, or provide requirements on the content and format of the preparation of the interim report, and specifically coordinate the relevant parties to prepare the first draft of the interim report on time. Subsequently, it is necessary to follow the approval and disclosure process of the interim report, and at the same time strictly abide by the time limit set by the regulator, and submit the response letter in a timely manner.

Chapter IV: Content of Information Disclosure

Section 1 Periodic reports

Article 29 The company shall be in accordance with the China Securities Regulatory Commission and the stock exchange where the company's shares are listed

Periodic reports are required to be prepared and disclosed. The periodic reports that should be disclosed by the company include annual reports, semi-annual reports and quarterly reports. All information that has a significant impact on investors' value judgments and investment decisions should be disclosed.

Article 30 The company shall make an appointment for the disclosure of the periodic report to the stock exchange where the company's shares are listed

Space.

The company shall handle the disclosure of periodic reports in accordance with the time arranged by the stock exchange where the company's shares are listed. If it is necessary to change the disclosure time for any reason, a written application shall be submitted to the Shanghai Stock Exchange five trading days in advance.

Article 31 The financial and accounting reports in the company's annual report must be approved in accordance with the Securities Law and the company

Audit by an accounting firm as required by the Listing Rules of the place where the stock is listed.

If the company intends to issue shares or convert capital reserve into share capital, the financial accounting report of the semi-annual report or quarterly report on which it is based shall be audited; Only cash dividends can be exempted from audit.

Article 32 The Company shall submit its periodic report to the Shanghai Stock Exchange in a timely manner after being reviewed by the Board of Directors

Submit and submit the relevant documents required by the Shanghai Stock Exchange.

Article 33 The content of the periodic report shall be deliberated and approved by the board of directors of the company. The Company shall not disclose unobtained

Periodic reports considered and adopted by the Board of Directors. The directors and senior management of the company shall sign a written opinion on the periodic report, stating whether the preparation and review procedures of the board of directors comply with laws, administrative regulations and the provisions of the China Securities Regulatory Commission, and whether the content of the report can truthfully, accurately and completely reflect the actual situation of the company.

The Board of Supervisors shall review the periodic reports prepared by the Board of Directors and submit written audit opinions. Supervisors shall sign a written confirmation opinion. The written review opinion issued by the board of supervisors on the periodic report shall explain whether the preparation and deliberation procedures of the board of directors comply with laws, administrative regulations and the provisions of the China Securities Regulatory Commission, and whether the content of the report can truthfully, accurately and completely reflect the actual situation of the company.

If directors or supervisors are unable to guarantee the authenticity, accuracy and completeness of the contents of the periodic report, or have objections, they shall vote against or abstain from voting when the board of directors or the board of supervisors deliberates and examines the periodic report.

If the directors, supervisors and senior management cannot guarantee the authenticity, accuracy and completeness of the contents of the periodic report or have objections, they shall express their opinions and state the reasons in the written confirmation opinion, and the company shall disclose it. If the company does not disclose it, the directors, supervisors and senior management personnel may directly apply for disclosure.

Directors, supervisors and senior managers shall follow the principle of prudence when expressing their opinions in accordance with the provisions of the preceding paragraph, and their responsibility to ensure the authenticity, accuracy and completeness of the contents of the periodic reports is not only exempted from the opinions expressed.

Article 34 If the company expects that the annual operating performance will occur in any of the following circumstances, it shall be in the accounting year

Earnings forecast within one month from the date of the end of the degree:

(i) Net profit is negative;

(2) Net profit increased or decreased by more than 50% compared with the same period last year;

(3) Turning losses into profits.

If the company expects that the semi-annual and quarterly results will occur in one of the above-mentioned situations, it can make a performance forecast.

The directors, supervisors and senior management of the company shall promptly and comprehensively understand and pay attention to the company's operating conditions and financial information, and conduct necessary communication with the accounting firm to prudently judge whether the circumstances specified in this article are met.

Article 35 After the company discloses the performance forecast, it is expected that the difference between the current performance and the performance forecast will reach

If it is more than 20% or there is a change in the direction of profit and loss, the correction announcement shall be disclosed in a timely manner.

