O9One 97 Communications543396Governance policy update

Board amends code of practices for fair disclosure of unpublished price sensitive information

The board has amended the company's Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information.

By ScoutQuest · Tue 27 Oct 2026, 4:16 PM IST · 2 min read

Amended Code Version

Version 3.0

Board Approval Date

October 26, 2026

Replaces Version

Version 2.0 of July 22, 2025

The company has shared an update on how it handles unpublished price sensitive information (UPSI) — information that can move the share price and is not yet public.

What was shared

• The board of directors amended the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information at its meeting held on October 26, 2026.
• The amended code is Version 3.0 and takes effect from October 26, 2026.
• It replaces Version 2.0 (board approval and effective date July 22, 2025); the first version was Version 1.0 of July 10, 2021.
• The disclosure was made to BSE (Scrip Code 543396) and NSE (Symbol PAYTM) under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
• The code will be hosted on the company's website.

What the code sets out

• Seven principles of fair disclosure: prompt public disclosure once credible and concrete information exists, uniform dissemination to avoid selective disclosure, quick dissemination if information leaks out selectively, fair response to news reports and market rumours, care that information shared with analysts is not UPSI, posting of transcripts of analyst and investor meetings on the website, and handling of UPSI on a need-to-know basis.
• The Chief Financial Officer is designated as the Chief Investor Relations Officer, responsible for overseeing dissemination and disclosure of UPSI.
• A Policy for Determination of Legitimate Purposes, attached as an annexure, lists the persons with whom UPSI may be shared in the ordinary course of business — auditors, accountancy firms, legal advisors, merchant bankers and consultants; contractual counterparties and business or commercial partners; lenders; customers and suppliers; and other advisors, consultants or partners. Anyone given UPSI this way is treated as an insider and must keep it confidential and not trade on it.
• The company must maintain a structured digital database of such sharing and must not outsource it. Information relating to UPSI that does not originate internally has to be entered in the database within 2 (two) calendar days of its receipt.
• Any leak or suspected leak of UPSI is to be handled under the company's inquiry policy, with the Chief Investor Relations Officer ensuring compliance.

How to read this

• The update is the text of a policy document — the rules the company follows for disclosing price-sensitive information and for sharing it internally and with outsiders.
• It is a governance and process update. It is not a statement about the company's financial performance, operations or any transaction.
• For a retail investor, the takeaway is procedural: a revised internal framework for how and when market-moving information is made public, and who inside and outside the company may receive it before it is public.

Nothing here is a view, opinion or recommendation of ScoutQuest, its parent, directors or employees. ScoutQuest is a technology company: this page was assembled automatically from public sources using artificial intelligence, and may contain errors or omissions. Confirm everything against the original source before you act on it. Any use of this page is at your own risk, and neither ScoutQuest nor its parent, directors or employees accepts liability for it.

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