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Majestic Ideal Holdings Ltd Statement of Policy Concerning Trading in Company Securities Adopted

Key Takeaway: Majestic Ideal Holdings Ltd has adopted a comprehensive Statement of Policy concerning the trading of company securities. This policy applies to all employees, officers, and directors, emphasizing compliance with applicable laws and regulations. The document outlines the use of inside information, responsibilities regarding trading practices, and consequences for insider trading violations. The company aims to ensure fairness in securities transactions and enhance transparency for shareholders.

Market Sentiment Analysis

POSITIVE FACTORS

  • Company demonstrates commitment to compliance with securities laws.
  • Introduction of clear guidelines for employees regarding trading activities.
  • Focus on transparency and equal access to information for investors.

CONCERNS & RISKS

  • Strict penalties outlined for insider trading violations could lead to severe consequences for individuals.
  • High compliance burden on employees and executives may create challenges in trading activities.

Full Press Release Details

Majestic Ideal Holdings Ltd
Statement of Policy Concerning Trading in Company
Adopted July 16, 2025
I Summary of Policy Concerning Trading in Company Securities 1
II The Use of Inside Information in Connection with Trading in Securities 1
A General Rule 1
B Who Does the Policy Apply To? 2
C Other Companies' Stock 2
D Hedging and Derivatives 3
E Pledging of Securities, Margin Accounts 3
F General Guidelines 3
G Applicability of U.S. Securities Laws to International Transactions 5
III Other Limitations on Securities Transactions 6
A Public Resales - Rule 144 6
B Private Resales 7
C Restrictions on Purchases of Company Securities 7
D Filing Requirements 7
I. SUMMARY OF POLICY CONCERNING TRADING IN COMPANY SECURITIES
It is the policy of Majestic Ideal Holdings Ltd
and its subsidiaries (collectively, the "Company") that it will, without exception, comply with all applicable laws
and regulations in conducting its business. Each employee, each executive officer and each director is expected to abide by this policy.
When carrying out Company business, employees, executive officers and directors must avoid any activity that violates applicable laws
or regulations. In order to avoid even an appearance of impropriety, the Company's directors, officers and certain other employees
are subject to pre-approval requirements and other limitations on their ability to enter into transactions involving the Company's
securities. Although these limitations do not apply to transactions pursuant to written plans for trading securities that comply with
Rule 10b5-1 under the Securities Exchange Act of 1934 (the "Exchange Act"), the entry into, amendment or termination
of any such written trading plan is subject to pre-approval requirements and other limitations.
II. THE USE OF INSIDE INFORMATION IN CONNECTION WITH
TRADING IN SECURITIES
The U.S. securities laws regulate the sale and
purchase of securities in the interest of protecting the investing public. U.S. securities laws give the Company, its officers and directors,
and other employees the responsibility to ensure that information about the Company is not used unlawfully in the purchase and sale of
All employees, executive officers and directors
should pay particularly close attention to the laws against trading on "inside" information. These laws are based upon the
belief that all persons trading in a company's securities should have equal access to all "material" information about
that company. Information is considered to be "material" if its disclosure would be reasonably likely to affect (1) an investor's
decision to buy or sell the securities of the company to which the information relates, or (2) the market price of that company's
securities. While it is not possible to identify in advance all information that will be deemed to be material, some examples of such
information would include the following: earnings; financial results or projections; dividend actions; mergers and acquisitions; capital
raising and borrowing activities; major dispositions; major new customers, projects or products; significant advances in product development;
new technologies; major personnel changes in management or change in control; expansion into new markets; unusual gains or losses in major
operations; major litigation or legal proceedings; granting of stock options; and major sales and marketing changes. When doubt exists,
the information should be presumed to be material. If you are unsure whether information of which you are aware is inside information,
you should consult with the Company's Chief Financial Officer. No individuals other than specifically authorized personnel may release
material information to the public or respond to inquiries from the media, analysts or others. If you are contacted by the media or by
a research analyst seeking information about the Company and if you have not been expressly authorized by the Company's Chief Financial
Officer to provide information to the media or to analysts, you should refer the call to the Chief Financial Officer. On occasion, it
may be necessary for legitimate business reasons to disclose inside information to outside persons. Such persons might include investment
bankers, lawyers, auditors or other companies seeking to engage in a potential transaction with the Company. In such circumstances, the
information should not be conveyed until an express understanding has been reached that such information is not to be used for trading
purposes and may not be further disclosed other than for legitimate business reasons. For example, if an employee, an executive officer
or a director of a company knows material non-public financial information, that employee, executive officer or director is prohibited
from buying or selling shares in the company until the information has been disclosed to the public. This is because the employee, executive
officer or director knows information that will probably cause the share price to change, and it would be unfair for the employee or director
to have an advantage (knowledge that the share price will change) that the rest of the investing public does not have. In fact, it is
more than unfair; it is considered to be fraudulent and illegal. Civil and criminal penalties for this kind of activity are severe.
The general rule can be stated as follows: It