Article 36 The Company is not expected to be able to disclose the annual report within 2 months from the date of the end of the accounting year

shall disclose the performance report in accordance with the requirements of the Listing Rules within 2 months from the end of the accounting year.

Article 37 The company shall ensure that the financial data and indicators disclosed in the performance express report and the periodic report are not

There are significant differences.

Before the disclosure of the periodic report, if the company finds that the difference between the financial data and indicators of the performance express report and the periodic report is more than 10%, it shall disclose the correction announcement in a timely manner.

Article 38 If the company's financial accounting report is issued by an accounting firm with a non-standard audit opinion, it shall be pressed

According to the Rules for the Preparation of Information Disclosure of Companies Offering Securities to the Public No. 14 - Handling of Non-standard Audit Opinions and Matters Involved, a company shall disclose the following documents at the same time as disclosing its periodic report:

(1) The special explanation and resolution of the board of directors on the matters involved in the audit opinion;

(2) Opinions of independent directors on matters covered by the audit opinion;

(3) Opinions and resolutions of the Board of Supervisors on the special explanation of the Board of Directors;

(4) Special explanations issued by accounting firms and certified public accountants;

(5) Other documents required by the China Securities Regulatory Commission and the Shanghai Stock Exchange.

If the matters involved are in obvious violation of accounting standards and relevant information disclosure provisions, the company shall correct the relevant matters and timely disclose the corrected financial and accounting materials and relevant materials such as audit reports or special assurance reports issued by accounting firms.

Section II Interim Reports

Article 39 The occurrence of a decision on the trading price of the securities of the listed company and its derivatives or investors

When investors have not yet learned of a major event that has a greater impact, the listed company shall immediately disclose and explain it

The cause of the incident, its current state, and its possible impact.

"Major incidents" as used in the preceding paragraph include:

(1) Major events as provided for in the second paragraph of Article 80 of the Securities Law;

(2) The company incurs a large amount of liability;

(3) The company makes provision for impairment of large assets;

(4) The company's shareholders' equity is negative;

(5) The company's main debtor is insolvent or enters bankruptcy proceedings, and the company fails to make sufficient provision for bad debts for the corresponding creditor's rights;

(6) Newly promulgated laws, administrative regulations, rules, and industry policies may have a significant impact on the Company;

(7) The company carries out equity incentives, share repurchases, major asset restructurings, asset spin-offs or listings;

(8) the court rules prohibiting the controlling shareholder from transferring its shares; More than 5% of the company's shares held by any shareholder are pledged, frozen, judicial auction, trusteeship, trust or voting rights restricted in accordance with the law, or there is a risk of forced transfer;

(9) Major assets are sealed, seized, or frozen; The main bank account is frozen;

(10) The listed company expects to incur losses or substantial changes in its operating results;

(11) The main or all operations have come to a standstill;

(12) Obtaining additional income that has a significant impact on the profit or loss of the current period, which may have a significant impact on the company's assets, liabilities, equity or operating results;

(13) Hiring or dismissing an accounting firm for the company's audit;

(14) Major voluntary changes in accounting policies and accounting estimates;

(15) Being ordered to make corrections by the relevant authorities or corrected by a decision of the board of directors due to errors in the information disclosed in the previous period, failure to disclose in accordance with regulations, or false records;

(16) The company or its controlling shareholders, actual controllers, directors, supervisors, and senior managers are subject to criminal penalties, and are investigated by the China Securities Regulatory Commission for suspected violations of laws and regulations, or are subject to administrative penalties by the China Securities Regulatory Commission, or are subject to major administrative penalties by other competent authorities;

(17) The company's controlling shareholders, actual controllers, directors, supervisors, or senior managers are suspected of serious violations of discipline and law or crimes abusing public office and are subject to retention in custody measures by the discipline inspection and supervision organs, which affects their performance of their duties;

(18) Other directors, supervisors, or senior managers of the company other than the chairman or manager are unable to perform their duties normally for more than three months due to physical or work arrangements, or are suspected of violating laws and regulations and are subject to compulsory measures taken by the competent authorities and their performance of their duties is affected;

(19) Other matters stipulated by the China Securities Regulatory Commission.

