ADAMALtd.Insiders Registration Management Policy

（Revised in December 2025）

Chapter 1 General Provisions

Article 1 The Insiders Registration Management Policy (hereinafter referred to as “thePolicy”) 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 subsidiaries and holding companies that

the Company can exert significant influence on shall be responsible for the

confidentiality of Insider Information within the scope of their management and shall

be responsible for the reporting and transmission of Insider Information to the

Secretary of the Board and the department of securities and legal affairs.Article 4 The Insiders stipulated by the Policy shall keep the Insider Information

confidential and shall not disclose any Insider Information or engage in insider

trading or cooperate with others to manipulate the price of the trading securities.

1Chapter 2 Scope of Insider Information

Article 5 The term "Insider Information" referred to in this Policy shall mean any

undisclosed information about the Company's operations or financials or information

that could materially affect the market price of the Company's shares or derivatives

according to the Securities Law.“Undisclosed information” means that the Company has not yet formally disclosed

such information on the Shenzhen Stock Exchange website or on media selected by

the Company that meet the requirement stipulated by CSRC.Article 6 Insider Information referred to in the Policy includes but is not limited to:

(I) Material changes to the Company's business strategies and scope

(II) Material investment by the Company or the purchase or sale by the Company

of significant assets which exceed thirty percent (30%) of the total assets of the

Company within one (1) year or the mortgage pledge sale or scrapping of major

assets of the Company exceeding thirty percent (30%) of such assets for business

purposes at one time.(III) The Company signs significant contracts or provides material guarantees or

engages in related-party transactions which may have a significant impact on the

Company's assets liabilities equity and operating results.(IV) The Company incurred material debts and failed to settle major debts due to

default or incurred a large amount of liability.(V) The suffering of material losses by the Company

(VI) Material changes in the external conditions of the Company's production

and operation.(VII) Changes in the directors of the board or the CEO of the Company; or

inability of the Chairman or CEO to perform his/her duties.(VIII) A substantial change to the shareholding of a shareholder who holds five

percent (5%) or more of the Company's shares or to the shareholding proportion or

control over the company of the person in effective control or a substantial change to

the business of the ultimate controller and other enterprises under its control which

are engaged in the same or similar business as the Company.(IX) Decisions made by the Company to reduce capital merge separate dissolve

or apply for bankruptcy; or commencement of bankruptcy proceedings by the

Company or the order of closure in accordance with the law.(X) Material litigation or arbitration involving the Company and resolutions of

the shareholders' meeting or the board of directors being revoked or declared invalid

in accordance with the law.(XI) Investigation conducted against the Company due to being suspected of

crimes or imposition of any enforcement measure in accordance with the law against

any of the Company's controlling shareholders ultimate controllers directors or

senior executives of the Company due to being suspected of crimes.

2(XII) Any plan made by the Company to distribute dividends or increase capital.

(XIII) Material changes to the Company's shareholding structure or production

and business conditions.(XIV) The transfer of shares held by the controlling shareholder prohibited by

the ruling of any court; five percent (5%) or more of the Company's shares held by

any shareholder being pledged frozen judicially auctioned held in custody placed in

trust or restricted in voting rights in accordance with the law or forced transfer of

ownership.(XV) The Company's main or all business comes to a halt; or its main assets are

seized sequestered frozen or its main bank accounts are frozen.(XVI) The Company issues new shares and bonds initiates equity incentive

plans repurchases shares and undertakes major asset restructuring.(XVII) Receiving additional income that significantly impacts the profit or loss

of the current period which may have a material impact on the Company's assets

liabilities equity or operating results.(XVIII) The contents of the Company's periodic reports financial statements

performance pre-announcements financial briefing and profitability forecast prior to

their disclosure in accordance with the law.(XIX) Other issues prescribed by the CSRC or the Shenzhen Stock Exchange or

other important information identified to have a significant impact on the trading

price of securities.Chapter 3 Scope of Insiders

Article 7 "Insider/s" referred to in the Policy shall mean any related personnel of the

Company both internally and externally who can directly or indirectly access and

obtain Insider Information before the disclosure of such Insider Information.Article 8 The scope of the Insider referred to in the Policy includes but is not limited

to:

