Manika Plastech Limited has adopted a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015. The policy aims to ensure equal accessibility of information to all stakeholders and prevent misuse of sensitive data.

The company disclosed that Karishma Himatbhai Waghela, Company Secretary and Compliance Officer, has been designated as the Chief Investor Relations Officer. This officer is responsible for monitoring adherence to rules, preserving UPSI, and overseeing the implementation of the codes specified in the regulations.

Scope and Designated Persons

The code applies to all "Insiders," including connected persons and designated persons, along with their immediate relatives. Designated persons encompass all directors, promoters, members of the promoter group, and key managerial personnel. It also includes employees in specific functions such as finance, accounts, audit, taxation, legal, and secretarial, regardless of grade.

Furthermore, the definition extends to employees up to two levels below the Managing Director and personal assistants of covered individuals. Any other employee notified by the Compliance Officer who may possess UPSI is also included.

Disclosure Mechanisms

To maintain transparency, the company mandates prompt public disclosure of UPSI that impacts price discovery once credible and concrete information is available. Dissemination must occur uniformly through stock exchanges to avoid selective disclosure. In cases of inadvertent selective disclosure, the company commits to taking corrective action, including informing the exchanges to make the information public.

Information shared with analysts and research personnel is strictly limited to public domain knowledge. Only authorized personnel, specifically the Chief Investor Relations Officer, are permitted to disclose information during meetings or conferences.

Structured Digital Database

A Structured Digital Database will be maintained for sharing UPSI for legitimate purposes. This database records the nature of the shared information and the names of those sharing and receiving it, along with permanent account numbers or other legal identifiers. The system includes time stamping and audit trails to prevent tampering. Records must be preserved for at least eight years after the completion of relevant transactions.

Legitimate purposes for sharing UPSI include obtaining regulatory licenses, credit facilities, legal advice, and business evaluations. Sharing is permitted only if recipients have agreed in writing to maintain confidentiality and abstain from trading based on the information.

Manika Plastech Limited has authorised its Key Managerial Personnel (KMP) to determine the materiality of events or information required for disclosure under Regulation 30(5) of the SEBI Listing Obligations Regulations.

The decision follows the company's Policy for Determination of Materiality of Events. The designated personnel are responsible for assessing materiality and making necessary disclosures to stock exchanges.

Authorised Personnel

The following officials have been empowered to handle these regulatory disclosures:

All communication regarding these determinations can be directed to the company's corporate office in Mumbai or via email to cs@manikaplastech.com . The information is also available on the company's investor relations website.