公告日期：2025-12-23

ADAMA Ltd.

Insiders Registration Management Policy

（Revised in December 2025）

Chapter 1 General Provisions

Article 1 The Insiders Registration Management Policy (hereinafter referred to as “the
Policy”) is formulated pursuant to the Company Law of PRC, the Securities Law of
PRC(hereinafter abbreviated as the Securities Law), the Management Measures of
Information Disclosure of Listed Companies, the Stock Listing Rules of Shenzhen
Stock Exchange, Supervisory Guidelines of Listed Companies No.5 – Policy for
Registration of Insiders of Listed Companies, the Self-regulatory Supervision
Guidelines of Shenzhen Stock Exchange No.5 – Management of Information
Disclosure, and other relevant laws, regulations, regulatory documents as well as
relevant provisions of the Articles of Association of ADAMA Ltd. (hereinafter
referred to as "the AOA"), with a view to regulate the Insider Information
management of ADAMA Ltd. (hereinafter referred to as “the Company”), strengthen
the confidentiality of insider information and comply with the principle of fairness for
information disclosure.

Article 2 As the body responsible for the management of Insider Information, the
board of directors of the Company should ensure that the archives of Insiders are true,
accurate and complete. The Chairman of the Board shall be the primary responsible
person for the management of the Company's insider information. The Secretary of
the Board shall be responsible for the registration, filing and reporting of Insiders.
Both the Chairman and the Secretary of the board shall sign a written confirmation of
the truthfulness, accuracy and completeness of the Insiders' archives.

Article 3 The department of securities and legal affairs of the Company shall be
responsible for the comprehensive management, registration summarization,
disclosure and daily management of the insiders’filing.

The heads of other departments, controlled subs……
[点击查看PDF原文]

提示：本网不保证其真实性和客观性，一切有关该股的有效信息，以交易所的公告为准，敬请投资者注意风险。