Investor Relations Management System

Shandong Keyuan Pharmaceutical Co., Ltd.

Investor Relations Management System

Chapter 1 General Provisions

Article 1 In order to further promote the improvement of the governance structure of Shandong Keyuan Pharmaceutical Co., Ltd. (hereinafter referred to as the "Company") and standardize the company's investor relations management work, in accordance with the relevant laws, regulations, rules and regulations of the People's Republic of China Company Law, the Securities Law of the People's Republic of China, the Guidelines for Listed Companies' Investor Relations Work issued by the China Securities Regulatory Commission, and the Shenzhen Stock Exchange (hereinafter referred to as the "Stock Exchange")'s Shenzhen Stock Exchange ChiNext Stock Listing Rules (hereinafter referred to as the "Listing Rules"), Shenzhen Stock Exchange Listed Company Self-Disciplinary Supervision Guidelines No. 2 - Standardized Operation of ChiNext Listed Companies (hereinafter referred to as the "Self-Disciplinary Supervision Guidelines"), and other relevant business rules, and the Articles of Association of Shandong Keyuan Pharmaceutical Co., Ltd. (hereinafter referred to as the "Company Articles of Association"), this system is hereby formulated.

Article 2 Company investor relations management refers to the company strengthening communication with investors and potential investors through information disclosure and exchange, enhancing investors' understanding and recognition of the company, and improving the company's governance level to maximize the company's overall interests and protect the legitimate rights and interests of investors.

Article 3 The purpose of the company's investor relations management is:

(1) To promote a positive relationship between the company and investors, and to enhance investors' further understanding and familiarity with the company.

(2) To establish a stable and high-quality investor base and obtain long-term market support.

(3) To form a corporate culture that serves and respects investors.

(4) To promote the investment philosophy of maximizing the company's overall interests and the growth of shareholder wealth.

(5) To increase the transparency of the company's information disclosure and improve corporate governance.

Article 4 The basic principles of the company's investor relations management are:

(1) Principle of full information disclosure. The company shall be honest and trustworthy, and shall fully disclose information necessary for investors to make value judgments and investment decisions in accordance with the law, ensuring that information disclosure is true, accurate, and complete, and shall not contain any false records, misleading statements, or material omissions. In addition to mandatory information disclosure, the company may proactively disclose other relevant information of interest to investors.

(2) Principle of compliant information disclosure. The company shall comply with national laws, regulations, and the provisions of securities regulatory authorities and stock exchanges on information disclosure by listed companies, ensuring that information disclosure is true, accurate, complete, and timely.

When conducting investor relations management work, attention should be paid to the confidentiality of unpublished information and other internal information. Once a leak occurs, the company shall disclose it in a timely manner in accordance with relevant regulations.

(3) Principle of equal opportunities for investors. The company and its relevant information disclosure obligors shall treat all shareholders and potential investors of the company fairly, avoiding selective information disclosure; they shall publicly disclose major information to all investors at the same time, ensuring that all investors can obtain the same information equally, and shall not privately disclose, reveal, or leak information to specific individuals in advance. The text used in information disclosure documents shall be concise, plain, simple, and easy to understand, facilitating reading by small and medium-sized investors.

(4) Principle of honesty and trustworthiness. The company's investor relations management should be objective, true, and accurate, avoiding excessive publicity and misleading information.

(5) Principle of high efficiency and low cost. When choosing investor relations management methods, the company should fully consider improving communication efficiency and reducing communication costs.

(6) Principle of interactive communication. The company should actively listen to investors' opinions and suggestions, achieve two-way communication between the company and investors, and form a positive interaction.

Article 5 This method is the basic system for the company's investor relations management. The company should actively and proactively carry out investor relations management work. The company's management should attach great importance to investor relations management.

The company, as well as directors, supervisors, senior management personnel, and staff, shall comply with laws, regulations, the "Listing Rules," the "Self-Disciplinary Supervision Guidelines," and other relevant regulations of the Shenzhen Stock Exchange when conducting investor relations management work, embodying the principles of openness, fairness, and justice, and objectively, truthfully, accurately, and completely introducing and reflecting the actual situation of the company. The following situations shall not occur:

(1) Disclosing or releasing major information that has not yet been publicly disclosed through non-statutory means;

(2) Releasing content that is false or misleading, making exaggerated publicity or misleading suggestions;

(3) Making predictions or promises about the price of the company's stock and its derivative products;

(4) Discriminatory, condescending, or other unfair treatment of small and medium-sized shareholders;

(5) Other violations of information disclosure rules or suspected illegal and irregular behaviors such as manipulating the securities market or insider trading.