(I) the Company its directors and senior executives

(II) shareholders holding 5% or more of the Company’s shares and their

directors supervisors and senior executives

(III) the ultimate controller of the Company and its directors supervisors and

senior executives

(IV) companies controlled by the Company or under its effective control and

their directors supervisors and senior executives

(V) persons who have access to Insider Information about the Company

because of their positions in the Company or because of their business

dealings with the Company.(VI) the acquirer of the Company or the trading party to a major asset

transaction and its controlling shareholder the person in ultimate control

directors supervisors and senior executives

(VII) relevant personnel of securities trading venues securities companies

3securities registration and settlement institutions and other service

institutions who have access to Insider Information because of their

positions and work

(VIII) staff of the securities supervision and administration authorities who can

obtain Insider Information because of their positions and work

(IX) staff of relevant competent authorities and regulatory bodies who can

obtain Insider Information because of their statutory duties to manage the

issuance and trading of securities the Company and its acquisitions and

major asset transactions

(X) other personnel who are aware of the Company's relevant Insider

Information due to the existence of relatives or business relations with any

of the natural persons specified in previous items

(XI) other persons who can obtain Insider Information as stipulated by the

CSRC.Chapter 4 Confidentiality Management of Insider Information

Article 9 Prior to the formal disclosure of insider information the directors of the

board senior executives and relevant personnel shall keep the number of persons who

are aware of such information to the minimum necessary and shall properly keep the

insider information and ensure its confidentiality.Article 10 Wherever the Company is required to provide undisclosed information to

any other entities or individuals it shall report to the department of securities and

legal affairs for record before doing so and should confirm that a confidentiality

agreement has already been signed with them or that they have been formally

notified of their confidentiality obligations in writing.Article 11 Before the public disclosure of Insider Information in accordance with the

law the controlling shareholder or ultimate controller of the Company shall not abuse

its rights as a shareholder or dominant position to require the Company and its

directors and senior executives to provide Insider Information.Article 12 The Insiders shall have the obligation of confidentiality. Before the

disclosure of the Insider information in accordance with the law the Insiders shall not

leak report or transmit the content of any Insider Information to the outside world or

spread it out in any form.Article 13 Relevant departments or related personnel frequently engaged in work

related to Insider Information should have a relatively independent and separate office

space and equipment in the premise that such arrangement is the interests of

confidentiality of Insider Information and facilitate the work.Chapter 5 Trading Restrictions over Insiders

4Article 14 Persons aware of insider information shall not prior to the lawful

disclosure of such information trade in the Company's shares or advise others to do

so on the basis of that information nor shall they use such information to seek profit

for themselves their relatives or any other person.Article 15 Persons with access to the Company's undisclosed financial information

shall not trade in its shares within fifteen days prior to the announcement of the

annual and half-yearly reports nor within five days prior to the announcement of the

quarterly report performance pre-announcement and briefings .Article 16 Persons with access to material non-republic information concerning the

Company shall not trade in its shares from the date on which such material non-public

events arise or are in the decision-making process until the date of its formal

disclosure in accordance with the law.Article 17 Before trading in the Company's shares and derivatives a person with

access to Insider Information shall consult the Secretary of the Board of directors. The

Secretary of the Board of directors shall verify the progress of the Company's

information disclosure and material matters etc. If such trading may be inappropriate

the Secretary of the Board of directors shall promptly notify the Insider who intends

to make the trading and alert the relevant risks.Article 18 Relevant persons shall declare the following to the responsible person of

each department entity and the Secretary of the Board of directors of the Company

within two trading days if they buy or sell shares and derivatives of the Company

during the period when they are the Insider of some certain information.(I) The number of shares held before this change.(II) The date quantity and price of the current share change.(III) The number of shares held after the change.(IV) Other explanations required by the Company such as a statement that no

Insider trading is involved.Article 19 The management of the shares of the Company held by its directors and

senior executives and the changes thereof shall be governed by the Rules Governing

the Shares of Listed Companies Held by their Directors and Senior Executives and the

Corresponding Changes.Chapter 6 Registration and Filing of Insiders

Article 20 Prior to the public disclosure of Insider Information pursuant to law the

