Nature of Disclosure: This is a regulatory intimation submitted to the National Stock Exchange of India Limited (NSE) and BSE Limited. The company is communicating the adoption and details of its "Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information" (Code of Fair Disclosure), as required under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (SEBI PIT Regulations).
Key Details of the Code:
The code was formulated by the Board of Directors of Moneyboxx Finance Limited pursuant to Regulation 8(1) of the SEBI PIT Regulations and its 2018 amendment.
Effective Date: The code is stated to be applicable from April 1, 2019.
Objective & Scope: The code's objective is to establish a framework for the fair disclosure of events that could impact the price discovery of the company's securities. It aims to ensure uniformity, transparency, and fairness in dealings with stakeholders and adherence to laws. The company commits to preserving the confidentiality of Unpublished Price Sensitive Information (UPSI) and preventing its misuse.
Oversight and Key Role:
- The Chief Investor Relations Officer (CIRO) is designated to oversee and coordinate the disclosure of UPSI. This role is also responsible for ensuring compliance with this code.
- The CIRO, in consultation with the Whole-time Director, CFO, and/or CEO, is empowered to decide whether a piece of information is price-sensitive.
- All UPSI is to be handled on a strict "need to know" basis.
Principles of Fair Disclosure: The code outlines several principles, including:
- Prompt public disclosure of credible and concrete UPSI.
- Uniform and universal dissemination of UPSI to avoid selective disclosure.
- Appropriate and fair response to queries on news reports and requests for verification of market rumors by regulatory authorities.
- Ensuring information shared with analysts is not UPSI.
- Developing best practices to publish transcripts of meetings with analysts on the company website.
Procedures:
- Prompt Disclosure: The company will ensure prompt dissemination of any price-sensitive event to the stock exchanges and will simultaneously publish the information on its website (
www.moneyboxxfinance.com). - Responding to Rumors: Authorized spokespersons (CIRO, Investor Relations Team, or other Board-authorized officials) are responsible for responding to market rumors and deciding if a public announcement is necessary.
- Sharing UPSI: UPSI can be shared only for "legitimate purposes," which include ordinary course of business with partners, lenders, advisors, auditors, etc., or for the discharge of legal duties and obligations.
- Notice to Recipients: Any person receiving UPSI for a legitimate purpose must be issued a notice informing them that the information is UPSI, making them aware of their duties and the liability for its misuse, and instructing them to maintain confidentiality.
- Digital Database: The CIRO is responsible for maintaining a structured digital database of all persons/entities with whom UPSI is shared. This database must contain the recipient's name, their organization, contact details, and PAN (or other authorized identifier). The database must be maintained with adequate internal controls to prevent tampering.
Amendments: The Board of Directors reserves the right to amend or replace this code. In case of any conflict between the code and prevailing law, the law shall take precedence. Any amendments to the code will be promptly intimated to the stock exchanges.
Availability: The updated code is attached to the disclosure and is also available on the company's website at www.moneyboxxfinance.com.