Gateway Distriparks Limited's Board of Directors approved a revised Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) at its meeting held on October 28, 2026. This approval was made pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (PIT Regulations).

The revised Code of Fair Disclosure is available on the company's website at www.gatewaydistriparks.com in compliance with Regulation 8(1) of the PIT Regulations.

The Code includes comprehensive definitions of key terms including Unpublished Price Sensitive Information (UPSI), which encompasses financial results, dividends, change in capital structure, mergers/acquisitions, changes in key managerial personnel, changes in ratings, fund raising, significant agreements, fraud or defaults, insolvency proceedings, forensic audits, regulatory actions, litigation outcomes, guarantees, and license approvals.

Principles of Fair Disclosure

The Code outlines eight key principles:

1. Prompt public disclosure of UPSI that would impact price discovery

2. Uniform and universal dissemination of UPSI to avoid selective disclosure

3. Designation of a Chief Investor Relations Officer (CIRO) - the Company Secretary serves as both Compliance Officer and CIRO

4. Prompt dissemination of UPSI that gets disclosed selectively or inadvertently

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

6. Communication guidelines with analysts and research personnel

7. Development of best practices for recording meetings with analysts

8. Handling of all UPSI on a need-to-know basis

Policy for Legitimate Purpose Sharing

The Code includes Annexure I - Policy for Determination of Legitimate Purpose for Sharing of UPSI, framed under Regulation 3(2A) of SEBI PIT Regulations. This policy:

  • Applies to all Insiders as defined in the Code of Conduct
  • Permits sharing of UPSI for legitimate purposes including with professional advisers, financial institutions, counterparties in transactions, government authorities, and employees
  • Requires specific conditions before sharing UPSI: necessity of disclosure, limited information sharing, recipient notification, confidentiality agreements, proper authorization, and compliance with structured digital database requirements
  • Mandates maintenance of a structured digital database with prescribed details of persons/entities with whom UPSI is shared, including time stamps and audit trails

The Compliance Officer is responsible for overseeing compliance with the structured digital database requirements and the Code overall.

Amendments and Compliance

The Board may amend the Code as per applicable laws, rules and regulations. Any amendments will be intimated to Stock Exchanges and hosted on the company's website. The Code shall be read in conjunction with SEBI PIT Regulations and other applicable laws, with regulatory provisions prevailing in case of inconsistency.