Date: 28.08.2026
Regulatory Disclosure
The company has submitted its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) to the National Stock Exchange of India Limited and BSE Limited, as required under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015. The policy has been uploaded on the Company's website www.lalithaajewellery.com.
Code Overview
The Fair Disclosure Code aims to preserve confidentiality of UPSI and prevent its misuse while ensuring timely and adequate disclosure. The code covers definitions of UPSI (including financial results, dividends, change in capital structure, mergers, acquisitions, changes in key managerial personnel) and generally available information.
Key Provisions
- The Company shall promptly disclose UPSI that would impact price discovery
- The Chief Financial Officer has been designated as the Chief Investor Relations Officer to deal with dissemination of information and disclosure of UPSI
- The Company shall ensure appropriate response to queries on news reports and market rumors
- Meetings with analysts shall be transcripted or recorded on the official website
Annexure A - Policy for Determination of Legitimate Purposes
Defines legitimate purposes for which UPSI can be shared, including:
- Sharing with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals or other advisors
- Communication in furtherance of performance of duties
- Discharge of legal obligations
- Any other genuine purpose determined by the Chief Investor Relations Officer
Digital Database Requirements
The Board shall maintain a structured digital database containing names of persons/entities with whom UPSI is shared along with PAN or other identifiers. The database must include internal controls like time stamping and audit trails, and be preserved for not less than eight years after completion of relevant transactions.
Confidentiality Obligations
Parties receiving UPSI must execute confidentiality and non-disclosure agreements and shall not trade in company securities when in possession of UPSI.
Leakage Investigation Procedure
If UPSI is leaked, the Company shall investigate and the Compliance Officer shall promptly notify the Chairman of the Audit Committee or Board Chairman. External consultants may be engaged, and appropriate action will be taken based on enquiry outcomes.
Effective Date
The code is effective from 17th February, 2024.