Annu Projects files SEBI PIT code for fair disclosure of UPSI
- Annu Projects Limited submitted its fair disclosure code to BSE and NSE on September 2, 2026
- The Board adopted the policy on May 22, 2025, complying with SEBI PIT Regulations 2015
- Uniform dissemination of UPSI is mandated to prevent selective disclosure to stakeholders
- A structured digital database must track all recipients of sensitive information for eight years

*this image is generated using AI for illustrative purposes only.
Annu Projects Limited has submitted its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) to the Bombay Stock Exchange and National Stock Exchange. The filing ensures compliance with Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
The company’s Board of Directors adopted the code in a meeting held on May 22, 2025. Sanjay Kumar Sarraf, Chairman and Managing Director, signed the intimation letter dated September 2, 2026. The document outlines protocols for handling sensitive data and preventing insider trading.
Key Provisions of the Code
The code mandates that all designated persons, including directors, promoters, and key managerial personnel, safeguard confidentiality. It defines "connected persons" broadly to include immediate relatives, subsidiaries, and intermediaries with access to sensitive information.
- Uniform Dissemination: The Chief Investor Relations Officer is responsible for furnishing UPSI to stock exchanges simultaneously to avoid selective disclosure.
- Need-to-Know Basis: Access to unpublished price-sensitive information is restricted to employees requiring it for legitimate business purposes.
- Structured Digital Database: The company must maintain an internal digital record of all entities receiving UPSI, including timestamps and audit trails, preserved for at least eight years.
Handling Analyst Interactions
The policy strictly regulates communication with analysts and institutional investors. Only authorized personnel may share information, and only public data can be disclosed during such meetings. Any inadvertent selective disclosure triggers an immediate obligation to make the information generally available through public announcements.
Compliance and Oversight
A Compliance Officer, reporting to the Board, oversees adherence to these procedures. The officer must be financially literate and capable of monitoring trades and maintaining records. The code applies to all insiders, including those sharing information for legitimate purposes such as mergers or legal advice, provided they sign confidentiality undertakings.
How might the implementation of a structured digital database for UPSI tracking impact Annu Projects' operational efficiency and compliance costs?
Could the strict regulation of analyst interactions lead to changes in how institutional investors perceive the company's transparency and governance standards?
What are the potential market reactions if Annu Projects faces any inadvertent selective disclosures despite these new protocols?

























