Date: September 04, 2026

KMP / Board / Auditor Changes

Not Specified

Dividend Declaration or Non-Declaration

Not Specified

Board Meeting Outcomes

The Board of Directors adopted the Code of Practices and Procedure for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) and Code of Conduct in their meeting held on April 22, 2025.

Financial Results (Standalone & Consolidated)

Not Specified

Disinvestment / Strategic Actions

Not Specified

Other Operational / Legal / Strategic Disclosures

Code of Conduct Framework:

  • The company has adopted a comprehensive Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) and Code of Conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015.
  • The code aims to preserve confidentiality of UPSI and prevent its misuse while ensuring transparency and fairness with stakeholders.

Compliance Officer Designation:

  • Aakriti Bhushan, Company Secretary and Compliance Officer (Membership No. A67952), is designated as the Chief Investor Relations Officer (CIRO) for implementation of this code.

Key Principles:

  • Prompt public disclosure of UPSI that would impact price discovery
  • Uniform dissemination of UPSI to avoid selective disclosure
  • Appropriate response to queries on news reports and market rumors when requested by stock exchanges
  • Handling of UPSI on a need-to-know basis
  • Implementation of Chinese Wall policy separating insider areas from public areas

Trading Restrictions:

  • Trading window will be closed before 3 days of specific events and open 48 hours after publication of price sensitive information
  • Events triggering closure include: declaration of financial results (quarterly, half-yearly, annual), declaration of dividends, issue of securities, major expansion plans, amalgamation/mergers/takeovers/buybacks, disposal of substantial undertaking, changes in company policies/plks/operations
  • Designated persons cannot trade during closed trading window periods

Pre-clearance Requirements:

  • All designated persons must obtain pre-clearance for transactions exceeding 25,000 equity shares or ₹5.00 lakhs in value or 1% of total holding, whichever is lower
  • Trades must be executed within 7 trading days of approval
  • Minimum holding period of 180 days from date of purchase/actual allotment (30 days waiver possible for personal emergencies)

Disclosure Requirements:

  • Persons holding more than 5% shares must disclose holdings in Form A within 2 working days
  • Directors/officers must disclose holdings in Form B within 7 working days of appointment
  • Changes in shareholding exceeding 2% for major holders must be disclosed in Form C
  • Changes in shareholding by directors/officers exceeding ₹5.00 lakhs value or 25,000 shares or 1% of total holding must be disclosed in Form D
  • Company must disclose received information to stock exchanges within 2 days

Digital Database Requirements:

  • Designated persons must disclose names and PAN of immediate relatives, persons with material financial relationships, and contact numbers annually
  • Educational institutions and past employers information required on one-time basis

Penalties for Violations:

  • Violators may face penalties and appropriate action by the company after show-cause opportunity
  • Disciplinary actions include wage freeze, suspension, ineligibility for future ESOP participation
  • SEBI may also take action against violators

Effective Date: The code was adopted by the Board on April 22, 2025 and is subject to modification by the Board as needed.