Company shall fill in the archives on persons privy to Insider Information (as attached

in Annex 1) in accordance with the regulations. It shall promptly record the list of

insiders at each stage including deliberation and planning consultation and

5assessment and contract execution as well as during key procedures such as reporting

transmission compilation resolution and disclosure. It shall also document the time

location basis method and content of their knowledge of the insider information.Insider information knowers shall confirm the relevant records.Article 21 The Insider files should include but are not limited to the name position

ID card number employer contents of the Insider Information the access manner

time and place in which the Insider Information became known registration time

etc..Article 22 When the Company carries out major asset restructuring high proportion

of shares transferred equity changes that lead to the change in the ultimate controller

or the largest shareholder tender offer issuance of securities merger division

spin-off listing share repurchase annual report and semi-annual report equity

incentive draft and employee holding plan and other material matters that may have a

material impact on the trading price of the Company's shares and their derivatives as

required by the CSRC or Shenzhen Stock Exchange the Insider file shall be made and

submitted to Shenzhen Stock Exchange and a memorandum on the progress of

material events shall be made (see Annex 2). The contents of the memorandum

include but are not limited to the time of each key point in the planning and

decision-making process the list of participants in the planning and decision-making

process the way of planning and decision-making etc. The Company shall urge the

personnel relevant to the memorandum to sign and confirm. The Company's

shareholders ultimate controllers and their related parties and other relevant entities

shall cooperate in the preparation of the memorandum.Article 23The Company shall timely supplement and improve the archives on persons

privy to Insider Information and the information contained in the memorandum on the

progress of material events. The Insider archives and the memorandum on the

progress of material events shall be kept for at least 10 years as of the date of

recording (including supplementation and improvement).Article 24 The Company shall within five trading days after the Insider Information

is publicly disclosed according to law submit the Insider archives and the

memorandum on the progress of material events to the Shenzhen Stock Exchange.Where any material change occurs to the relevant matters after the disclosure of

material events by the Company it shall timely supplement and submit the Insider

archives and the memorandum on the progress of material events. Where abnormal

fluctuations have already occurred in the trading of the Company’s shares and

derivatives prior to the disclosure of any material event the Company shall submit the

relevant insider information records to the Shenzhen Stock Exchange.Article 25 The directors senior executives and the heads of the departments branches

(subsidiaries) and holding companies that can exert material influence shall actively

6cooperate with the Company in registering and filing of the Insider and timely inform

the Secretary of the Board of the Insider status and the changes of the relevant

Insiders.Article 26 The shareholders ultimate controllers and their related parties acquirers

counterparties other parties related to the Company who may have material influence

on the price of its securities trading securities companies accounting firms law firms

and other agency staff who knows Insider information shall actively cooperate with

the Company in the filing of Insiders and promptly keep it posted about the Insider

who is aware of the occurrence or proposed occurrence of any material event of the

Company as well as the changes of the Insider concerned.Article 27 Where the Company needs to submit information to the relevant

administrative authority on a regular basis according to the requirements of relevant

laws regulations and policies before disclosure it may provided that there is no

major change in the competent authority or contents be deemed as the same Insider

Information and the name of the administrative authority shall be recorded in the

same form and the time of submission shall be recorded on an ongoing basis. Except

for the aforesaid circumstances when the Insider Information is circulated to the

administrative authority the Company shall on the basis of one entry for one event

record in the Insider archives the name of the administrative authority the reason for

access to the Insider Information and the time when the Insider Information is known.Chapter 7 Accountability

Article 28 The Company shall in accordance with the provisions of the CSRC and

Shenzhen Stock Exchange conduct self-inspection on the trading of its securities by

persons privy to Insider Information. If the Company discovers that a person privy to

Insider Information has conducted insider trading divulged any Insider Information

or suggested any other person to conduct trading it shall verify and pursue

accountability of the relevant persons according to the Policy. Then within two

trading days it shall report the relevant information and the handling results to the

Hubei Securities Regulatory Bureau and the Shenzhen Stock Exchange and disclose

to the public accordingly

Article 29 If any employee of the Company who leaks the Insider Information to the

public or uses the Insider Information for insider trading or advises others to use the

Insider Information for trading etc. causes serious impact or loss to the Company the

board of directors shall in accordance with the severity of the circumstances and the

loss and impact caused give criticism warning demerit demotion of salary

probation dismissal of employment contract confiscation of illegal income etc. to

the relevant responsible personnel and require appropriate compensation accordingly.The sanctions imposed by the CSRC the Shenzhen Stock Exchange and other

regulatory authorities shall not affect the sanctions imposed by the Company on them.

