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Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information

As per sub-regulation (1) of regulation 8 of the SEBI (Prohibition of Insider Trading) Regulations, 2015

The Company will adhere to the following so as to ensure fair disclosure of events and occurrence that could impact price of its securities in the market.

  1. Make prompt public disclosure of unpublished price sensitive information that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available.
  2. Make uniform and universal dissemination of unpublished price sensitive unpublished price sensitive information to avoid selective disclosure.
  3. The Compliance Officer of the Company appointed under the said regulation shall act as chief investor relations officer to deal with dissemination of information and disclosure of unpublished price sensitive information.
  4. Make prompt dissemination of unpublished price sensitive information that gets disclosed selectively, inadvertently or otherwise to make such information generally available.
  5. Provide appropriate and fair response to queries on news reports and requests for verification of market rumors by regulatory authorities.
  6. Ensure that, information shared with analysts and research personnel is not unpublished price sensitive information.
  7. Develop best practices to make transcripts or records of proceedings of meetings with analysts and other investor relations conferences on the official website to ensure official confirmation and documentation of disclosures made.
  8. Handle of all unpublished price sensitive information on a need-to-know basis.
  9. Sharing of information with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, other advisors or consultants, shall be considered as "legitimate purposes" for the purpose of sharing unpublished price sensitive information in the ordinary course of business by an insider, provided that such sharing has not been carried out to evade or circumvent the prohibitions of the PIT regulations.
  10. A structured digital database shall be maintained containing the names of such persons or entities as the case may be with whom information is shared for legitimate purposes along with the Permanent Account Number or any other identifier authorized by law where Permanent Account Number is not available. Adequate and effective system of internal controls will also be laid out to ensure the compliance of maintenance of a digital database for sharing the information for said legitimate purposes.
  11. Any person in receipt of unpublished price sensitive information pursuant to a "legitimate purpose" shall be considered an "insider" for purposes of SEBI PIT regulations and such persons are also required to ensure the confidentiality of unpublished price sensitive information shared with them, in compliance with SEBI PIT Regulations.

(Note: Clauses 9 to 11 incorporated pursuant to SEBI (Prohibition of Insider Trading) (Amendment) Regulations, 2018 shall come into effect from 1stApril 2019