Deepa Jewellers Limited has submitted its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) to BSE and NSE. The submission complies with Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015.

The company framed the code pursuant to Regulation 8(1) of the PIT Regulations. The policy aims to ensure timely and adequate disclosure of UPSI to the investor community. This enables stakeholders to take informed investment decisions regarding the company's securities. The document is based on the model code prescribed under Schedule A of the regulations.

Key provisions of the code

The code mandates that all UPSI be handled on a need-to-know basis. It prohibits selective disclosure and requires uniform dissemination of information. The Compliance Officer has been designated as the Chief Investor Relations Officer. This officer is responsible for managing disclosures and responding to market rumors.

The policy outlines specific procedures for interactions with analysts and institutional investors. Only public information may be shared with these groups. Meetings with analysts must be recorded, and presentations must be hosted on the company website. Unanticipated questions involving UPSI require a public announcement before a response is provided.

Structured digital database requirements

The company is required to maintain a structured digital database. This database records the names of persons or entities with whom UPSI is shared for legitimate purposes. It includes Permanent Account Numbers or other authorized identifiers. Adequate internal controls must secure this database against unauthorized access.

Governance and compliance structure

The code applies to all insiders, including connected persons and designated persons. Designated persons include directors, promoters, key managerial personnel, and employees in finance, accounts, audit, taxation, legal, and corporate communication functions. Immediate relatives of these individuals are also covered.

The Board of Directors retains the authority to amend or modify the code. Any regulatory changes requiring modifications will be reviewed with board approval. Regulatory requirements prevail over the policy if not explicitly incorporated. The code was approved in the board meeting held on November 28, 2025.