Trading Symbol

PARAS (NSE)

Key Details

Board Approval

The Board of Directors of Paras Defence and Space Technologies Limited approved amendments to the Code for Prohibition of Insider Trading and Fair Disclosure of Unpublished Price Sensitive Information ("the PIT Code") at its meeting held on July 24, 2026.

Regulatory Basis

The amended policy has been formulated in accordance with the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time, specifically under Regulations 8 and 9 read with Schedules A and B.

Document Version and Effective Dates

  • Version: 3.0
  • Original Effective Date: 7th March, 2020
  • Amendment Date: 24th July, 2026
  • Document Owner: Secretarial and Compliance
  • Document Approver: Board of Directors

Key Policy Components

The amended Code comprises three parts:

  • Part A: General Provisions containing definitions and overarching principles
  • Part B: Code of Conduct for Regulating, Monitoring and Reporting of Trading by Designated Persons and their Immediate Relatives (framed under Regulation 9(1))
  • Part C: Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (framed under Regulation 8(1))

Significant Amendments and Features

Automated Trading Window Closure (PAN-Freeze Mechanism)

The policy incorporates SEBI Circular No. SEBI/HO/ISD/ISD-PoD-2/P/CIR/2025/55 dated April 21, 2025, requiring:

  • Freezing of PAN of Designated Persons and their Immediate Relatives at security level through Designated Depository (NSDL or CDSL)
  • Upload of PAN and demat account details to Designated Depository at least 2 trading days prior to trading window closure
  • Automatic implementation during declaration of financial results periods
Expanded Definition of "Immediate Relative"

Clarifies that a spouse is always an Immediate Relative regardless of financial independence. For parents, siblings, and children, they must be declared as Immediate Relatives if they routinely consult or align with the Designated Person before executing stock market trades.

Designated Persons Scope

Includes comprehensive categories:

  • Promoters, Members of Promoter group, all Directors
  • CEO, MD, KMP and all employees up to two levels below CEO/MD
  • Employees in Finance, Accounts, Secretarial/Legal, Corporate Communications, and IT departments with UPSI access
  • Executive Assistants, Personal Secretaries to Directors and KMPs
  • Any other employee, intermediary, or fiduciary identified by Compliance Officer
Trading Restrictions
  • Mandatory pre-clearance for trades exceeding prescribed thresholds
  • 7-day validity for pre-clearance approvals
  • Contra trade restrictions (no purchase followed by sale or vice versa within 6 months)
  • Trading window closure during UPSI periods, particularly from quarter-end until 48 hours after results dissemination
Reporting Requirements
  • Initial disclosure by KMPs/directors/promoters within 7 days of appointment
  • Continual disclosure for transactions aggregating over ₹10 lakhs within 2 working days
  • Annual disclosure of Immediate Relatives and persons with material financial relationships
  • One-time disclosure of educational institutions and past employers
Whistleblower Protection
  • Informant mechanism for reporting UPSI leaks
  • Protection against discharge, termination, demotion, suspension, threat, harassment, or discrimination
  • Oversight by Audit Committee
Structured Digital Database
  • Maintenance of database with names of persons/entities with whom UPSI is shared
  • 8-year preservation requirement
  • Time stamping and audit trails for non-tampering

Compliance Officer Details

  • Name: Minal Bhate
  • Designation: Company Secretary and Compliance Officer
  • Membership No.: A20188
  • Contact: +91-22-6919 9999, cs@parasdefence.com

Dissemination

  • The amended policy has been uploaded to the company's website at https://parasdefence.com/investors
  • Requested dissemination on stock exchange websites (BSE and NSE)

Forms and Documentation

The policy includes numerous prescribed forms:

  • Form I: Application for Approval of Trading Plan
  • Form II: Letter of Intimation of Trading Plan/Pre-clearance
  • Form III: Disclosure of Pre-cleared/Trading Plan Transactions
  • Form IV: Application for Pre-clearance of Trades
  • Form V: Annual/One-time Disclosure by Designated Persons
  • Form VI: Undertaking for Prevention of Insider Trading by Connected Person
  • Form B: SEBI-prescribed Initial Disclosure
  • Form C: SEBI-prescribed Continual Disclosure
  • Form D: SEBI-prescribed Transactions by Other Connected Persons

Penalties for Violation

Designated Persons who violate the Code may face:

  • Disciplinary action including wage freeze, suspension, recovery, clawback
  • Ineligibility for future participation in employee stock option plans
  • Reporting to stock exchanges and potential SEBI action
  • Disgorgement of profits from contra trades

Geographic and Contact Information

  • Company Address: D-112, TTC, Industrial Area, MIDC, Nerul, Navi Mumbai - 400706
  • BSE Address: Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai - 400 001
  • NSE Address: Exchange Plaza, Plot C/1, G Block, Bandra-Kurla Complex, Bandra (East), Mumbai - 400 051