Behari Lal Engineering Limited has adopted and disclosed its "Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information" (the "Code") pursuant to Regulation 8(1) of the SEBI PIT Regulations. The disclosure was made to both BSE Limited and the National Stock Exchange of India Limited on August 22, 2026.
The Code defines Unpublished Price Sensitive Information (UPSI) to include information relating to: financial results/statements; dividends; change in capital structure; mergers, demergers, acquisitions, delisting, disposals and expansion of business; award or termination of order/contracts not in the normal course of business; changes in Key Managerial Personnel other than due to superannuation or end of term; resignation of Statutory Auditor or Secretarial Auditor; change in rating(s) (other than ESG rating(s)); fund raising proposed to be undertaken; agreements impacting management or control of the company; fraud or defaults by the company, its promoter, director, key managerial personnel, or subsidiary; arrest of key managerial personnel, promoter or director; resolution plan/restructuring or one-time settlement in relation to loans/borrowings from banks/financial institutions; admission of winding-up petition; initiation of corporate insolvency resolution process; initiation of forensic audit and receipt of final forensic audit report; actions initiated or orders passed by regulatory, statutory, enforcement authority or judicial body against the company or its directors, key managerial personnel, promoter or subsidiary; outcome of any litigation(s) or dispute(s) impacting the company; giving of guarantees or indemnity for any third party not in the normal course of business; granting, withdrawal, surrender, cancellation or suspension of key licenses or regulatory approvals; and such other information as determined by the Board.
The Code designates the Chief Financial Officer of the Company (or such other senior official nominated by the board) as the Chief Investor Relations Officer ("CIRO") responsible for dissemination of information and disclosure of UPSI, responding to queries on news reports, and verification of market rumors by regulatory authorities.
The Code mandates that all UPSI shall be handled on a need-to-know basis and disseminated to stock exchanges in a continuous and timely manner. The CIRO must authorize all communications of UPSI with stock exchanges and oversee contents posted on the company website. Use of social media platforms to disclose material non-public information is prohibited as selective disclosure.
The Code includes a "Policy for Determination of Legitimate Purposes" (Annexure A) which permits sharing of UPSI with specified entities including regulators, directors, partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, accountants and auditors, advisors or consultants, insolvency professionals, and others as determined by the Compliance Officer to be in furtherance of a Legitimate Purpose.
The Company must maintain a structured digital database containing the nature of UPSI and names of persons/entities with whom information is shared, along with Permanent Account Numbers or other identifiers. This database must be preserved for not less than eight years after completion of relevant transactions with adequate internal controls and checks including time stamping and audit trails to ensure non-tampering.
The Code is effective from the commencement of listing and trading of the company's equity shares on stock exchanges, with relevant provisions applicable to 'proposed to be listed' companies becoming effective immediately. The Code has been made available on the company's website at www.beharilalengineering.com.