Date: November 05, 2026

Regulatory Compliance Disclosure

Bombay Coated and Special Steels Limited has submitted its "Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information" to BSE Limited and National Stock Exchange of India Limited. This submission is made pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.

The policy was framed under Regulation 8(1) of the SEBI PIT Regulations and is effective from March 21, 2025, following approval by the Board of Directors on that date.

Policy Framework Details

Definition of Unpublished Price Sensitive Information (UPSI):

The policy defines UPSI as any information relating to the company or its securities that is not generally available and would likely materially affect security prices upon becoming public. Specific categories include:

  • Financial results
  • Dividends
  • Change in capital structure
  • Mergers, demergers, acquisitions, delistings, disposals, and business expansion
  • Award or termination of orders/contracts not in normal course of business
  • Changes in key managerial personnel (other than superannuation or end of term)
  • Resignation of Statutory Auditor or Secretarial Auditor
  • Change in rating(s) (excluding ESG ratings)
  • Fund raising proposals
  • Agreements impacting management or control of the company
  • Fraud or defaults by company, promoter, director, KMP, or subsidiary
  • Arrest of key managerial personnel, promoter or director
  • Resolution plan/restructuring/one-time settlement for loans/borrowings
  • Winding-up petitions or insolvency proceedings
  • Initiation of forensic audit and receipt of final reports
  • Regulatory, statutory, enforcement or judicial actions against company or related parties
  • Outcome of litigations or disputes impacting the company
  • Giving guarantees or indemnities for third parties not in normal course of business
  • Granting, withdrawal, surrender, cancellation or suspension of key licenses or regulatory approvals

Principles of Fair Disclosures:

The company commits to eight principles including prompt public disclosure of UPSI, uniform dissemination, designation of Chief Investor Relations Officer, prompt response to selective disclosures, appropriate response to market rumors, ensuring information shared with analysts is not UPSI, maintaining records of investor meetings, and handling UPSI on need-to-know basis.

Procedure for Market Rumors:

The Compliance Officer, in consultation with MD or WTD, shall provide appropriate, fair and prompt responses to regulatory queries regarding news reports and market rumor verification requests. The company may also proactively clarify, confirm or deny reported events.

Legitimate Purpose Policy:

Defines legitimate purposes for sharing UPSI including performance of duties, compliance with legal obligations, pursuance of corporate actions, meeting regulatory requirements, evaluation of business opportunities, and other bonafide purposes.

Governance and Implementation

Compliance Officer: Sonam Dilipkumar Gupta, Company Secretary and Compliance Officer (Membership No.: A53881) is designated as the responsible officer.

Version History: First version approved by Board of Directors on March 21, 2025, effective from same date.

Website Disclosure: The policy is available on the company's website at https://www.bcsspl.in/

Conflict Resolution: In case of conflict between this Code and applicable laws, the provisions of applicable laws shall prevail.

Amendment Process: The policy will be reviewed periodically by the Board/Committee to comply with regulatory amendments, with material changes requiring Board approval.