Chapter 2 Objects, Content, and Methods of Investor Relations Management

Article 6 The objects of investor relations management include:

(1) Investors (including registered investors and potential investors);

(2) Financial media, industry media, and other relevant media;

(3) Other relevant institutions.

Article 7 The content of communication between the company and investors in investor relations management mainly includes:

(1) The company's development strategy, including the company's development direction, development plan, competitive strategy, and business policy, etc.;

(2) Statutory information disclosure and its explanation, including periodic reports and temporary announcements, etc.;

(3) Business management information that the company can legally disclose, including production and operation status, financial status, research and development of new products or new technologies, business performance, dividend distribution, etc.;

(4) Major matters that the company can legally disclose, including major investments and their changes, asset restructuring, mergers and acquisitions, external cooperation, external guarantees, major contracts, related party transactions, major lawsuits or arbitrations, changes in management, and changes in major shareholders, etc.;

(5) Corporate culture building;

(6) Other relevant information of the company.

Article 8 The company can communicate with investors through multiple channels and multiple levels. Communication methods should be as convenient and effective as possible to facilitate investor participation.

The company should bear the primary responsibility for handling investor complaints, improving the complaint handling mechanism, and publicly disclosing the handling process and progress.

Disputes between the company and investors can be resolved through self-negotiation, submission to a securities and futures dispute mediation institution, arbitration, or litigation in the people's court.

Article 9 Information that should be disclosed according to laws, regulations, and the provisions of securities regulatory authorities and stock exchanges must be published on the company's designated newspapers and websites in a timely manner.

Article 10 Information disclosed by the company in other public media shall not precede the designated newspapers and websites, and shall not replace company announcements in other forms such as press conferences or Q&A sessions. If the company and relevant information disclosure obligors have a genuine need, they may release information that should be disclosed through press conferences, media interviews, company websites, and online self-media during non-trading hours, but the company shall disclose the relevant announcement before the start of the next trading session.

When communicating with specific parties through performance briefings, analyst meetings, roadshows, and investor research, the company and relevant information disclosure obligors shall not provide any undisclosed material information.

The company should clearly distinguish between advertising and media reports, and shall not influence the objective and independent reporting of the media through advertising materials or paid means.

The company should promptly pay attention to media publicity reports and respond appropriately when necessary.

Article 11 The company should attach great importance to the construction of online communication platforms, set up an investor relations column on the company's website, accept questions and suggestions from investors through email or forums, and respond promptly. The company should also hold regular meetings with investors to promptly answer questions of public concern and enhance investors' understanding of the company. The company should update its website promptly, and clearly distinguish between historical and current information, correct any erroneous information promptly, and avoid misleading investors.

Article 12 The company should enrich and promptly update the content of its website, including news releases, company profiles, information on products or services, legally required disclosure materials, investor relations contact information, special articles, speeches by executives, stock quotes, and other relevant information of interest to investors.

Article 13 The company should establish a dedicated investor hotline and fax number and announce it in its regular reports. The hotline should be handled by a dedicated person familiar with the situation, ensuring that the line is open during working hours and calls are answered seriously. Any changes to the hotline number should be promptly announced and published on the company's website. In the event of a major incident or other necessary circumstances, the company should open multiple lines to answer investor inquiries. The company may use online and other modern communication tools to conduct regular or irregular exchange activities conducive to improving investor relations. The company's responses and feedback to investors through telephone, fax, and email should be disclosed at least quarterly.

The company should promptly update its website, correct erroneous information, and clearly distinguish between the latest information and historical information to avoid misleading investor decisions.

Article 14 The company should communicate with investors through the investor relations interactive platform of the stock exchange (hereinafter referred to as "Interactive Easy"), and assign or authorize the company secretary or securities representative to be responsible for reviewing investor questions received on Interactive Easy, and handle relevant information on Interactive Easy promptly according to the "Listing Rules" and other relevant regulations.

