Kesar Terminals & Infrastructure Limited has revised its code for fair disclosure of unpublished price sensitive information (UPSI) to ensure compliance with SEBI regulations. The board of directors approved the revised policy during a meeting held on May 26, 2026. This code, formulated under Regulation 8 of the SEBI (Prohibition of Insider Trading) Regulations, 2015, mandates the company to ensure prompt public disclosure of UPSI that impacts price discovery, ensuring uniform and universal dissemination to avoid selective disclosure.

The revised policy outlines specific procedures for the handling and dissemination of UPSI. It requires the company to promptly disseminate any information that is disclosed selectively, inadvertently or otherwise. Additionally, the company must ensure an appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities. The policy also stipulates that information shared with analysts and research personnel must not be UPSI and encourages maintaining transcripts of investor relations conferences on the official website.

Archana Mungunti, Company Secretary, will act as the Chief Investor Relations Officer (CIRO) for the purpose of dealing with the dissemination of information and disclosure of UPSI. The policy emphasizes that all UPSI must be handled on a need-to-know basis. It also includes a framework for determining 'legitimate purpose' for sharing UPSI, which includes sharing with partners, lenders, auditors, and legal advisors, provided it is not done to circumvent regulations.

The policy defines UPSI broadly to include financial results, dividends, changes in capital structure, mergers, acquisitions, and key managerial personnel changes. It also covers events such as fraud, defaults, forensic audits, regulatory actions, and material litigation. The guidelines for materiality referred to in Schedule III of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, will be applicable for identifying such events.

Key Policy Provisions

The policy mandates that any person in receipt of UPSI pursuant to a legitimate purpose shall be considered an 'insider' and must comply with the code. It also requires the maintenance of a database of individuals with whom UPSI is shared, including their PAN or other identifiers, with adequate internal controls such as time stamping and audit trails. An internal audit will be conducted once a year to ensure the integrity of the system and data maintained.

Kesar Terminals & Infrastructure Limited has announced the extension of its special window for physical share transfer and dematerialization, providing shareholders with an additional year to complete their transfer requests. The company published a newspaper advertisement on 9th April 2026 to inform stakeholders about this important development.

Regulatory Disclosure and Compliance

The company made this disclosure under Regulation 30 of SEBI (Listing Obligation and Disclosure Requirements) Regulations, 2015, following SEBI Circular No. HO/38/13/11(2)2026-MIRSD-POD/I/3750/2026 dated 30th January 2026. The advertisement was published in Free Press Journal (Mumbai, Indore, & Bhopal edition) and Navshakti newspapers to ensure wide dissemination of information to shareholders.

Extension Details and Timeline

The extended special window facilitates the lodgement and re-lodgement of transfer deeds that were executed prior to 1st April 2019. This includes transfer requests that were previously rejected, returned, or not attended to due to deficiencies in documents, processes, or other issues.

Scope of the Special Window

The special window covers multiple categories of transfer requests to provide comprehensive support to shareholders. It addresses both fresh lodgements of shares sold or purchased before the specified cut-off date and re-lodgements of previously submitted but unsuccessful transfer requests.

Shareholders who had faced difficulties with their earlier transfer attempts due to documentation issues or procedural deficiencies can now resubmit their requests during this extended period. This initiative aims to help shareholders complete pending transfer formalities and convert their physical shares to dematerialized form.

Company Communication

Company Secretary Archana Mungunti signed the official communication to BSE Limited, emphasizing the company's commitment to facilitating shareholder services. The disclosure is also available on the company's website, ensuring accessibility for all stakeholders.

The company has requested BSE Limited to take this information on record, maintaining transparency in its regulatory communications. This extension demonstrates Kesar Terminals & Infrastructure Limited's proactive approach to addressing shareholder needs and ensuring compliance with evolving SEBI regulations regarding physical share transfers.