Date: August 19, 2026

KMP / Board / Auditor Changes

Not Specified

Dividend Declaration or Non-Declaration

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Board Meeting Outcomes

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Financial Results (Standalone & Consolidated)

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Auditor’s Report

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Disinvestment / Strategic Actions

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Other Operational / Legal / Strategic Disclosures

UPSI Fair Disclosure Code Adoption

The company has framed and adopted a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) pursuant to Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.

Key Framework Elements

  • Chief Investor Relations Officer (CIRO): A senior officer designated to be responsible for dissemination of information and ensuring compliance with continuous disclosure requirements.
  • Prompt Public Disclosure: UPSI shall be disclosed to stock exchanges and disseminated promptly as soon as credible and concrete information comes into being.
  • Uniform Dissemination: UPSI shall be disseminated uniformly to all stakeholders through stock exchanges and the company's official website (www.shiprocket.in).
  • Response Procedures: Defined procedures for responding to queries on news reports or requests for verification of market rumors from regulatory authorities. Responses must be signed by the CIRO, CFO, Head of Public Relations, Compliance Officer, or another Board-authorized person.
  • Analyst Interactions: Only public information to be provided to analysts; if UPSI is shared, it must be simultaneously made public. Company representatives should be present at meetings, and discussions should be recorded and transcribed.
  • Need-to-Know Basis: UPSI shall be handled on a need-to-know basis and shared only with those who require it to discharge official duties or legal obligations.

Operating Guidelines for Legitimate Purpose (Annexure A)

  • Scope: Covers sharing UPSI in the ordinary course of business with partners, collaborators, lenders, distributors, customers, suppliers, merchant bankers, legal advisors, insolvency professionals, or other advisors/consultants.
  • Exclusions: Does not cover sharing with auditors (who have separate procedures) or regulatory/governmental authorities.
  • Determination Factors: Legitimate purpose is determined case-by-case based on nature/extent of UPSI, purpose, necessity, company/shareholder interests, and external circumstances.
  • Request Process: Employees must submit detailed requests specifying assignment particulars, nature of UPSI, rationale, and complete details of all persons (natural/legal) with whom information will be shared.
  • Notice and NDA: A due notice (format provided in Annexure I-A) must be served to all persons before sharing UPSI, making them aware of its nature and associated liabilities. Non-Disclosure Agreements (NDAs) may be required in exceptional circumstances.
  • Information Sharing Controls: UPSI should be shared via specific drives or password-protected emails with controls. Virtual Data Rooms (VDRs) may be used in exceptional cases.
  • Digital Database: A digital database with time-stamping and audit trails must be maintained for all persons with whom UPSI is shared, containing their details and the date of sharing.
  • Compliance & Review: The Authorised Officer ensures compliance; deviations are reported to the Audit Committee. Exceptions require Board approval. The guidelines are subject to annual review by the Audit Committee.