Poonawalla Fincorp Limited’s Board of Directors approved an amended Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) on July 17, 2026. The code, framed under Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, mandates universal dissemination of UPSI to prevent selective disclosure and ensure price discovery is not compromised. The amendment aligns the company's internal compliance framework with regulatory requirements aimed at maintaining market integrity.

The code defines UPSI as information not generally available that could materially affect the price of securities, including financial results, dividends, changes in capital structure, and key managerial personnel changes. It designates the Chief Investor Relations Officer (CIRO), typically the Chief Financial Officer or a senior officer, as the authority responsible for determining whether information constitutes UPSI and handling its universal dissemination. The CIRO must ensure prompt public disclosure of credible information to avoid selective leaks to analysts or institutional investors.

company name has established protocols for sharing UPSI only on a need-to-know basis and for legitimate purposes, such as consultations with legal advisors, auditors, or regulatory bodies. The Compliance Officer, in consultation with the Chief Financial Officer or Whole-time Director, must maintain a record of all recipients of UPSI shared for legitimate purposes. This record, which cannot be outsourced, must include details such as the recipient's PAN, the reason for sharing, and confirmation of non-disclosure agreements.

The code specifies that records of UPSI sharing must be preserved for at least eight years after the completion of the relevant transaction. If SEBI initiates an investigation or enforcement proceedings, the records must be maintained until the conclusion of those proceedings. The Board of Directors retains the authority to make further amendments to the code, provided they do not conflict with SEBI regulations, and must promptly inform stock exchanges of any changes.

Key Definitions and Scope

The code applies to all connected persons, designated persons, and insiders of the company, including promoters, directors, key managerial personnel, and employees with access to UPSI. It also covers entities such as holding companies, subsidiaries, and intermediaries like bankers and auditors. The definition of UPSI is broad, encompassing events like fraud, defaults, forensic audits, regulatory actions, and material litigation.

Record-Keeping Requirements

The following table outlines the details required to be maintained for each instance of UPSI shared for legitimate purposes:

The database must be maintained under the supervision of the Compliance Officer and reviewed periodically to ensure accuracy and compliance with the code.

Poonawalla Fincorp has stated that it currently sees no need for additional fundraising in FY27. The company's communication signals confidence in its existing capital base and liquidity position as it navigates the current financial year.

Capital Position Outlook

The non-banking financial company's declaration that no further fundraising is required at this stage suggests that its current resources are considered sufficient to meet near-term operational and growth requirements. The statement, as communicated by the company, reflects its present assessment of funding needs without elaborating on specific capital metrics or deployment plans.

Key Announcement

The company has not provided additional quantitative details or forward-looking financial projections in connection with this statement. Stakeholders and market participants have noted the update as an indicator of the company's current capital management stance for the fiscal year.