Where the controlling shareholder or actual controller of a listed company has a greater impact on the occurrence or progress of a major event, it shall promptly inform the listed company in writing of the relevant circumstances of which it is aware, and cooperate with the listed company in performing its information disclosure obligations.

Article 40 The company changes the company name, stock abbreviation, articles of association, registered capital, registered address,

The main office address and contact telephone number shall be immediately disclosed.

Article 41 In the event of any of the following major accidents or negative events, the Company shall disclose the specific circumstances in a timely manner

And its impact:

(1) The occurrence of major environmental, production and product safety accidents;

(2) Receiving a notice of the decision of the government department to rectify, suspend production, relocate, or close down within a time limit;

(3) Improper use of science and technology or violation of scientific ethics;

(4) Other major accidents or negative events that improperly fulfill social responsibilities.

Article 42 The Company shall, in accordance with the relevant provisions and requirements of the Listing Rules and the Hong Kong Listing Rules,

Review and disclose major transactions that should be disclosed, transactions within the scope of daily business, related party transactions and other major matters.

Article 43 The Company shall promptly fulfill the letter of major event after any of the following points in time

Information Disclosure Obligations:

(1) When the Board of Directors or the Board of Supervisors makes a resolution on the major event;

(2) When the parties concerned sign a letter of intent or agreement on the material event;

(3) When the directors, supervisors or senior management are aware of the occurrence of the major event.

If there is great uncertainty in the major event planned by the company, and immediate disclosure may damage the interests of the company or mislead investors, and the insider of the relevant inside information has promised in writing to keep it confidential, the company may temporarily withhold the disclosure, but shall disclose it to the public at the latest when the final resolution of the material matter is formed, the final agreement is signed, and the transaction is determined to be concluded.

Article 44 If any of the following circumstances occurs before the time specified in the preceding article, the company shall disclose it in a timely manner

Disclose the current status of the matter and the risk factors that may affect the progress of the event:

(1) It is difficult to maintain the confidentiality of the major event;

(2) the major event has been leaked or rumors have appeared in the market;

(3) Abnormal fluctuations have occurred in the trading of the company's securities and its derivatives.

Article 45 After the company discloses a major event, the occurrence of the disclosed major event may affect the company's securities

If the progress or change of the trading price of its derivatives has a greater impact, the company shall disclose the progress or change and the possible impact in a timely manner.

Article 46 The Company and the relevant information disclosure obligor shall pay close attention to the public media about the Company

major reports and market rumors (hereinafter collectively referred to as rumors). If the relevant rumors may have a greater impact on investment decisions or the company's stock trading, the company shall verify it in a timely manner and disclose or clarify it as appropriate.

Article 47 If the company plans a major event for a long period of time, it shall follow the principle of materiality.

Disclose progress in stages, prompt relevant risks in a timely manner, and not withhold disclosure solely on the grounds that the outcome of relevant matters is uncertain.

Article 48 The subsidiaries and other entities within the scope of the company's consolidated financial statements shall be subject to the weight mentioned in this system

Major events shall be regarded as major events occurring in the company, and the provisions of the preceding chapters shall apply. If the major event described in this system occurs in the company's shareholding company, which may have a greater impact on the trading price of the company's shares and its derivatives, the company shall refer to the above provisions to fulfill the obligation of information disclosure.

Chapter V: Confidentiality of Information

Article 49 The directors, supervisors, senior managers, employees of the company and other employees of the company are related to their work

Persons who have access to information that should be disclosed are obliged to maintain confidentiality and not to divulge inside information.

Article 50 The board of directors and directors and supervisors of the company shall disclose the information before the company's information is publicly disclosed

The informant controls it to a minimum.

Chapter VI Information Disclosure Suspension, Exemption and Approval Procedures

Article 51 The information that the information disclosure obligor shall disclose is subject to the Listing Rules and the Regulatory Guidelines

and other relevant business rules of the Shanghai Stock Exchange that may suspend or exempt information disclosure, it may not be necessary to apply to the Shanghai Stock Exchange, and the information disclosure obligor shall make its own prudent judgment and accept the post-event supervision of the Shanghai Stock Exchange on the suspension or exemption of information disclosure.

