WeWork India Management Limited has submitted a regulatory filing to the National Stock Exchange of India Limited and BSE Limited regarding amendments to its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI).
The Board of Directors of the Company, at its meeting held on October 26, 2026, reviewed and approved the amended Code framed under Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015. The amended Code is available on the company's website at https://wework.co.in/investors-relations/shareholders-information/#codes-and-policies.
The document specifies that this is Version 3.0 of the Code, with an original approval and effective date of September 27, 2024, last reviewed/amended on October 17, 2024, and most recently reviewed/amended on October 26, 2026.
Key Components of the Code:
Definitions: The Code provides comprehensive definitions of key terms including Board, CFO, Chief Investor Relations Officer (CIRO), Company, Compliance Officer, Connected Person, Designated Persons, Director, Insider, Key Managerial Personnel (KMP), Legitimate purposes, Material Subsidiary, and Unpublished Price Sensitive Information (UPSI).
UPSI is defined as information relating to the Company or its securities that is not generally available and would likely materially affect the price of securities upon becoming public. This includes but is not limited to financial results, dividends, change in capital structure, M&A activities, changes in key managerial personnel, rating changes, fund raising, agreements impacting management control, fraud or defaults, insolvency proceedings, forensic audits, regulatory actions, litigation outcomes, guarantees, license changes, and other matters prescribed by SEBI.
Overseeing and Coordination of Disclosure: The CIRO is responsible for dissemination of information and disclosure of UPSI, while the Compliance Officer oversees disclosure to Stock Exchanges. Authorized spokespersons include CEO, CFO, Chief Investment Officer (CIO), and any other person authorized by the Board or CEO/CFO/CIO/CIRO.
Principles for Fair Disclosure: The Company adheres to principles including prompt public disclosure of UPSI, uniform dissemination, designation of CIRO, prompt dissemination of selectively disclosed information, appropriate response to market rumors, ensuring information shared with analysts is not UPSI, maintaining records of investor meetings, and handling UPSI on a need-to-know basis.
Policy for Determination of Legitimate Purposes: UPSI can be shared for legitimate purposes in the ordinary course of business with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, or other advisors/consultants. Specific circumstances include sharing with persons who agree to confidentiality, obtaining regulatory approvals, credit facilities, legal advice, evaluating business opportunities, and disclosure processes under SEBI LODR Regulations.
Structured Digital Database: The Board must maintain a structured digital database containing nature of UPSI and names of persons who shared/received information, along with PAN or other identifiers. The database must be maintained internally (not outsourced) with internal controls like time stamping and audit trails, preserved for at least eight years after relevant transactions complete, or until investigation/proceedings completion if initiated by SEBI.
Enforcement: Violations of the Code may result in penal action under applicable law and disciplinary action including termination of employment, suspension, wage freeze, or non-participation in future ESOPs. SEBI may also initiate separate action for violations of Regulations.
The filing was digitally signed by Udayan Shukla, Company Secretary & Compliance Officer (Membership No.: F11744) on October 26, 2026, at 22:29:50 +05'30'.