{"url_path":"/sec/raasy/10-k/2026/item-16j","section_key":"item-16j","section_title":"Item 16J INSIDER TRADING POLICIES**","topic":"sec","document":{"doc_type":"20-F","doc_date":"2026-05-08","source_url":"https://www.sec.gov/Archives/edgar/data/1804583/0001493152-26-021875-index.html","accession_number":"0001493152-26-021875","cik":"0001804583","ticker":"RAASY","issuer_name":"Cloopen Group Holding Ltd","edgar_url":"https://www.sec.gov/Archives/edgar/data/1804583/0001493152-26-021875-index.html","primary_entity_key":"0001804583","primary_entity_name":"Cloopen Group Holding Ltd"},"word_count":480,"has_tables":true,"body_markdown":"**ITEM\n16J. INSIDER TRADING POLICIES**\n\n \n\nWe\nhave adopted an insider trading policy to promote compliance with applicable securities laws and regulations, including those that prohibit\ninsider trading. This policy applies to all officers, directors, employees and consultants of our company, or each an Affiliate, and\nextends to all activities within and outside an individual’s duties at our company. The insider trading policy establishes guidelines\nand procedures for the following:\n\n \n\n \n●\n**No\nTrading**: No Affiliate may purchase or sell any type of security or enter into a binding security trading plan in compliance\nwith Rule 10b5-1 under the Exchange Act, as amended, while in possession of material non-public information. Affiliates in possession\nof such information may not purchase or sell our securities until the later of (1) the expiration of a 48-hour waiting period following\npublic disclosure of the material information by us, and (2) the lapse of one full trading day following such public disclosure.\nAdditionally, Affiliates may not trade during limited trading periods, regardless of the possession of material information. All\ntransactions of securities by officers, directors, and key employees must be pre-approved by our compliance officer.\n\n \n \n \n\n \n●\n**Trading\nWindow**: The insider trading policy establishes a trading window for Affiliates, during which they can trade our securities\nor enter into a trading plan. The trading window begins at the close of business on the second trading day following the public disclosure\nof our financial results for the previous fiscal year or quarter and ends on the last day of each fiscal quarter. Trading during\nthe trading window does not provide a safe harbor, and Affiliates must comply with all policies.\n\n \n \n \n\n \n●\n**No\nTipping**: No Affiliate may directly or indirectly disclose any material information to anyone who trades in our securities.\n\n \n \n \n\n \n●\n**Confidentiality**:\nNo Affiliate may communicate any material information to anyone outside our company under any circumstances unless approved by the\ncompliance officer in advance, or to anyone within our company other than on a need-to-know basis.\n\n \n \n \n\n \n●\n**No\nComment**: No Affiliate may discuss any internal matters or developments of our company with anyone outside our company, except\nas required in the performance of regular corporate duties. Unless expressly authorized to do otherwise, if an Affiliate receives\nany inquiries about us or our securities from any press, investment analyst, investor or other outsiders, or any requests for comments\nor interviews, they should decline to comment and direct the inquiry or request to the compliance officer or any other office designated\nby the chief executive officer.\n\n \n \n \n\n \n●\n**Corrective\nAction**: If any information that may be considered material information is inadvertently disclosed, any Affiliate with knowledge\nof the disclosure should notify the compliance officer immediately.\n\n \n\nWe\nare committed to maintaining the highest standards of ethical conduct and have implemented these insider trading policies and procedures\nto ensure compliance with applicable securities laws and to protect the interests of our shareholders.\n\n \n\n140"}