ADAMALtd.Management Policy for Information Disclosure Suspension

and Exemption

Chapter I General Provisions

Article 1 To regulate the suspension and exemption of information disclosure by

ADAMA Ltd. (hereinafter referred to as the “Company”) and other information

disclosure obligors strengthen the management of information disclosure affairs and

protect the lawful rights and interests of investors this Policy is formulated in

accordance with the Securities Law of the People's Republic of China the Company

Law of the People's Republic of China the Administrative Provisions on the

Suspension and Exemption of Information Disclosure by Listed Companies the

Listing Rules of the Shenzhen Stock Exchange the Shenzhen Stock Exchange

Self-Regulatory Guidance No.5 - Management of Information Disclosure Affairs and

other relevant laws regulations regulatory rules and the provisions of the Articles of

Association of the Company.Article 2 This Policy shall apply to the suspension or exemption of disclosure of

interim reports by the Company and other information disclosure obligors as well as

the exemption of disclosing certain contents stipulated or required by the China

Securities Regulatory Commission (hereinafter referred to as “CSRC”) and the

Shenzhen Stock Exchange (hereinafter referred to as “SZSE”) in the periodic or

interim reports.Article 3 The Company and other information disclosure obligors shall disclose

information in a truthful accurate complete timely and fair manner. They shall not

abuse the suspension or exemption of disclosure to evade information disclosure

obligations or mislead investors nor shall they engage in illegal activities such as

insider trading or market manipulation.

1The Company and other information disclosure obligors shall prudently determine

matters for which disclosure may be suspended or exempted and shall implement such

decisions after completing internal review procedures.Chapter II Circumstances for the Application of Temporary

Suspension and Exemption from Information Disclosure

Article 4 Where the Company or other information disclosure obligor possesses

conclusive and sufficient evidence demonstrating that the information to be disclosed

involves national secrets or other matters whose disclosure may result in breaches of

state confidentiality regulations or administrative requirements (hereinafter

collectively referred to as “national secrets”) such disclosure shall be exempted in

accordance with the law.Article 5 The Company and other information disclosure obligors shall bear the duty

to safeguard national secrets. They shall not disclose national secrets through any

form of information disclosure investor communications and Q&As press releases

interviews or similar means nor shall they use the pretext of information being

classified for business promotion.The Company's Chairman and the Secretary of the Board shall enhance their legal

awareness regarding the safeguarding of national secrets ensuring that disclosed

information does not contravene national confidentiality regulations.Article 6 Where information to be disclosed by the Company or other information

disclosure obligor involves commercial secrets or confidential business information

(hereinafter collectively referred to as “commercial secrets”) and meets any of the

following circumstances and has not yet been made public or leaked disclosure may

be suspended or exempted:

(1) Information which pertains to core technologies and may give rise to unfair

competition if disclosed.

2(2) Information relating to the Company's own operations or the operations of

clients suppliers or other parties the disclosure of which may infringe upon the

Company's or such parties’ commercial secrets or seriously prejudice the interests of

the Company or such parties.

(3) Other circumstances where disclosure may seriously prejudice the interests

of the Company or other parties.Article 7 Where information contained in the Company's periodic reports to be

disclosed involves national secrets or commercial secrets disclosure of such

information may be exempted by employing methods such as using aliases

summarizing and generalizing or omitting key information.Where information in interim reports intended for disclosure by the Company or other

information disclosure obligors involves national secrets or commercial secrets

disclosure of such information may be exempted by employing methods such as using

aliases summarizing in aggregate form or omitting key details. Where disclosure

after employing the aforementioned methods still carries a risk of disclosure of

confidential information disclosure of the interim reports may be exempted.Article 8 Where the Company or other information disclosure obligor has suspended

or been exempted from disclosing commercial secrets they shall promptly disclose

such information upon the occurrence of any of the following circumstances:

(1) The reason for suspension or exemption has ceased to exist.

(2) The relevant information is difficult to keep confidential.

(3) The relevant information has been leaked or rumors have emerged in the market.

Chapter III Management of Suspension and Exemption for

Information Disclosure

Article 9 The internal review procedures for suspending and exempting information

3disclosure shall be as follows.

(1) Where matters arise that fall within the information disclosure scope by laws and

regulations the Listing Rules other relevant business rules of the Shenzhen Stock

Exchange or the Company's Information Disclosure Management Policy the

relevant departments subsidiaries and other information disclosure obligors of

the Company shall promptly notify the Secretary of the Board of such information.If they think such information should be suspended or exempted from disclosure

as outlined in this Policy a written application shall be submitted to the Secretary

of the Board at the same time. The application shall detail the reasons and basis

for suspension or exemption the potential impact of disclosure and shall include

supporting documentation and registration details of relevant insiders. The

responsible personnel shall be accountable for the authenticity accuracy and

completeness of the submitted materials.

(2) The Secretary of the Board shall review the information and may organize

relevant departments such as legal and finance to conduct deliberations as needed

and shall submit it to the Chairman for approval.Article 10 Where the Company resolves to suspend or exempt disclosure of relevant

information the Secretary of the Board shall promptly register and file such

resolution with the Chairman signing to confirm. Relevant registration materials shall

be retained by the Company's Securities and Legal Affairs Department for a period no

less than ten years.Article 11 The Company and other information disclosure obligors shall register the

following matters when suspending or exempting disclosure of information:

(1) The method of exemption which includes exemption from disclosing interim

reports and exemption from disclosing certain content within periodic and interim

reports etc.

(2) The type of documents subject to exemption which includes annual reports

half-yearly reports quarterly reports and interim reports etc.

4(3) The type of information subject to exemption which includes material

transactions routine transactions or related-party transactions in interim reports

or client and supplier names in annual reports etc.

(4) Internal review procedures.

(5) Other matters deemed necessary for registration by the Company.

Where disclosure is suspended or exempted due to commercial confidentiality in

addition to promptly registering the matters specified in the preceding paragraph the

following information shall also be recorded: whether the relevant information has

been made public through other manners the principal grounds for classifying it as a

commercial secret the potential impact of disclosure on the Company or others and

the list of insiders.Article 12 Where the Company or other information disclosure obligor suspends the

disclosure of an interim report or certain contents therein it shall promptly disclose

such information once the grounds for suspension cease to exist. Concurrently it shall

explain the principal reasons for classifying the information as a commercial secret

the internal review procedures followed and any securities transactions conducted by

relevant insiders during the suspension period.Article 13 The Company and other information disclosure obligors shall within ten

days of announcing the annual semi-annual or quarterly reports submit the relevant

registration materials pertaining to the suspension or exemption of disclosures during

the reporting period to the Hubei Securities Regulatory Bureau and the Shenzhen

Stock Exchange.Chapter IVAccountability

Article 14 Where a breach of information disclosure regulations occurs due to the

negligence of parties involved in such disclosures under this Policy resulting in

serious impacts or losses for the Company the responsible individuals shall be subject

5to disciplinary action including reprimand warning or even removal from their posts.

Chapter V Supplementary Provisions

Article 15 Where matters are not covered by this Policy or where this Policy conflicts

with relevant laws administrative regulations normative documents or other

provisions the relevant laws administrative regulations normative documents or

other provisions shall prevail.Article 16 This Policy shall be formulated interpreted and amended by the

Company's Board of Directors.Article 17 This Policy shall take effect and come into force from the date of their

approval by the Company's Board of Directors.Board of Directors of ADAMALtd.December 22nd 2025

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