is a violation of federal securities laws for any person to buy or sell securities if he or she is in possession of material inside information.
Information is material if there is a substantial likelihood that a reasonable investor would consider it important in making an investment
decision. It is inside information if it has not been publicly disclosed in a manner making it available to investors generally on a broad-based
non-exclusionary basis. Furthermore, it is illegal for any person in possession of material inside information to provide other people
with such information or to recommend that they buy or sell the securities. (This is called "tipping"). In that case,
they may both be held liable.
The Securities and Exchange Commission (the "SEC"),
the stock exchanges and plaintiffs' lawyers focus on uncovering insider trading. A breach of the insider trading laws could expose
the insider to criminal fines up to three times the profits earned and imprisonment up to ten years, in addition to civil penalties (up
to three times of the profits earned), and injunctive actions. In addition, punitive damages may be imposed under applicable state laws.
Securities laws also subject controlling persons to civil penalties for illegal insider trading by employees, including employees located
outside the United States. Controlling persons include directors, officers, and supervisors. These persons may be subject to fines up
to the greater of $1,000,000 or three times profit (or loss avoided) by the insider trader.
Inside information does not belong to the individual
directors, officers or other employees who may handle it or otherwise become knowledgeable about it. It is an asset of the Company. For
any person to use such information for personal benefit or to disclose it to others outside the Company violates the Company's interests.
More particularly, in connection with trading in the Company's securities, it is a fraud against members of the investing public
and against the Company.
All directors, executive officers and employees
of the Company must observe these policies at all times. Your failure to do so will be grounds for internal disciplinary action, up to
and including termination of your employment or directorship.
B. Who Does the Policy Apply To?
The prohibition against trading on inside information
applies to directors, officers and all other employees, and to other people who gain access to that information. The prohibition applies
to both domestic and international employees of the Company and its subsidiaries. Because of their access to confidential information
on a regular basis, Company policy subjects its directors and certain employees (the "Window Group") to additional
restrictions on trading in Company securities. The restrictions for the Window Group are discussed in Section F below. In addition, directors
and certain employees with inside knowledge of material information may be subject to ad hoc restrictions on trading from time to time.
C. Other Companies' Stock.
Employees, executive officers and directors who
learn material information about suppliers, customers, or competitors through their work at the Company, should keep it confidential and
not buy or sell stock in such companies until the information becomes public. Employees, executive officers and directors should not give
tips about such stock.
D. Hedging and Derivatives.
Employees, executive officers and directors are
prohibited from engaging in any hedging transactions (including transactions involving options, puts, calls, prepaid variable forward
contracts, equity swaps, collars and exchange funds or other derivatives) that are designed to hedge or speculate on any change in the
market value of the Company's equity securities.
Trading in options or other derivatives is generally
highly speculative and very risky. People who buy options are betting that the stock price will move rapidly. For that reason, when a
person trades in options in his or her employer's stock, it will arouse suspicion in the eyes of the SEC that the person was trading
on the basis of inside information, particularly where the trading occurs before a company announcement or major event. It is difficult
for an employee, executive officer or director to prove that he or she did not know about the announcement or event.
If the SEC or the Nasdaq were to notice active
options trading by one or more employees, executive officers or directors of the Company prior to an announcement, they would investigate.
Such an investigation could be embarrassing to the Company (as well as expensive), and could result in severe penalties and expense for
the persons involved. For all of these reasons, the Company prohibits its employees, executive officers and directors from trading in
options or other derivatives involving the Company's stock. This policy does not pertain to employee stock options granted by the
Company. Employee stock options cannot be traded.
E. Pledging of Securities, Margin Accounts.
Pledged securities may be sold by the pledgee
without the pledgor's consent under certain conditions. For example, securities held in a margin account may be sold by a broker
without the customer's consent if the customer fails to meet a margin call. Because such a sale may occur at a time when an employee,
executive officer or a director has material inside information or is otherwise not permitted to trade in Company securities, the Company
prohibits employees, executive officers and directors from pledging Company securities in any circumstance, including by purchasing Company
securities on margin or holding Company securities in a margin account.

Frequently Asked Questions

What is Majestic Ideal Holdings' trading policy?

The policy mandates compliance with laws and regulations for all employees, executives, and directors.

Who must follow the trading policy?

The policy applies to directors, officers, employees, and others with access to material information.

What restrictions exist for inside information?

Trading on inside information is prohibited; only authorized personnel can share material information.

Are there limitations on hedging transactions?

Yes, employees, executives, and directors cannot engage in hedging transactions involving options.

What are the penalties for insider trading violations?

Violators may face criminal fines, imprisonment, and civil penalties, including significant monetary damages.

Last updated: Jul 16, 2025