Key Policies Adopted

Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons

  • Approved by Board of Directors on September 16, 2025
  • Becomes effective from the day of listing of shares at stock exchanges
  • Regulates trading by designated persons and their immediate relatives
  • Includes trading window restrictions, pre-clearance procedures, and contra trade restrictions

Policy on Code of Practices and Procedures for Fair Disclosure of UPSI

  • Formulated under Regulation 8(1) of SEBI PIT Regulations
  • Approved by Board of Directors on September 16, 2025
  • Ensures fair disclosure of unpublished price sensitive information

Designated Persons Coverage

The Code applies to:

  • Promoters and promoter group members
  • Directors and key managerial personnel of the company and its subsidiaries
  • Senior management including employees up to two levels below managing director
  • Auditors of the company
  • Officers in grade of Manager and above
  • Employees in functions likely to possess UPSI
  • Operational heads and unit heads with employees up to two levels below
  • Support staff with access to UPSI (IT, secretarial, legal)
  • Employees of material subsidiaries
  • Immediate relatives of all above persons

Compliance Officer Responsibilities

  • CS Arpit Nikunjbhai Thakkar appointed as Compliance Officer
  • Responsible for policy implementation, monitoring adherence, pre-clearance approvals
  • Maintains records of designated persons and their disclosures
  • Reports to Board and Chairman of Audit Committee annually

Key Procedures Implemented

Trading Restrictions

  • Trading window closure during sensitive periods (financial results, dividends, capital changes, etc.)
  • Minimum 48-hour window closure after financial results declaration
  • Pre-clearance required for trades exceeding ₹10,00,000 in value per calendar quarter

Reporting Requirements

  • Designated persons must disclose holdings within 7 days of appointment
  • Transaction disclosures required within 2 trading days for trades exceeding ₹10,00,000 value
  • Annual disclosures of securities holdings and immediate relative details
  • Monthly transaction statements required

Digital Database Maintenance

  • Structured digital database maintained for UPSI sharing records
  • Preservation period of 8 years after relevant transactions
  • Contains nature of UPSI, names of persons sharing/receiving information, PAN details

Effective Date

The policies become applicable from the day of listing of company shares at stock exchanges

Financial Impact

No specific financial impact quantified in the disclosure. The policies represent compliance measures with SEBI regulations.