Article 15   Before the shareholders' meeting deliberates on the specific plan for cash dividends, the company should proactively communicate and exchange with shareholders, especially small and medium-sized shareholders, through various channels such as Interactive Easy, fully listen to the opinions and demands of small and medium-sized shareholders, and promptly respond to questions of concern.

The company should provide a full, in-depth, and detailed analysis, explanation, and response to investors' questions about the disclosed information through Interactive Easy. For important or general questions and answers, the company should compile them and post them prominently on Interactive Easy.

The company's actions of posting information or answering investor questions on Interactive Easy cannot replace its information disclosure obligations, and the company shall not answer investor questions on Interactive Easy that involve or may involve undisclosed material information.

When publishing information on the Interactive Easy platform, the company should be cautious and objective, based on facts, ensuring that the published information is true, accurate, complete, and fair, not using exaggerated, promotional, or misleading language, not misleading investors, and fully indicating the significant uncertainties and risks that may exist.

The company's information disclosure shall be based on the content disclosed through qualified media. Information published on the Interactive Easy platform shall not conflict with legally disclosed information.

When publishing information on the Interactive Easy platform and responding to questions involving market hot concepts and sensitive matters, the company should be cautious, objective, and factual, not using the Interactive Easy platform to cater to market hot spots or improperly associate with market hot spots, not deliberately exaggerating the impact of relevant matters on the company's production, operation, research and development, sales, and development, and improperly influencing the price of the company's stock and its derivative products.

Article 16 The company may arrange for investors, analysts, and news media to visit the company's site for on-site visits and discussions. The company should reasonably and properly arrange the visit process, allowing visitors to understand the company's business and operations, while also avoiding the possibility of visitors obtaining undisclosed material information. The company should assign two or more people to accompany the visit, and a dedicated person should answer the visitors' questions.

Article 17 If the company's major matters are subject to high market attention or questioning, in addition to fulfilling its information disclosure obligations in a timely manner in accordance with the listing rules, it should promptly hold an investor briefing to introduce the situation, explain the reasons, and answer relevant questions. The chairman, general manager, company secretary, chief financial officer, or other responsible person should attend the briefing.

When the company holds an investor briefing, it should adopt a method that facilitates investor participation. The company should issue an announcement before the investor briefing, specifying the time, method, location, website, list of company attendees, and theme of the investor relations activity. The investor briefing should generally be held during non-trading hours.

The company should open a question-and-answer channel for investors before and during the investor briefing, do a good job of collecting investor questions, and answer the questions of concern at the briefing.

The company personnel participating in the investor briefing should include the chairman (or general manager), chief financial officer, independent directors, and company secretary. If the company is under continuous supervision, it is encouraged that the sponsor representative or independent financial advisor principal participate.

Article 18 When deemed necessary, the company may hold analyst meetings with investors, fund managers, and analysts on the company's operations, financial condition, and other matters to introduce the situation, answer relevant questions, and listen to relevant suggestions.

The company shall not release any material non-public information in presentations or analyst meetings. The company should provide relevant information equally to all other investors.

Article 19 The company may hold roadshows in accordance with relevant regulations when implementing financing plans.

Article 20 If the company experiences a significant year-on-year decline in net profit or has dividend-paying capacity but a low cash dividend payout ratio, and these situations attract significant market attention or questioning, it may hold online, offline, or other forms of roadshows.

Article 21 The company should strengthen communication and exchanges with small and medium-sized investors, establish effective channels of communication with investors, and meet with investors regularly. The company may hold an annual report presentation within fifteen trading days after the disclosure of the annual report. The chairman (or general manager) of the board, chief financial officer, independent director (at least one), board secretary, and sponsor representative (at least one) should attend the presentation, which should include the following:

(1) The status, development prospects, and risks of the industry in which the company operates;

(2) The company's development strategy, production and operation, use of raised funds, and development of new products and technologies;

(3) The company's financial condition and operating performance and their changing trends;

(4) Difficulties, obstacles, or contingent losses faced by the company in terms of business, marketing, technology, finance, use of raised funds, and development prospects;

(5) Other matters of concern to investors.

If the company holds an annual report presentation, it should issue a notice of the annual report presentation at least two trading days in advance. The announcement should include the date and time (no less than two hours), method of holding (on-site/online), location or website, and list of attendees.  

Article 22 The company may send company announcements, including periodic and interim reports, to investors or analysts and other relevant institutions and individuals.

