Tonbo Imaging India544999Governance policy update

Fair disclosure code for unpublished price sensitive information intimated to exchanges

Tonbo Imaging has adopted a Code for fair disclosure of unpublished price sensitive information and for determining legitimate purposes, along with a policy for inquiring into leaks.

By ScoutQuest · Fri 23 Oct 2026, 4:46 PM IST · 3 min read

Regulatory basis: Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015
Intimation letter date: October 23, 2026
Database retention period: not less than eight years

What was intimated

A letter dated October 23, 2026 from the Company Secretary and Compliance Officer, addressed to NSE and BSE, intimating the "Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information and Determination of Legitimate Purposes".
The code is framed under Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, and the intimation is made under Regulation 8(2) of the same regulations.
The code is stated to be effective from the commencement of listing and trading of the company's equity shares on BSE Limited or the National Stock Exchange of India Limited.

What the code says

Unpublished price sensitive information (UPSI) is to be disclosed promptly, once credible and concrete information comes into being, so that it becomes generally available.
Dissemination is to be uniform and universal, with care taken to avoid selective disclosure.
Material events are to be disseminated as required under Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
If UPSI is disclosed selectively or inadvertently, prompt steps are to be taken to make it generally available, through stock exchange notification, press release, the company website or other means.
A Chief Investor Relations Officer, being the Compliance Officer, the Chief Financial Officer or a nominated senior official, authorises disclosure of UPSI. In a temporary absence, the managing director may nominate another official.

Handling of information shared with analysts and investors

No UPSI is to be disclosed selectively to any one analyst or group of investors to the disadvantage of other stakeholders.
If UPSI is shared in meetings with analysts, research personnel or investor meets, it is treated as selective disclosure and the company will disclose audio recordings or transcripts of those proceedings.
Recordings and transcripts of quarterly earnings calls and other such interactions are to be made available on the company's website.
The Chief Investor Relations Officer is to ensure fair responses to news reports and to requests from regulatory authorities for verification of market rumours within prescribed timelines, with a copy of any reply to one exchange sent to the other exchange as well.

Records and recipients

A structured digital database is to be maintained recording the nature of UPSI and the names of persons or entities with whom it is shared, with time stamping and audit trails to prevent tampering.
This database is to be preserved for a period of not less than eight years after completion of the relevant transactions, and until completion of proceedings if information is received from SEBI about an investigation or enforcement action.
Anyone given UPSI for a legitimate purpose is treated as an insider, must keep it confidential, and is to give a written undertaking not to trade in the company's securities while in possession of that information.

The two annexures

Annexure A is the Policy for Determination of Legitimate Purposes, prepared under Regulation 3(2A) of the insider trading regulations. It lists the factors for judging whether sharing information is for a legitimate purpose, such as whether it is in the ordinary course of business, whether it is meant to evade the regulations, whether it furthers a genuine commercial purpose, and whether the information matches the purpose.
Annexure B is the Policy and Procedure for Inquiry in Case of Leak or Suspected Leak of UPSI, framed under Regulation 9A(5), which the Board of Directors approved in its meeting held on December 20, 2025. It provides that an Inquiry Committee, comprising the Chief Financial Officer, Finance Controller, Director Data Science and the Company Secretary, will look into any leak or suspected leak, and that the Compliance Officer will inform the stock exchanges and SEBI about such an incident.

How to read this

This is a process and governance disclosure. It sets out the internal rules on how price sensitive information will be kept and released, and how leaks will be examined.
The intimation itself contains no financial results, order wins, capital actions or other business developments, so it does not by itself change the earnings picture of the company.

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