SEBI responds to Avenue Supermarts' request for interpretive guidance on Designated Persons pledging shares for ESOP exercise funding.
SEBI clarifies that pledge creation/revocation for ESOP funding may be exempt from trading window restrictions if deemed bona fide by compliance officer.
Invocation of pledge is considered akin to sale and may attract contra trade restrictions based on surrounding transactions within six months.
The guidance states that bona fide purpose determination is case-specific and must align with the company's Code of Conduct and SEBI regulations.