Code Of Practices & Procedures for fair disclosure of Unpublished Price Sensitive Information :
Corporate Disclosure Policy
To ensure timely and adequate disclosure of ‘Unpublished Price Sensitive Information ‘(UPSI), the following norms / principles shall be followed by the Company.
Prompt public disclosure of UPSI
The Company shall make a prompt public disclosure of UPSI that would impact the
price discovery, as soon as credible and concrete information comes into being, in
order to make such information generally available.
The Board of Directors shall ensure that the price sensitive information that would
impact price discovery no sooner that the information comes into being in order to
make such information generally available to the public and authorize the
Compliance Officer in this regard to take necessary action to make the information
available to the general public.
The Board of Directors through the Chief Investor Relations Officer shall ensure that
prompt dissemination of UPSI that gets disclosed selectively, inadvertently or
otherwise to make such information generally available
The Chief Investor Relations Officer shall be responsible for ensuring that the
Company complies with continuous disclosure requirements, overseeing and
coordinating disclosure of UPSI to Stock Exchanges, analysts, shareholders and
media, and educating staff on disclosure policies and procedures.
The Board of Directors shall ensure that uniform and universal dissemination of
UPSI to avoid selective disclosure.
The Company secretary being the Compliance Officer is designated as the “Chief
Investor Relations Officer” to deal with the dissemination of information and
disclosure of UPSI.
Information disclosure/ dissemination may normally be approved in advance by the
Chairman or in his absence, any Managing Director or Chief Executive Officer of the
If information is accidentally disclosed without prior approval as aforesaid, the Chief
Investor Relations Officer may inform the Chairman immediately, even if the
information is not considered price sensitive.
The Company shall supplement the information released to Stock Exchanges either
by public announcements and / or by simultaneously publishing information in the
By a due process of authorization from the Board of Directors or the Chairman of
the Board of Directors or the Managing Director of the Company, the Chief Investor
Relations Officer shall give appropriate and fair response to queries on news reports
and requests for verification of market rumours by regulatory authorities.
The Board of Directors and the Key Managerial Personnel consisting of the
Managing Director, Chief Financial Officer and the Company Secretary, shall ensure
that information shared with analysts and research personnel is not UPSI.
The Board of Directors and the Management shall develop best practices to make
transcripts or records of proceedings of meetings with analysts and other investor
relations conferences on the official website to ensure official confirmation and
documentation of disclosures made. The Company shall provide only generally
available information, namely information that is accessible to the public on a
nondiscriminatory basis, to analysts/research persons/large investors like
In order to avoid misquoting or misrepresentation, it is desirable that at least two
representatives of the Company be present at meetings with analysts, brokers or
Institutional Investors and discussion should preferably be recorded. It is also
desirable that, if the meeting is a large gathering, the meeting may be video-
The Board of Directors and the Management shall ensure that all the UPSI shall be
handled on a need-to-know basis.
Disclosure/dissemination of information may be done through various media such as
publication of results or the Company’s website and/ or press release so as to
achieve maximum reach and quick dissemination. The Company shall ensure that
disclosure of information to Stock Exchanges is made promptly.
The mail id of the Chief Investor Relations Officer is firstname.lastname@example.org