Swaraj Engines Limited has amended its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (Code of Fair Disclosure) effective from October 12, 2026. The amendment was made in compliance with Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
The revised code defines Unpublished Price Sensitive Information (UPSI) to include information relating to financial results, dividends, change in capital structure, mergers, acquisitions, delistings, disposals, business expansion, changes in key managerial personnel, changes in ratings, fund raising, agreements impacting management or control, fraud or defaults, insolvency proceedings, forensic audits, regulatory actions, litigation outcomes, guarantees not in normal course, and licensing changes.
The code designates the Whole-time Director as Chief Investor Relations Officer (CIRO) responsible for ensuring timely, adequate, uniform and universal dissemination of UPSI. The CIRO oversees continuous disclosure requirements, coordinates disclosure to stock exchanges, analysts, shareholders and media, and educates employees on disclosure policies.
The policy includes procedures for responding to market rumors, requiring the company to confirm, deny or clarify any reported event or information in mainstream media within 24 hours when applicable as per SEBI notification.
For analyst and investor meetings, the code requires that only public information be provided, discussions should be recorded with at least two company representatives present, and transcripts should be posted on the company website. Unanticipated questions requiring price sensitive information must be made generally available before responding.
The code includes a Policy for Determination of "Legitimate Purposes" which allows sharing of UPSI in the ordinary course of business with designated persons, partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, consultants, credit rating agencies, bankers and other approved persons.
The company is required to maintain a structured digital database of persons with whom UPSI is shared, containing names and PAN numbers or other identifiers. Any violation of the policy may result in disciplinary action and reporting to SEBI.
The amended code is available on the company's website at https://swarajenterprise.com/policies.
Financial Impact
Financial impact not quantified in the disclosure. This is a procedural and compliance update without direct financial implications.