Article 52: The information to be disclosed by the information disclosure obligor is uncertain and is a temporary business

In circumstances such as secrecy, where timely disclosure might harm the company's interests or mislead investors, disclosure may be suspended.

Article 53 The information to be disclosed by the Company and the relevant information disclosure obligor is a commercial secret

Sensitive information may be exempted from disclosure if the disclosure or performance of relevant obligations under the Listing Rules may lead to unfair competition, damage the interests of the company and investors, or mislead investors.

If the information to be disclosed is recognized as a state secret in accordance with the law, and the disclosure or performance of relevant obligations in accordance with the Listing Rules may cause it to violate domestic laws and regulations or endanger national security, it may be exempted from disclosure.

Article 54: "Commercial secrets" as used in this System refers to the state's laws and regulations on countering unfair competition

and commercial information such as technical information, business information, and other commercial information that is not known to the public, has commercial value, and has been subject to corresponding confidentiality measures by the right holder.

"State secrets" as used in this system refers to information that is related to national security and interests, as provided for by the state's relevant laws and regulations on secrecy and departmental rules, determined in accordance with legal procedures, known only to a certain range of persons for a certain period of time, and may harm the state's security and interests in the political, economic, national defense, foreign affairs, and other fields if leaked.

Article 55: Information suspended or exempted from disclosure shall meet the following requirements:

(i) The relevant information has not been disclosed;

(ii) the person in charge of the inside information has undertaken in writing to keep it confidential;

(3) There is no abnormal fluctuation in the trading of the company's shares and its derivatives.

Article 56 The Company shall prudently determine the matters for which information disclosure is suspended or exempted, and shall not arbitrarily expand the matters for which the information disclosure is suspended

The scope of the matters to be deferred or exempted, and effective measures are taken to prevent the disclosure of information that has been suspended or exempted.

If the company decides to suspend or exempt the disclosure of specific information, the secretary of the board of directors shall be responsible for registration, and after being signed and confirmed by the chairman of the company, it shall be properly filed and safeguarded.

Article 57 If the information that has been suspended or exempted from disclosure is leaked or there are market rumors, the company shall:

Verify the relevant information in a timely manner and disclose it to the public.

If the reasons for the suspension or exemption from disclosure have been eliminated or the time limit has expired, the company shall promptly announce the relevant information and disclose the reasons for the previous suspension or exemption from disclosure, the company's internal registration review, etc.

Chapter VII: Punishment

Article 58 The board of directors of the company shall give the parties internal punishment according to the severity of the violation of this system

Circulate criticism, financial punishment, dismissal, expulsion, and other punishments, until their legal responsibility is pursued.

Article 59 If the consultants, intermediaries and affiliates hired by the company disclose the company's information without authorization,

If adverse consequences are caused, the company reserves the right to pursue its legal responsibility.

Chapter VIII: Supplementary Provisions

Article 60 This system does not provide for or cooperate with the relevant laws, securities regulators and securities regulators of the place where the company's shares are listed

In the event of any inconsistency between the relevant regulatory rules, administrative regulations, normative documents and the Articles of Association of the Stock Exchange, the relevant laws, administrative regulations, relevant regulatory rules, normative documents and the Articles of Association of the securities regulatory authority of the place where the company's shares are listed shall prevail.

Article 61 The terms "above", "at least" and "within" in this system all include this number, and "exceed" and "no".

"Over" and "Below" do not include this number.

Article 62 The board of directors of the company shall be responsible for the interpretation and revision of this system.

Article 63 This system shall be deliberated and approved by the board of directors of the company, and shall be listed overseas from the company's initial public offering

Ordinary shares (H shares) shall take effect and take effect on the date of listing on The Stock Exchange of Hong Kong Limited. After this system comes into effect, the original "Information Disclosure Management System of Shanghai Hehui Optoelectronics Co., Ltd." will automatically become invalid.