In accordance with Regulation 8 of Securities and Exchange Board of India (Prohibition Insider Trading) Regulations 2015 and any amendment thereof, the Board of the Company, has adopted this code of practices and procedures for fair disclosure of Unpublished Price Sensitive Information
All terms used but not defined herein shall have the meaning ascribed to such term under the Insider Trading Regulations. In case of any discrepancy between the Insider Trading Regulations and the terms defined herein, the meaning as ascribed under the Insider Trading Regulations shall prevail.
The Compliance Officer as defined above shall be responsible for, and deal with, the dissemination of information and disclosure of Unpublished Price Sensitive Information. He/She shall be responsible for ensuring that the Company complies with the continuous disclosure requirements of the Insider Trading Regulations and this code.
Trading restriction period shall be made applicable from the end of every quarter till 48 hours after the declaration of financial results. The gap between clearance of accounts by audit committee and board meeting should be as narrow as possible and preferably on the same day to avoid leakage of material information.
The disclosures to be made by any person under Chapter III of Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 shall include those relating to trading by such person’s immediate relatives, and by any other person for whom such person takes trading decisions. The disclosures so made shall be maintained by the company, for a minimum period of five years, in such form as may be specified.
(1) Initial Disclosures
Every person on appointment as key managerial personnel or a director of the company or upon becoming a promoter or member of the promoter group shall disclose his holding of securities of the company as on the date of appointment or becoming a promoter, to the company within seven days of such appointment or becoming a promoter.
(2) Continual Disclosures
Every promoter, member of the promoter group, designated person and director of every company shall disclose to the company the number of such securities acquired or disposed of within two trading days of such transaction if the value of the securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of ten lakh rupees or such other value as may be specified;
Every company shall notify the particulars of such trading to the stock exchange on which the securities are listed within two trading days of receipt of the disclosure or from becoming aware of such information.
The above disclosures shall be made in such form and such manner as may be specified by the regulator from time to time.
Any company whose securities are listed on a stock exchange may, at its discretion require any other connected person or class of connected persons to make disclosures of holdings and trading in securities of the company in such form and at such frequency as may be determined by the company in order to monitor compliance with these regulations.
The following action may be taken in case of leak of UPSI:
The Board reserves the power to review and amend this Policy from time to time. All provisions of this Policy would be subject to revision / amendment in accordance with applicable laws as may be issued by relevant statutory, governmental and regulatory authorities, from time to time. In case of any amendment(s),clarification(s), circular(s) etc. issued by the relevant statutory, governmental and regulatory authorities arenot consistent with the provisions laid down under this Policy, then such amendment(s), clarification(s), circular(s) etc. shall prevail upon the provisions hereunder.