7Article 30 The company has the right to pursue the responsibility of shareholders

holding 5% or more of its total shares and its ultimate controller who violate this

Rules disclose the information without authorization and cause losses to the

Company.Article 31 If the sponsors securities service institutions and their relevant personnel

who produce and issue special documents such as securities issue sponsorship audit

report asset evaluation report legal opinion financial advisory report and credit

rating report for the Company's material projects and the relevant entities and

personnel participating in the consultation planning and demonstration of the

Company's major projects disclose the information without authorization in violation

of the Policy the Company may depending on the severity of the circumstances

cancel or terminate contracts and it has the right to hold them accountable for any loss

caused to itself.Article 32 If the Insider violates the provisions of this Policy for insider trading or

other illegal activities and is punished by the Company administrative or judicial

institutions the Company will report the results of the punishment to Hubei Securities

Regulatory Bureau and Shenzhen Stock Exchange for the record and at the same time

make an announcement on the Company's designated information disclosure media.Article 33 Any Insider who violates the relevant national laws and regulations as well

as the provisions of the Policy uses Insider Information to manipulate the share price

causes serious consequences and constitutes a crime will be transferred to the judicial

authorities and the criminal responsibility will be investigated according to law.Chapter 8 Supplementary Provisions

Article 34 Any matters not covered by the Policy shall be executed in accordance with

the relevant laws regulations regulatory documents the AOA and other relevant

provisions.Article 35 The Policy shall be formulated interpreted and amended by the Board of

Directors of the Company.Article 36 The Policy shall be effective from the date of review and approval by the

Board of Directors replacing the "Management Rules for Registration of Insider"

passed at the Ninth meeting of the Ninth session of the board of directors.Board of Directors of ADAMALtd.December 22nd 2025

8Annexes.

1.Insiders Archives

2. Memorandum on the Progress of Material Events

9Annex 1: Insiders Archives

Securities Code: Abbreviation: Insider Information Item:

N Na Natio Types Certif Shareh Mo Add Affili Relat Posit Rel Type Time Place Way Conte At Regist Regis

o. me nality of icate olders’ bile ress ated ions ions ated s of to to to nts of Which ration tered

of Certifi No. Code Entit with Pers Relat Know Know Know Inside Period Time by

Insi cates y the on ions the the the r to

der Liste Inside Inside Inside Infor Know

d r r r matio Inside

Com Infor Infor Infor n r

pany matio matio matio Infor

n n n matio

n

Abbreviated Name of the Company:

Securities Code of the Company:

Signature of the Legal Representative:

Stamp of the Company:

Note: 1. The insider information matters should be kept in the way that one matter forms up one piece of record that is each insider file only

10involves one matter of insider information and different insider information matters involved in the file should be recorded separately.

2. The ways to know the insider information such as meetings telephone fax written reports e-mail etc. should be recorded.

3. When filling the content of the insider information to add the attached page for detailed explanation is allowed.

4. The period at which the insider information is informed such as negotiation and planning demonstration and consultation contract formation

internal company report transmission preparation resolution etc. should be recorded.

5. If it is a listed company please fill in the name of the registrant of the listed company; if it is a summary for the listed company please keep

the name of the original registrant in the summary form.

11Annex 2

Memorandum on the Progress of Material Events

Abbreviation of the Company:

Securities Code:

Overview of the Relevant Material Event:

Contents of

Manner of Participatin

Discussion

Plannin Tim Locatio Planning and g Institution Signatur

s and

g Stage e n Decision-makin and e

Resolution

g Personnel

s

Note: All relevant personnel should sign to confirm the process memorandum of the

material event.Signature of the Legal Representative:

Stamp of the Company:

12