Padmanabh Alloys & Polymers Ltd.
 

Code of Fair Disclosure

CODE OF PRACTICE AND PROCEDURE FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION

[As envisaged under the SEBI (Prohibition of Insider Trading) Regulations, 2015]

The securities and Exchange board of India (SEBI), in its endeavor to protect the interest of investors in general, had formulated the SEBI (Prohibition of Insider Trading) Regulations, 2015 under the power conferred on it under the SEBI Act, 1992.

These regulations came into force with effect from 15th May, 2015 and the same have been made applicable to all Listed Companies. The company is required to formulate Code of Practices and Procedure for Fair Disclosure of Unpublished Price Sensitive Information (UPSI). The code of Practice and Procedures for Fair Disclosure is required for the company to ensure timely and adequate disclosure of Unpublished Price Sensitive Information which would impact the price of the company's securities and to maintain the uniformity, transparency and fairness in dealing with all stakeholders and in ensuring adherence to applicable laws and regulations.

Further, the company endeavors to preserve the confidentiality of UPSI and to prevent misuse of such information.

The board of directors of the company has always thrived to conduct its business in a fair and transparent manner with a view to protect the interest of all stakeholders in the company. Towards achieving this objective, the company will adhere to the following principles of fair disclosure of unpublished price sensitive information:
  • The company will make prompt disclosure of unpublished price sensitive information to the stock exchange that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available.
  • The company will make disclosures of unpublished price sensitive information on a continuous, immediate, uniform basis and will be universally dissemination to avoid selective disclosure.
  • The Chief Financial officer of the company shall be designated as chief investor relations officer to deal with dissemination of information and disclosure of unpublished price sensitive information.
  • The company will make Prompt dissemination of unpublished price sensitive information that gets disclosed selectively, inadvertently or otherwise to make such information generally available.
  • The chief Investor Relations officer shall promptly respond to any queries or request for verification of market rumors by regulatory authorities. He shall also be responsible for deciding whether a public announcement is necessary for verifying or denying rumors and then making the disclosure. He shall also provide appropriate assistance and fair response to the regulatory authorities including the stock exchange for verification of news reports and market rumors.
  • The company will ensure that information shared with analysts and research personnel is not unpublished price sensitive information.
  • The company will make recording of proceedings and discussion of meetings with analysts and other investor relations conferences and post relevant information on the official website to ensure official confirmation and documentation of disclosures made.
  • The company will handle all unpublished price sensitive information on a need-to-know basis i.e. unpublished price sensitive information shall be disclosed only to those where such communication is in furtherance of legitimate purpose, performance of duties or discharge of legal obligations.