Key Dates and Approvals
The revised Code was approved by the Board of Directors of Honasa Consumer Limited at its meeting held on May 21, 2026. The disclosure letter to the exchanges is dated May 22, 2026, and was digitally signed by Gaurav Pandit, Company Secretary and Compliance Officer, on the same date at 19:32:28 +05'30'.
Document Availability
The disclosure, including the enclosed Code, will be hosted on the Company's website at www.honasa.in.
Code Details and Purpose
The Code is effective from May 21, 2026. Its purpose is to ensure prompt, accurate, and non-discriminatory disclosure of UPSI, prevent selective disclosure, preserve the confidentiality of UPSI, and establish responsibilities for communications. It applies to Honasa Consumer Limited and, to the extent applicable, all its subsidiaries. All Directors, Key Managerial Personnel, employees, and persons acting on behalf of the Company are expected to comply.
Key Definitions
- Chief Investor Relations Officer (CIRO): Defined as the Chief Financial Officer of the Company.
- Legitimate Purpose: Defined as sharing information in the ordinary course of business with specified entities (promoters, employees, partners, lenders, customers, suppliers, advisors, etc.), provided it is not to evade regulations.
- Unpublished Price Sensitive Information (UPSI): Its meaning is assigned as per the Company's Code of Conduct for Prevention of Insider Trading.
Principles of Fair Disclosure
The Code outlines principles for adhering to Schedule A of the SEBI PIT Regulations, including:
- Prompt public disclosure of concrete UPSI.
- Uniform and timely dissemination of UPSI to stock exchanges and the company website.
- Disclosure of important press releases on the website.
- Hosting quarterly/annual results and related investor presentations on the website.
- Restricting responses to stock exchange or media enquiries to authorised personnel (CIRO).
- Promptly disseminating any UPSI that was disclosed selectively or inadvertently.
- Providing appropriate responses to queries on news reports and requests for verification of market rumours by Regulatory Authorities, but not commenting on every rumour unless requested by a Stock Exchange.
- Ensuring information shared with analysts is not UPSI and developing best practices for documenting such interactions.
- Basing communications with institutional shareholders on generally available public information.
- Handling UPSI on a need-to-know basis.
Policy for Determining Legitimate Purpose
The Code includes a policy for determining legitimate purposes for sharing UPSI:
- UPSI can be shared only on a need-to-know basis for legitimate purposes, not to evade regulations.
- It can be shared in the ordinary course of business if necessary to complete a task or activity for business interests.
- Subject to the above, UPSI can be shared with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, or other advisors/consultants for proposed assignments, professional services, or other business purposes. It can also be shared if mandatory for performance of duties or discharge of legal obligations.
Governance and Review
The Fair Disclosure Code is subject to review by the Board of Directors as and when deemed necessary.