Code of Fair Disclosure for Unpublished Price Sensitive Information Approved
NSE has adopted a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) in compliance with SEBI's Insider Trading Regulations.
What is this Code?
National Stock Exchange has adopted a formal Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI). This is a regulatory requirement under SEBI's Prohibition of Insider Trading Regulations, 2015. The Code became effective immediately upon Board approval.
Key Objectives
The Code creates a framework to ensure fair, uniform and transparent disclosure of events that could impact the price of NSE's shares. It aims to prevent selective disclosure—where some investors or analysts get information before others—and to maintain consistent treatment of all stakeholders.
Who Runs This?
The Company Secretary and Compliance Officer serves as the Chief Investor Relations Officer (CIRO). This person is responsible for:
- Ensuring information is disclosed uniformly to everyone at the same time
- Assessing whether information is material and must be disclosed
- Monitoring how employees handle sensitive information
- Responding to regulatory queries about rumors
- Reviewing disclosure controls to ensure they work properly
How Information Gets Disclosed
Unpublished Price Sensitive Information must be disclosed to stock exchanges and posted on NSE's website as soon as credible and concrete information becomes available. The company follows timelines set by SEBI's Listing Obligations and Disclosure Requirements Regulations, 2015.
If sensitive information is accidentally disclosed to only some people—such as during a conversation with analysts or investors—the company must immediately make that same information public through stock exchanges and its website.
Keeping Information Confidential
Sensitive information is shared within the company or with external parties only on a need-to-know basis. If someone outside the company needs the information for a legitimate business purpose, strict wall-crossing procedures must be followed. All sharings are recorded and monitored.
Dealing with Analysts and Investors
When NSE holds conference calls, meetings or investor relations events
- Analysts, investors and research personnel must not receive any unpublished price-sensitive information
- If such information is shared, it must be publicly announced before or simultaneously
- Transcripts of calls and meetings are recorded and disclosed to stock exchanges and posted on the website
- Unexpected questions that might reveal sensitive data are noted for a considered response later, after consultation with the CIRO
Responding to Rumors
When regulatory authorities ask NSE to verify market rumors or respond to news reports, the company provides prompt and fair responses signed by the CIRO, Chief Financial Officer, or another designated person. Replies are copied to all stock exchanges where NSE is listed.
For Retail Investors: This Code ensures that you and other investors get material news about NSE at the same time, preventing insiders from trading on undisclosed information before the public knows about it. It reinforces NSE's commitment to fair market conduct.
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