Fair Disclosure Code framed under SEBI PIT Regulations, intimated to exchanges

SRIT India Limited has framed a Fair Disclosure Code for Unpublished Price Sensitive Information, plus a policy on legitimate purposes.

Tue 6 Oct 2026

Code Version

Version 1.0, initial release, Board-approved

Regulatory Basis

Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015

Investor Relations Officer

The Company Secretary acts as the Investor Relations Officer

SRIT India Limited has informed the stock exchanges that it has framed a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information and for determination of legitimate purposes. The intimation is made under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, and a copy of the Code is enclosed with it.

What the Code is

A Fair Disclosure Code is the company's own stated framework for how it will release price-sensitive information to the market in a timely, uniform and non-selective way. The update sets out that a listed company's Board is required to formulate and publish such a framework for events and occurrences that could impact price discovery in the market for its securities.

What the Code covers

• What counts as Unpublished Price Sensitive Information (UPSI). The update lists items such as financial results, dividends, change in capital structure, mergers, de-mergers, acquisitions, delisting, disposals and expansion of business, award or termination of orders or contracts not in the normal course of business, changes in key managerial personnel, resignation of the statutory or secretarial auditor, change in ratings other than ESG ratings, fund raising proposed to be undertaken, agreements that may impact management or control, fraud or defaults, resolution plans or one-time settlements of bank borrowings, insolvency-related events, forensic audit findings, regulatory or judicial action, litigation outcomes, guarantees or indemnity for third parties, and key licence or regulatory approvals.
• How the company responds to queries on news reports and requests to verify market rumours from regulatory authorities, routed through authorised spokespersons only.
• How information is shared with analysts, institutional investors and research personnel, with meetings and calls to be transcribed or recorded on the official website.
• The 'need to know' principle, under which UPSI is handled only by those who need it to discharge their duties.
• How legitimate purposes for sharing UPSI are determined, by the Board on the basis of operating guidelines attached to the Code.

Who is responsible

The Company Secretary acts as the Investor Relations Officer for the Code and is responsible for dissemination of information and disclosure of UPSI. The intimation is signed by Nidhi Hitesh Vaswani, Company Secretary and Compliance Officer.

Version record

The Code is version 1.0, an initial release approved by the Board of Directors, and any amendment to it will be intimated to the stock exchanges and updated on the company's website.

Where it is available

The Code is enclosed with the exchange intimation and is also available on the company's website.

How to read this

This is a policy and disclosure-process intimation. It tells the reader that the company has a stated framework for fair, uniform and non-selective disclosure of price-sensitive information, and for how UPSI is identified, kept confidential and shared only for legitimate purposes.

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