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Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information

POLICY on Fair Disclosure for purpose of Code of Practices and Procedures for Disclosure of Unpublished Price Sensetive information

This revised Policy will be effective on and from 1st April 2019

[ vide sub-Registration(1) of the Regulation 8 and sub_Regulation (2A) of Regulation 3 of thr SEBI (Prohibition of insider Trading) Regulation 2015 read with Securities and Exchange Board of India(Prohibition of Inside Trading) (Amendment) Regulation 2018]

The policy of fair Disclosure of unpublished price sensitive information as enumerated hereunder shall be effective solely for the legitimate purpose of the company, which means sharing of the information in the ordinary course of business – with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisers, auditors, insolvency professionals or other advisors or consultants – with the clear instruction to the particular recipient of the information that is strictly for the purpose of performance of the act agreed upon or for which the recipient is engaged and shall not be disclosurable to any other persons not directly connected with such act or engagement for any reason whatsoever until allowed by the company to do so.

1. Timing of disclosure:

The company shall disclose any incident generating or leading to an unpublished price sensitive information (such ‘incident’) {as defined under SEBI( Prohibition of insider trading)Regulation 2015 whenever the same will materialize finally.

2. Means of disclosure:

Such disclosure shall be through the Stock Exchanges where its shares are listed and if so merited or statutorily required, through the Company’s websites and such newspaper/s as the Board of Directors may decide.

3. Investors Relation:
The company Secretary shall act as the Chief Investor relation Officer to deal with dissemination of information and disclosure of unpublished price sensitive information.
4. Inadvertence:
During the progress of such incident and until Its finally, the Company shall take all possible safeguard to protects its confidentiality. In case of any inadvertent or selective disclosure about such incident, the company shall promptly clear its position by appropriate means.
5. Unverified information:
If any rumor or unverified information regarding The company comes into its notice, it shall clear its standing suitably inclusive of replying any query form regulatory authorities and shareholders.
6. Analysis and research:
The Company shall not share with any analyst. And research personnel, any unpublished price Sensitive information. Important outcomes of With analyst and investors will be documented and posted in brief on the company’s standing suitably inclusive of replying any
7. Need to know:
All unpublished price sensitive information shall be handled on need to know basis and for the legitimate purpose.