Board approves and adopts Code for Fair Disclosure of Unpublished Price Sensitive Information
The Board approved and adopted the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information under Regulation 8(1) of the SEBI PIT Regulations.
- Regulation
- Regulation 8(1) of the SEBI PIT Regulations
- Contra Trade Bar
- 6-month contra trade bar
- Code Adopted
- Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information
What was intimated
Under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, the company has intimated the exchanges that it encloses its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information, approved and adopted by the Board of Directors under Regulation 8(1) of the same regulations. The letter to the exchanges is signed by Vandan Shah, Company Secretary and Compliance Officer.
The enclosed document is titled Code of Conduct for Prevention of Insider Trading.
Who the Code applies to
- The reviewing and approving authority is the Board of Directors, and the Code applies to the company.
- Its preamble and objectives are directed at Designated Persons and their Immediate Relatives, who are expected to understand their obligations and keep such information confidential.
- The Code states that no person may use their position or knowledge to gain personal benefit or to provide benefit to a third party.
What it sets out to do
- Ensure adherence to the guidelines prescribed under the SEBI Regulations.
- Prevent Designated Persons from taking undue advantage of confidential or price sensitive information.
- Prevent legal, business and ethical conflicts, and the misuse of proprietary or confidential information.
- Guide Designated Persons in maintaining a high standard of probity.
- Address actual or potential conflicts of interest arising from dealings by research analysts in companies on which a research report is prepared or issued.
Key definitions a reader can track
- A "connected person" includes any person who is or has been, during the six months prior to the concerned act, associated with the company in any capacity that allows, or may reasonably be expected to allow, access to unpublished price sensitive information.
- A contra trade is a trade in the company's shares followed by an opposite trade within 6 (six) months of the prior transaction.
- Among the deemed connected persons is a concern, firm, trust, Hindu undivided family, company or association of persons in which a director of the company, his relative or the company's banker has more than ten percent of the holding interest.
The Code also refers to a structured digital database, a Chinese wall, trading plans, pre-clearance of trades and the Compliance Officer's role in monitoring adherence.
How to read this
This is a policy and process-level intimation. It tells the market how the company will handle unpublished price sensitive information and restrict trading by those who have access to it. Such codes form part of a listed company's insider-trading framework under the SEBI PIT Regulations.
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More numbers
- Contra trade period (opposite trade window)6 (six) months
- Look-back period to be a connected personsix months
- Holding interest threshold for deemed connected personmore than ten percent
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