SFC Environmental Technologies Limited submitted a formal intimation to the National Stock Exchange of India Ltd. and BSE Limited regarding its compliance with Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 ('SEBI PIT Regulations').

The disclosure attaches the company's Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information framed under Regulation 8(1) of the SEBI PIT Regulations. The policy became effective on November 28, 2024.

Key Policy Provisions

Definitions: The code defines key terms including:

  • Promoters: Mr. Sandeep Sudhakar Asolkar, Mr. Saketchandrasingh Pratapsingh Dhandoriya, and Mrs. Priya Sandeep Asolkar
  • Compliance Officer: A senior officer reporting to the Board, financially literate, responsible for policy compliance and monitoring
  • Designated Persons: Directors, Employees, and Connected Persons (including auditors, consultants, analysts) as identified by the Compliance Officer

Chief Investor Relations Officer: The Company Secretary has been appointed as the Chief Investor Relations Officer responsible for dissemination of information and ensuring compliance with continuous disclosure requirements.

Disclosure Principles:

  • UPSI shall be disclosed to stock exchanges and disseminated promptly on a continuous basis
  • Information shall be disseminated uniformly to all stakeholders through stock exchanges and the company's official website (www.sfcenvironment.com)
  • The company will use best endeavors to avoid selective disclosure

Procedures for Market Rumors:

  • Appropriate, fair and prompt responses shall be submitted to all queries on news reports and/or requests for verification of market rumors from regulatory authorities
  • Replies must be signed by the Compliance Officer or Managing Director (or CEO/CFO in their absence)
  • Copies of replies to one exchange must be sent to other exchanges where company shares are listed
  • Compliance Officer oversees corporate disclosure and decides whether public announcements are necessary for verifying/denying rumors

Analyst and Investor Relations:

  • Only public information will be provided to analysts, research personnel and institutional investors
  • Any UPSI provided must be simultaneously made public
  • Two company representatives should be present at meetings with analysts, and discussions should be recorded with transcripts disseminated on the website
  • Unanticipated questions will be taken on notice and responded to later, with public announcements if answers include UPSI

Operating Guidelines for UPSI Sharing:

The policy includes detailed 'Operating Guidelines for Determination of Legitimate Purpose & Approval for Sharing of Unpublished Price Sensitive Information' as Annexure A.

Legitimate Purpose Determination: Sharing UPSI is permitted for ordinary course of business with partners, collaborators, lenders, customers, suppliers, advisors, consultants, and for genuine corporate purposes. The Compliance Officer or Authorized Officer determines legitimate purpose case-by-case based on:

  • Nature and extent of UPSI
  • Purpose of data sharing
  • Necessity of data
  • Company and shareholder interests
  • External circumstances

Request Process: Requests for UPSI sharing must include:

  • Assignment particulars
  • Nature of UPSI sought
  • Rationale for sharing
  • Complete details of all persons (natural/legal) with whom information will be shared, including names, addresses, email, PAN/Aadhaar, contact numbers

Confidentiality Measures:

  • Notice must be served to recipients using prescribed format (Annexure I-A) making them aware of UPSI nature and liabilities
  • Non-Disclosure Agreements may be required in exceptional circumstances
  • Information sharing through specific drives, password-protected emails, or Virtual Data Rooms (VDR) with controlled access
  • VDR access limited to view rights for most users, with download/print rights for maximum three persons per entity
  • Data files in VDR must be deleted within two months of purpose completion (maximum one year retention)

Database Maintenance: A digital database of all persons with whom UPSI is shared must be maintained with time-stamping and audit trails, containing all recipient details and date of sharing.

Governance:

  • The Authorized Officer ensures compliance with guidelines
  • Deviations must be reported to the Audit Committee
  • Exceptions to guidelines require Board approval
  • Guidelines subject to annual review by Audit Committee

The intimation was digitally signed by Shweta Deshpande (Company Secretary & Compliance Officer, Membership No. A67764) on November 3, 2026.