Date: September 17, 2026

KMP / Board / Auditor Changes

Not Specified

Dividend Declaration or Non-Declaration

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Board Meeting Outcomes

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Financial Results (Standalone & Consolidated)

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Auditor’s Report

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Disinvestment / Strategic Actions

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Other Operational / Legal / Strategic Disclosures

This document is an intimation to the stock exchanges (BSE and NSE) regarding the adoption and disclosure of the company's updated "Prohibition of Insider Trading Policy" and its constituent codes, as required by SEBI Regulations.

The enclosed policy document is comprehensive and includes the following key components:

1. Prohibition of Insider Trading Policy
  • Preamble: The policy has been adopted by the Board of Directors of LCC Projects Limited to comply with the SEBI (Prohibition of Insider Trading) Regulations, 2015 ("SEBI PIT Regulations").
  • Applicability: The policy is applicable to all Insiders of the Company, including Designated Persons and their immediate relatives.
  • Objective: The policy aims to regulate, monitor, and report trading by insiders and ensure fair disclosure of Unpublished Price Sensitive Information (UPSI).
2. Definitions

A detailed list of definitions is provided for key terms, including:

  • 'Act', 'Board', 'Company', 'Compliance Officer' (currently the Company Secretary).
  • 'Connected Persons', 'Contra Trade', 'Dealing in Securities'.
  • 'Designated Person' (includes Promoters, Directors, KMPs, senior managers in key departments, other designated employees, and their immediate relatives).
  • 'Immediate Relative', 'Insider', 'Insider trading', 'Key Managerial Personnel'.
  • 'Legitimate purpose', 'Officer of the Company', 'Promoter and Promoter Group'.
  • 'Securities', 'Trading', 'Trading Day'.
  • 'Unpublished price sensitive information (UPSI):' Defined in detail and includes information relating to:
  • Financial results
  • Dividends
  • Change in capital structure
  • Mergers, de-mergers, acquisitions, delistings, disposals, expansion of business
  • Changes in key managerial personnel
  • Change in ratings
  • Fund raising
  • Agreements impacting management or control
  • Fraud or defaults by the company or its key personnel
  • Resolution plans/restructuring for loans
  • Insolvency proceedings under IBC
  • Initiation of forensic audits and receipt of reports
  • Regulatory or judicial actions against the company or its personnel
  • Outcome of material litigations
  • Giving guarantees not in the normal course of business
  • Granting, withdrawal, surrender, cancellation or suspension of key licenses or regulatory approvals.
  • 'Valid Trading Window'.
3. Code of Practices and Procedures for Fair Disclosure of UPSI [Under Regulation 8(1)]

This code outlines principles for the fair disclosure of UPSI:

  • Prompt Public Disclosure: The company will promptly disclose UPSI that would impact price discovery.
  • Uniform Dissemination: Disclosure will be continuous, immediate, uniform, and universal.
  • Overseeing Disclosure: The Company Secretary & Compliance Officer is responsible for overseeing corporate disclosures and ensuring compliance.
  • Responding to Rumors: The company will appropriately respond to queries on news reports and market rumors.
  • Transcripts of Meetings: Best practices will be developed to make transcripts of analyst meetings available on the website.
  • Need-to-Know Basis: UPSI shall be handled on a strict "need to know" basis.
  • Policy for Determination of "Legitimate Purposes": An annexure (Annexure-A) details the policy for sharing UPSI for legitimate purposes, which includes sharing in the ordinary course of business with partners, collaborators, lenders, auditors, legal advisors, etc. It mandates maintaining a structured digital database of persons with whom UPSI is shared.
4. Code of Conduct to Regulate, Monitor and Report Trading by Insider [Under Regulation 9(1)]

This code is binding on all designated persons and their immediate relatives. Key provisions include:

  • Compliance Officer: The Company Secretary is appointed as the Compliance Officer, with defined duties including maintaining records of designated persons, specifying prohibited periods, pre-clearing trades, and reporting to the Board/Audit Committee.
  • Preservation of UPSI: UPSI must be handled on a need-to-know basis. Guidelines are provided for maintaining confidentiality and securing files containing UPSI.
  • Trading Restrictions: Designated persons are prohibited from trading when in possession of UPSI, except per an approved trading plan. Contra trades (opposite transactions within 6 months) are restricted and require prior approval.
  • Chinese Walls: Policies and procedures are to be established to prevent the inadvertent spread of UPSI within the company.
  • Trading Window: A trading window is specified. It is closed from the end of every quarter until 48 hours after results declaration, and 7 days prior to the publication of any other UPSI. Trading is prohibited during this "Prohibited Period".
  • Trading Plan: Designated persons can formulate an irrevocable trading plan for approval by the Compliance Officer, with specific conditions on its formulation and execution.
  • Pre-clearance of Trades: Designated persons must seek pre-clearance from the Compliance Officer before trading. The Board is the approving authority for trades by the Compliance Officer and Executive Director.
  • Disclosure Requirements: Detailed initial and continual disclosure requirements are mandated for designated persons, including holdings of securities, details of immediate relatives, and persons with whom they share a material financial relationship. Various forms (Form I to Form XIII) are prescribed for these disclosures.
  • Penalties: Violations may lead to disciplinary action, including termination of services, and reporting to SEBI.
5. Policy and Procedures for Inquiry in Case of Leak of UPSI

This policy outlines the procedure for reporting and investigating suspected leaks of UPSI:

  • Reporting: Suspected violations can be reported to an immediate superior, the Compliance Officer (cs@lccprojects.com), or the Chairman of the Audit Committee if the superior/Compliance Officer is involved.
  • Investigation: The management will investigate and report to the Audit Committee. Cooperation is mandatory, and false information can lead to disciplinary action.
  • Remedial Action: If a violation is confirmed, effective remedial action will be taken, which may include disciplinary action up to termination.
  • Reporting: The Compliance Officer will provide a quarterly report of complaints to the Audit Committee.
6. Forms

The document includes numerous prescribed forms (Form I to Form XIII) for maintaining records and making disclosures as required under the policy.