Milky Mist Dairy Food Limited submitted a formal intimation to BSE Limited and National Stock Exchange of India Limited regarding compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015.

The company has framed a Code of Fair Disclosure and Code of Conduct for Prevention of Insider Trading as required under Regulation 8(1) of the SEBI PIT Regulations. This code became effective from the commencement of listing and trading of the company's equity shares on stock exchanges.

Key Policy Components

Unpublished Price Sensitive Information (UPSI) Definition:

  • Periodical financial results
  • Intended declaration of dividends (Interim and Final)
  • Change in capital structure
  • Mergers, demergers, acquisitions, delistings, disposals and business expansion
  • Major expansion plans or execution of new projects
  • Significant changes in policies, plans or operations
  • Changes in key managerial personnel
  • Other information the company may decide from time to time

Principles of Fair Disclosure:

  • Prompt public disclosure of credible and concrete UPSI
  • Uniform and universal dissemination to avoid selective disclosure
  • Designation of senior officers for information dissemination
  • Prompt dissemination of selectively disclosed information
  • Appropriate response to queries on news reports and market rumors
  • Ensuring information shared with analysts is not UPSI
  • Developing best practices for meeting transcripts
  • Handling UPSI on a need-to-know basis

Officer Designations:

  • Company Secretary designated as Chief Compliance Officer (CCO)
  • Chief Financial Officer designated as Chief Investor Relations Officer (CIRO)
  • CCO and CIRO responsible for dissemination of information and disclosure of UPSI
  • CCO responsible for ensuring compliance and educating employees

Policy for Determination of Legitimate Purposes (Annexure A):

  • Prepared in accordance with Regulation 3(2A) of Insider Trading Regulations
  • Identifies legitimate purposes for sharing UPSI while performing duties or discharging legal obligations
  • Factors for determining legitimate purpose include ordinary course of business, avoiding circumvention of regulations, company's best interests, legal/contractual obligations, and commensurate nature of information

Digital Database Requirements:

  • Structured digital database must be maintained containing nature of UPSI and names of persons/entities with whom information is shared
  • Must include Permanent Account Number or other authorized identifiers
  • Requires adequate internal controls and checks including time stamping and audit trails
  • Database must be preserved for not less than eight years after completion of relevant transactions

Entities Considered Legitimate Purposes:

  • Company's partners
  • Auditors, accountancy firms, legal advisors, and merchant bankers
  • Collaborators
  • Lenders
  • Customers
  • Suppliers
  • Insolvency professionals
  • Any other advisors/consultants/partners

Disclosure and Publication:

  • The policy has been uploaded on the company's website at https://www.milkymist.com/policies1
  • Will be disclosed in the Annual Report
  • Any amendments will be disclosed along with rationale in the Annual Report and on the website

The intimation was digitally signed by Prakash Sivasamy, Company Secretary and Compliance Officer (Membership No: A22495) on August 18, 2026, at 11:58:58 IST.