Article 23 When communicating with investors through performance presentations, analyst meetings, roadshows, etc., on matters of investor concern such as the company's industry status, development strategy, production and operation, financial condition, dividend situation, and risk factors, the company must not disclose or leak any material non-public information. Online live broadcasts may be used to ensure all investors have the opportunity to participate. For online live broadcasts, the company should issue an announcement in advance, specifying the time, method, location, website, list of attendees, and theme of the investor relations activity.

Article 24 Before holding performance presentations, analyst meetings, or roadshows, the company should determine the scope of questions that can be answered in advance. If a question involves material non-public information, or if the answer can be inferred from material non-public information, the company should refuse to answer and must not disclose material non-public information.

If the company leaks material non-public information during investor relations activities, it should immediately issue an announcement through the designated information disclosure media and take other necessary measures.

After investor relations activities such as investor presentations, performance presentations, analyst meetings, and roadshows, the company should promptly prepare an investor relations activity record sheet and post it on the ir.cninfo.com.cn platform and the company website (if any) before the opening of the next trading day. The activity record sheet should at least include the following:

(1) Participants, time, location, and format of the activity;

(2) Communication content and specific question-and-answer records;

(3) A statement on whether the activity involved material information that should be disclosed;

(4) Attachments such as presentation materials and documents provided during the activity (if any);

(5) Other content required by the Shenzhen Stock Exchange.

Article 25 If the company needs to submit documents and provide material non-public information to its shareholders, actual controllers, or banks, tax authorities, statistical departments, intermediary institutions, or counterparties in business negotiations due to special circumstances, it should promptly report to the stock exchange and fulfill its information disclosure obligations in accordance with the relevant regulations of the stock exchange. The company should also require intermediary institutions and counterparties in business negotiations to sign confidentiality agreements to ensure that relevant information is not disclosed externally, and to undertake not to trade or recommend others to trade the company's stocks and derivatives before the relevant information is announced.

Article 26 If the company funds an analyst or other independent institution to publish an investment value analysis report, the words “This report is commissioned by the company” should be prominently displayed when publishing the investment value analysis report.

Article 27 On the premise of complying with information disclosure rules, the company shall establish a communication mechanism for major matters with investors. When formulating major plans involving shareholder rights and interests, the company shall communicate and negotiate fully with investors through various means. After making an announcement in accordance with the information disclosure rules and before the shareholders' meeting, the company may communicate fully with investors and widely solicit opinions through various means, such as on-site or online investor exchanges and presentations, visits to institutional investors, distribution of opinion solicitation letters, and establishment of hotlines, faxes, and email addresses. Relevant intermediary institutions hired by the company may also participate in relevant activities when communicating with investors.

Chapter 3 Fair Information Disclosure

Article 28 When releasing material non-public information, the company and relevant information disclosure obligors must disclose it publicly to all investors so that all investors can obtain the same information simultaneously. It is prohibited to privately disclose, reveal, or leak information in advance to specific entities such as institutional investors, analysts, or news media.

Specific entities include, but are not limited to:

(1) Institutions and individuals engaged in securities analysis, consulting, and other securities services, and their affiliates;

(2) Institutions and individuals engaged in securities investment, and their affiliates;

(3) News media and news professionals, and their affiliates;

(4) Shareholders holding or controlling more than 5% of the company's shares, and their affiliates;

(5) Other institutions or individuals identified by the company or the stock exchange.

When receiving research from institutions and individuals engaged in securities analysis, consulting, and other securities services, and institutions and individuals engaged in securities investment (hereinafter referred to as research institutions and individuals), the company should properly conduct relevant reception work and fulfill the corresponding information disclosure obligations in accordance with regulations.

Article 29 For direct communication between the company and research institutions or individuals, except for situations such as attending investment strategy analysis meetings held by securities company research institutes, the company should request research institutions and individuals to provide unit certificates and ID cards, and require them to sign a letter of commitment.

