Key Details

  • The code was formulated pursuant to Regulation 8(1) of SEBI PIT Regulations, 2015
  • The policy was approved by the Board of Directors in their meeting dated November 28, 2025
  • Effective date of the code: November 28, 2025
  • Place of adoption: Hyderabad
  • Company CIN: U74999TG2016PLC109435

Policy Framework

The code is structured into three chapters:

Chapter I - Preliminary

Defines key terms including:

  • Unpublished Price Sensitive Information (UPSI) covering financial results, dividends, change in capital structure, M&A, changes in KMP, rating changes, fund raising, agreements impacting management, fraud/defaults, insolvency proceedings, forensic audits, regulatory actions, litigation outcomes, guarantees, and license changes
  • Designated Persons including directors, promoters, promoter group members, employees in grades 1-3, KMPs, finance/accounts/audit/tax/legal/secretarial/corporate communication/IT functions, and their immediate relatives
  • Connected Persons and those deemed to be connected persons
  • Legitimate purposes for sharing UPSI

Chapter II - Principles and Obligations

Applies to all Insiders including connected persons and designated persons and their immediate relatives. Emphasizes safeguarding confidentiality of UPSI and ensuring equal accessibility of information to all stakeholders.

Chapter III - Practices and Procedures

Outlines specific procedures including:

  • Prompt public disclosure of credible UPSI
  • Uniform dissemination through stock exchanges and company website
  • Designation of Compliance Officer as Chief Investor Relations Officer to handle information dissemination
  • Procedures for handling selective or inadvertent disclosure
  • Response protocol for queries on news reports and market rumors
  • Guidelines for interactions with analysts and research personnel (requires prior approval, recording of meetings, hosting presentations on website)
  • Handling of UPSI on need-to-know basis only
  • Policy for determination of legitimate purposes
  • Maintenance of structured digital database with names of persons/entities with whom UPSI is shared, along with PAN or other identifiers
  • Execution of confidentiality agreements with third parties sharing UPSI

Compliance Officer Details

  • Name: Vandana Modani
  • Designation: Company Secretary and Compliance Officer
  • Membership Number: A53323
  • Digitally signed the intimation on September 23, 2026 at 18:22:10 IST

Amendment Authority

The Board of Directors is authorized to amend or modify this Fair Disclosure Code as deemed necessary. Regulatory changes requiring modifications shall be binding on the Company even if not incorporated in the Policy.