Sahajanand Medical Technologies Adopts UPSI Fair Disclosure Code

The Code aims to:

Lay down practices and procedures for fair disclosure of Unpublished Price Sensitive Information (UPSI)
Set out processes to preserve the confidentiality of UPSI and prevent its misuse
Ensure timely and adequate disclosure of UPSI that could impact the price of the company's securities
Maintain uniformity, transparency and fairness in dealing with all stakeholders

The Company Secretary & Compliance Officer or any senior person authorized by the MD & CEO shall act as CIRO
CIRO is responsible for ensuring uniform and universal dissemination of information and disclosure of UPSI

Prompt Public Disclosure: The company shall endeavor to make prompt public disclosure of UPSI as soon as it has credible and concrete information through stock exchanges and its website
Uniform Dissemination: UPSI shall be disseminated uniformly to all stakeholders through stock exchanges and the company website
Response to Rumors: The company shall provide appropriate responses to regulatory queries about market rumors, especially those likely to substantially affect security prices
Analyst Interactions: Information shared with analysts must not be UPSI; if UPSI is shared, it must be simultaneously made public
Need-to-Know Basis: UPSI shall be made available strictly on a need-to-know basis following appropriate wall-crossing procedures

Defines 'Legitimate Purpose' as sharing UPSI in ordinary course of business with partners, collaborators, lenders, customers, suppliers, advisors, etc.
Prohibits all directors, designated persons, employees and other insiders from communicating UPSI except for legitimate purposes
Persons receiving UPSI for legitimate purposes are considered insiders and must maintain confidentiality
Provides illustrative list of legitimate purposes including statutory investigations, court proceedings, compliance requirements, strategic assessments, and bona fide business purposes

The company shall maintain an SDD containing nature of UPSI and names of persons who shared/received information
SDD shall include PAN or other authorized identifiers
Database shall have internal controls including time stamping and audit trails
Information must be entered within 2 calendar days of receipt
SDD shall be preserved for at least 8 years after transaction completion

The Code is available on the company website at www.smtpl.com
Amendments require prior Board approval, though Company Secretary can make changes to reflect SEBI notifications
Company Secretary and CFO shall review the Code periodically