The letter of commitment should at least include the following content:

(1) Commitment not to intentionally inquire about the company's undisclosed material information, and without the company's permission, not to communicate or inquire with personnel other than those designated by the company;

(2) Commitment not to disclose inadvertently obtained undisclosed material information, and not to use the obtained undisclosed material information to trade the company's securities or advise others to trade the company's stocks and their derivatives;

(3) Commitment not to use undisclosed material information in investment value analysis reports, press releases, etc., unless the company discloses the information at the same time;

(4) Commitment that, in investment value analysis reports, press releases, etc., involving profit forecasts and stock price forecasts, the source of the information should be stated, and subjective assumptions and information lacking factual basis should not be used;

(5) Commitment to inform the company before the investment value analysis reports, press releases, etc., are released or used;

(6) Clearly define the responsibilities for violating the commitment.

The company, research institutions, and personnel must not use research activities to engage in market manipulation, insider trading, or other illegal or irregular activities.

The company should establish a post-facto verification procedure for accepting research, clarify the response measures and handling procedures for the leakage of undisclosed material information, and require research institutions and individuals to inform the company before releasing or using research reports such as investment value analysis reports and press releases based on communication.

If the company finds errors or misleading records during the verification process, it should request corrections; if corrections are refused, the company should promptly issue a clarification announcement; if undisclosed material information is involved, the company should immediately report to the stock exchange and issue an announcement, and at the same time require the specific parties not to disclose the information to the outside world before the company's formal announcement, and clearly inform them that they must not trade or advise others to trade the company's stocks and their derivatives during this period.

The controlling shareholder and actual controller of the company shall follow the provisions of Articles 28 and 29 when accepting research or interviews related to the company.

Article 30 If the company provides materials related to disclosed information to specific objects such as institutional investors, analysts, or news media, if other investors make the same request, the company should provide it equally.

Article 31 The company can expand the scope of information dissemination through methods such as holding press conferences, investor talks, and online briefings, so that more investors can learn about the company's publicly disclosed material information in a timely manner.

Article 32 During the implementation of the refinancing plan (including private placement), when conducting pricing and promotion activities to specific individuals or institutions, the company should pay special attention to the fairness of information disclosure and must not attract them to subscribe to the company's securities by providing them with undisclosed material information.

Article 33 When conducting investor relations management activities, the company should use publicly disclosed information as the content of communication and must not disclose or leak undisclosed material information in any way.

In investor relations activities, if there are questions involving or potentially involving price-sensitive matters, undisclosed material information, or information that can be inferred as undisclosed material information, the company should inform investors to pay attention to the company's announcements and provide necessary explanations on information disclosure rules.

The company must not replace formal information disclosure with communication in investor relations management activities. If the company inadvertently leaks undisclosed material information in investor relations management activities, it should immediately issue an announcement through qualified media and take other necessary measures.

Article 34 The company shall strictly fulfill its information disclosure obligations in accordance with the relevant laws, administrative regulations, departmental rules, normative documents, "Listing Rules," "Self-Regulatory Supervisory Guidelines," and other relevant regulations of the stock exchange. Information that may affect the investment decisions of shareholders and other investors should be actively disclosed voluntarily, and all investors should be treated fairly, and selective information disclosure should not be conducted.

Article 35 The company should try to avoid accepting on-site investor research, media interviews, etc., within 30 days before the disclosure of the annual report and semi-annual report. Before accepting interviews and research from specific objects, the controlling shareholder, actual controller, directors, supervisors, and senior management personnel of the company should inform the company secretary, who should properly arrange the interview or research process and participate throughout. The personnel accepting the interview or research should prepare written records of the research process and the content of the meeting, and jointly sign and confirm with the interview or research personnel. The company secretary should also sign and confirm.

Article 36 The company should establish and improve the internal control system and procedures for information disclosure related to investor relations management activities to ensure the fairness of information disclosure:

(1) The company should formulate reception and promotion regulations, the content of which should at least include the organizational arrangements for reception and promotion, arrangements for activity content, personnel arrangements, and regulations prohibiting the unauthorized disclosure, revelation, or leakage of undisclosed material information, etc.;

(2) The company should formulate an information disclosure filing and registration system to make detailed records of investor relations management activities such as research, communication, and interviews. The content should at least include the time, location, and method (written or oral) of the activity, the names of both parties, the content related to the company discussed during the activity, and the materials provided. The company should disclose the information disclosure filing and registration situation in the periodic report;

(3) The company should publicly disclose the relevant regulations for investor relations management activities.

Article 37 The company should strictly review information conveyed to the outside world in a non-formal announcement manner, set up a review or recording procedure, and prevent the leakage of undisclosed material information.

