Date: November 04, 2026

Board Meeting Outcomes

  • The Board of Directors approved amendments to the Code of Practices and Procedures for Fair Disclosure of UPSI and the Policy for Inquiry in Case of Leak or Suspected Leak of UPSI
  • The Board approved consolidation of these two separate policies into a single comprehensive Policy
  • The meeting commenced at 02:30 P.M. (IST) and concluded at 03:10 P.M. (IST) on November 04, 2026
  • The updated Policy is referenced as Version V.03, approved on November 04, 2026

Policy Framework Details

Part A - Code of Practices and Procedures for Fair Disclosure of UPSI

  • The Company Secretary & Compliance Officer (Aparna Sharma) serves as Chief Investor Relations Officer (CIRO)
  • CIRO contact email: investor@nivabupa.com
  • CIRO responsibilities include ensuring prompt public disclosure of UPSI, uniform dissemination, and preventing selective disclosure
  • UPSI must be shared only on need-to-know basis and for legitimate purposes
  • Authorized spokespersons: Managing Director & CEO, Executive Directors, CFO, CIRO, Investor Relations team, and specifically authorized employees
  • Structured Digital Database (SDD) must be maintained with UPSI details, shared parties' names and PAN/identifiers
  • SDD must be preserved for minimum 8 years after transaction completion

Part B - Policy for Inquiry in Case of Leak or Suspected Leak of UPSI

  • Inquiry Committee composition: Chief Financial Officer, Chief Compliance Officer, Chief Risk Officer, Chief Human Resource Officer, or any other person nominated by Managing Director & CEO
  • Quorum requirement: three members
  • Committee Secretary: Company Secretary & Compliance Officer
  • Whistleblower mechanism available for reporting actual or suspected UPSI leaks
  • Inquiry procedure includes: Receipt of Information & Intimation, Preliminary Inquiry (15 working days), Detailed Investigation (60 days)
  • Inquiry Committee has authority to access Company records, summon employees, and engage external forensic investigators

Compliance and Oversight

  • Audit Committee must review SEBI PIT Regulations compliance at least once every financial year
  • Policy review required at least once every two years by Audit Committee and Board of Directors
  • All records, complaints, proceedings, and investigation reports must be maintained for minimum 8 years
  • Policy available on company website: www.nivabupa.com