Runwal Enterprises Limited (the "Company") has submitted a formal intimation to The National Stock Exchange of India Limited (NSE) and BSE Limited, pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 ("SEBI PIT Regulations").

The disclosure states that the Company, in compliance with Regulation 8(1) of the SEBI PIT Regulations, has formulated a "Code of Practices and procedures for fair disclosure of unpublished price sensitive information," officially titled the "Code of Conduct for Fair Disclosure." A copy of this code was enclosed with the submission to the exchanges.

Key Details of the Code:

  • Approval Authority: The Code was approved by the Company's Board of Directors.
  • Date of Approval: The approval was granted on March 22, 2025 (22/03/2025).
  • Version: The submitted code is identified as Version 1 (V1), owned by the Secretarial Department.
  • Effective Date: The policy takes effect from the date of commencement of listing and trading of the company's equity shares on the stock exchanges (BSE and NSE).
  • Availability: The Code has been hosted on the Company's official website, www.runwalenterprises.com.

Contents of the Code of Fair Disclosure:

The code is a comprehensive document structured with multiple sections and annexures, designed to ensure fair disclosure of Unpublished Price Sensitive Information (UPSI).

1. Introduction & Objective: The code is framed in accordance with SEBI PIT Regulations, 2015. Its primary objective is to prevent the misuse of UPSI, ensure its timely and adequate disclosure, and maintain uniformity, transparency, and fairness in dealings with all stakeholders.

2. Guidelines for Fair Disclosure: The code adopts the principles listed in Schedule A of the SEBI PIT Regulations. These include:

  • Prompt public disclosure of credible and concrete UPSI.
  • Uniform and universal dissemination of UPSI to avoid selective disclosure.
  • Promptly making generally available any UPSI that was disclosed selectively.
  • Responding appropriately to market rumours and verification requests.
  • Ensuring information shared with analysts is not UPSI; if UPSI must be disclosed, it should be provided to stock exchanges first.
  • Handling all UPSI on a strict 'need to know' basis.

3. Annexure A1 - Policy for Determination of Legitimate Purpose: This policy, formulated under Regulation 3(2A), defines "Legitimate Purpose" as sharing UPSI in the ordinary course of business on a need-to-know basis. It provides an illustrative list of purposes, including sharing with partners, lenders, customers, suppliers, advisors, auditors, and for statutory investigations or compliance. It mandates that any recipient of UPSI must be notified of its confidential nature and their responsibilities.

4. Annexure A2 - Policy for Procedure of Inquiry in Case of Leak of UPSI: This policy, mandated under Regulation 9A, outlines the procedure for handling leaks. Key elements include:

  • Duty of CIRO: The Chief Investor Relations Officer (CIRO) is responsible for overseeing compliance, coordinating with an Inquiry Committee, and promptly intimating any actual or suspected leak to SEBI.
  • Inquiry Committee: The Board will constitute a committee comprising the Managing Director, CFO, Compliance Officer, and CIRO (quorum of two).
  • Procedure: The committee will conduct a preliminary inquiry (a fact-finding exercise), which may involve appointing external agencies. A report must be submitted within 7 days.
  • Disciplinary Action: If a person is found guilty, the committee can recommend actions like wage freeze, suspension, recovery, or termination, in addition to any actions by SEBI.
  • SEBI Intimation Format: Schedule I provides a prescribed format for informing SEBI of a leak, requiring details like the name of the suspect, nature of information, medium of leak, and actions initiated.

The letter to the exchanges was signed digitally by Abhishek Kumar Jain, Company Secretary & Compliance officer, on November 06, 2026, at 00:07:26 IST.