Company Disclosure Submission

Key Details

  • The amended UPSI disclosure policy was approved by the Board of Directors at its meeting held on Friday, May 22, 2026.
  • The policy is available on the company's website at www.belding.ltd.
  • The disclosure was signed by Muskan Gurumukhdas Pinjani, Company Secretary and Compliance Officer, on May 23, 2026 at 07:55:22 +05'30'.

Policy Framework Overview

The amended policy establishes a comprehensive framework for fair disclosure of Unpublished Price Sensitive Information with the following key components:

Regulatory Basis

  • Formulated in accordance with Regulation 8 of SEBI PIT Regulations, 2015
  • Read with applicable provisions of Companies Act, 2013 and other relevant laws

Definition of UPSI

The policy defines Unpublished Price Sensitive Information as any information relating to the company or its securities that is not generally available and would likely materially affect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. This includes but is not limited to:

  • Financial results
  • Dividends
  • Change in capital structure
  • Mergers, demergers, acquisitions, delistings, disposals, and business expansion
  • Changes in key managerial personnel (excluding superannuation/end of term)
  • Change in ratings (excluding ESG ratings)
  • Fund raising proposals
  • Agreements impacting management or control
  • Fraud or defaults by company/promoter/director/key personnel
  • Resolution plans/restructuring/one-time settlements for loans
  • Insolvency proceedings under IBC 2016
  • Initiation of forensic audits and receipt of final reports
  • Regulatory/enforcement actions against company or its personnel
  • Outcome of litigations/disputes impacting the company
  • Guarantees/indemnities/sureties not in normal course of business
  • Granting/withdrawal/surrender/cancellation/suspension of key licenses

Principles of Fair Disclosure

The policy outlines seven key principles:

1. Prompt public disclosure of credible and concrete UPSI

2. Uniform and universal dissemination to avoid selective disclosure

3. Compliance Officer acts as Chief Investor Relations Officer (CIRO)

4. Prompt dissemination of selectively disclosed UPSI

5. Appropriate response to queries on news reports and market rumors

6. Ensuring information shared with analysts is not UPSI

7. Maintaining transcripts/records of analyst meetings on website

8. Handling UPSI on need-to-know basis

Sharing UPSI for Legitimate Purposes

UPSI may be shared only for legitimate purposes on need-to-know basis, including:

  • Ordinary course of business with partners, collaborators, lenders, customers, suppliers
  • With merchant bankers, legal advisors, auditors, insolvency professionals, consultants
  • Where communication is in furtherance of performance of duties and legal obligations

Recipient Requirements

Persons receiving UPSI must be given notice regarding:

  • Awareness that information is UPSI
  • Duties and responsibilities attached to receipt of UPSI
  • Liability for misuse or unwarranted use
  • Instruction to maintain confidentiality

Digital Database Maintenance

The CIRO must maintain a structured digital database of UPSI recipients containing:

  • Name of recipient
  • Organization/entity represented
  • Postal address and email ID
  • PAN or other authorized identifier

The database must include internal controls and checks such as time stamping and audit trails to prevent tampering.

Amendment Process

The Board of Directors may review and amend the code periodically. Provisions are subject to revision based on rules, regulations, notifications issued by statutory authorities.

The policy was last amended by the Board of Directors at its meeting held on May 22, 2026.