Paradeep Parivahan Limited has intimated the adoption of its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) to BSE Limited.

The Board of Directors approved and adopted this Code of Fair Disclosure at its meeting held on May 22, 2026, in compliance with Regulation 8 read with Schedule A of the SEBI (Prohibition of Insider Trading) Regulations, 2015. The Code sets out principles and practices to ensure timely, adequate, and uniform dissemination of UPSI.

The updated Code of Fair Disclosure has been placed on the company's website at https://www.paradeepparivahan.com/ for stakeholder information.

The Code includes definitions of key terms such as Act, Board, Company, Code, Connected Person, Employee, Insider, Trading, Securities, Trading day, Trading Window, and Unpublished Price Sensitive Information, all aligned with SEBI PIT Regulations.

Principles of Fair Disclosure

  • Prompt public disclosure of UPSI that would impact price discovery
  • Uniform and universal dissemination of UPSI through stock exchanges and company website
  • Disclosure of press releases and financial results on company website
  • Appropriate response to queries on news reports and market rumors by regulatory authorities
  • Development of best practices for transcripts of meetings with analysts
  • Handling of price sensitive information on a need-to-know basis

Chief Investor Relation Officer (CIRO)

The Board shall appoint a CIRO (who may be the CFO or any senior officer) to deal with dissemination of information and disclosure of UPSI. The CIRO may be contacted at cfo@paradeepparivahan.com and shall be responsible for compliance of this Fair Disclosure Code. Employees are prohibited from responding to enquiries without authorization from the CIRO or Managing Director.

Policy for Determination of Legitimate Purposes

Annexure-1 outlines the policy for sharing UPSI for legitimate purposes, which includes sharing in the ordinary course of business or on a need-to-know basis. Legitimate purposes inter-alia include sharing with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, and other consultants, provided it's not to evade regulatory prohibitions.

Illustrative examples of legitimate purposes include:

  • Investigation or request for information by statutory or governmental authorities
  • Proceedings or orders of courts or tribunals
  • Compliance with applicable laws and regulations
  • Contractual obligations or arrangements
  • Business requirements including promoting business strategies

The process for sharing UPSI requires insiders to: satisfy that information is UPSI and sharing is for legitimate purpose; identify recipients; notify recipients and enter into confidentiality agreements; use secure modes of sharing; and maintain a database of persons with whom information is shared.

System Audit and Review

The Company shall conduct periodic system audits at least once each financial year to ensure integrity of the system and data maintained. The policy will be automatically updated for any subsequent amendments/modifications in SEBI PIT Regulations or applicable laws.

Communication and Effective Date

The Policy has been communicated to all Directors, KMPs, Members of the Management Committee, and other concerned persons. It is effective from May 22, 2026.