Neomile Asset Managers Pvt. Ltd. has filed a disclosure under SEBI regulations regarding its acquisition of a substantial stake in Innovision Limited. The disclosure, dated March 24, 2026, reveals the acquisition of 20,88,956 shares representing 8.77% of the company's total share capital.

Acquisition Details

The acquisition involves multiple entities acting in concert with Neomile Asset Managers. The acquirer group includes Neomile Growth Fund – Series I, Neomile India Opportunity Fund, Neomile Corporate Advisory Ltd, and Kirtan Rupareliya. Notably, the acquirer group does not belong to the promoter or promoter group category.

Shareholding Position

Prior to this acquisition, the Neomile group held no shares in Innovision Limited. The transaction represents their initial entry into the company's shareholding structure. The acquisition was completed through a combination of public issue and open market purchases.

Company Information

Innovision Limited is listed on both the National Stock Exchange of India Limited (NSE) and Bombay Stock Exchange Ltd (BSE). The company's total equity share capital stands at 2,38,13,294 shares, which remained unchanged following this acquisition. The disclosure was signed by CA Rashesh Shah, Director of Neomile Asset Managers Pvt. Ltd., and submitted to both stock exchanges as well as to Innovision Limited's registered office in Delhi.

Regulatory Compliance

The disclosure has been filed in compliance with Regulation 29(1) of SEBI (Substantial Acquisition of Shares and Takeover) Regulations, 2011. This regulation requires disclosure when an acquirer's shareholding crosses certain thresholds in a listed company. The filing demonstrates adherence to transparency requirements for substantial acquisitions in the Indian capital markets.

Innovision Limited has submitted its Code of Practices and Procedures for fair disclosure of Unpublished Price Sensitive Information (UPSI) to BSE Limited and National Stock Exchange of India Limited. The submission was made pursuant to Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, with the code becoming effective from 16.07.2024.

Regulatory Compliance and Framework

The code has been framed in accordance with the model code prescribed under Schedule A of the SEBI (Prohibition of Insider Trading) Regulations, 2015. Chairman and Managing Director Randeep Hundal signed the intimation letter, confirming the company's commitment to regulatory compliance and transparent disclosure practices.

Key Provisions and Scope

The comprehensive code establishes detailed guidelines for handling UPSI across the organization. Designated Persons under the code include all directors, promoters, key managerial personnel, and employees in specific functions such as Finance, Accounts, Audit, Taxation, Legal and Secretarial, and Corporate Communication. The framework extends to employees up to two levels below the Managing Director and their immediate relatives.

UPSI is defined as information relating to the company or its securities that is not generally available and could materially affect security prices. This includes:

• Financial results and dividends
• Changes in capital structure
• Mergers, acquisitions, and business expansions
• Changes in Key Managerial Personnel

Disclosure Procedures and Controls

The code establishes the Chief Investor Relations Officer role, designated to the Compliance Officer, for managing information dissemination and UPSI disclosure. All information sharing follows a strict need-to-know basis principle, with employees required to handle UPSI only in furtherance of their organizational roles and duties.

Digital Infrastructure and Documentation

The company maintains a structured digital database containing names of persons or entities with whom UPSI is shared for legitimate purposes, along with Permanent Account Numbers or authorized identifiers. Adequate security measures including password protection and internal controls secure confidential documents and computer files.

Analyst and Media Interactions

Strict guidelines govern interactions with analysts, research personnel, and media. Only authorized personnel may disclose company information, with the Chief Investor Relations Officer required to attend analyst meetings. All discussions are recorded, and presentation materials are hosted on the company website following analyst meetings to ensure transparency and official documentation.

The code emphasizes that unanticipated questions containing potential UPSI require public announcements before responses are provided. This ensures equal access to information for all stakeholders and prevents selective disclosure practices.