The above-mentioned non-formal announcement methods include: shareholder meetings, press conferences, product launch conferences; the company or relevant individuals accepting media interviews; directly or indirectly releasing press releases to the media; the company (including subsidiaries) websites and internal publications; blogs, Weibo, WeChat, and other social media of directors, supervisors, or senior management personnel; communicating with specific investors and securities analysts in written or oral form; various other forms of external publicity and reports of the company; and other forms identified by the Shenzhen Stock Exchange.

Chapter 4 Organization and Implementation of Investor Relations Management

Article 38 The company secretary of the board of directors is the person in charge of the company's investor relations management work.

Article 39 The company's board of directors office is the dedicated department responsible for the company's investor relations management work.

Article 40 The main responsibilities of the company's investor relations management include:

(1) Analysis and Research. Statistically analyze the number, composition, and changes in investors and potential investors; continuously monitor the opinions, suggestions, and reports from investors and the media, and promptly feedback to the company's board of directors and management.

(2) Communication and Liaison. Integrate and disseminate information needed by investors; hold analyst briefings and other meetings and roadshows, and respond to inquiries from analysts, investors, and the media; receive investor visits, maintain regular contact with institutional and small and medium-sized investors, and increase investor participation in the company.

(3) Public Relations. Establish and maintain good public relations with stock exchanges, industry associations, the media, other listed companies, and relevant institutions; after major events such as litigation, major restructuring, changes in key personnel, unusual stock trading, and significant changes in the operating environment, cooperate with the relevant departments of the company to propose and implement effective solutions, and actively maintain the company's public image.

(4) Other work conducive to improving investor relations.

Article 41 The company should establish a sound internal coordination mechanism and information collection system. The department or personnel responsible for investor relations should promptly collect information on production and operation, finance, litigation, etc., from various departments and subsidiaries, and all departments and subsidiaries of the company should actively cooperate.

Article 42 Unless explicitly authorized, senior management and other employees of the company may not speak on behalf of the company in investor relations activities.

Article 43 The company may hire professional investor relations agencies to assist in implementing the company's investor relations management.

Article 44 Personnel engaged in investor relations management by the company need to possess the following qualities and skills:

(1) A comprehensive understanding of all aspects of the company.

(2) Possessing a sound knowledge structure, familiar with corporate governance, financial accounting, and other relevant laws, regulations, and the operation mechanism of the securities market.

(3) Possessing good communication and coordination skills.

(4) Possessing good character and integrity.

Article 45 The company may adopt appropriate methods to conduct training on investor relations management-related knowledge for all employees of the company, especially senior management and heads of relevant departments. Specialized training may also be conducted when undertaking major investor relations promotion activities.

Except for the company secretary, other directors, supervisors, senior management personnel, and employees should avoid speaking on behalf of the company in investor relations activities unless explicitly authorized and trained.

Article 46 Within two trading days after investor relations activities such as performance briefings, analyst meetings, and roadshows, the company should prepare an investor relations activity record sheet and promptly publish this sheet, along with the presentation materials and documents provided during the activity (if any), on the Shenzhen Stock Exchange's interactive platform, and also on the company's website.

Article 47 Within 30 days prior to the disclosure of periodic reports, the company should try to avoid investor relations activities to prevent the leakage of undisclosed material information.

Article 48 The company should establish a complete filing system for investor relations activities. The investor relations activity files should at least include the following content:

(1) Participants, time, and location of investor relations activities;

(2) Content discussed in investor relations activities;

(3) Handling process and responsibility assumption (if any) for the leakage of undisclosed material information;

(4) Other content.

Investor relations management files should be classified according to the method of investor relations management, and relevant records, on-site recordings, presentation materials, documents provided during the activity (if any), etc., should be archived and properly stored. The retention period shall not be less than three years.

Chapter 5 Supplementary Provisions

Article 49 If this system conflicts with national laws, administrative regulations, rules, normative documents, and the company's articles of association, the provisions of national laws, administrative regulations, rules, normative documents, and the company's articles of association shall be followed.

Article 50 This system shall be formulated, amended, and interpreted by the board of directors.

Article 51 This system shall come into effect upon approval by the company's board of directors.

Shandong Keyuan Pharmaceutical Co., Ltd.

2024 Year  3  Month  28  Day