Shree Refrigerations adopts amended code of conduct for insider trading
Shree Refrigerations Limited has implemented an amended Code of Conduct for Insider Trading effective May 25, 2026, aligning with SEBI regulations. The policy mandates pre-clearance for trades over ₹10 Lakhs, restricts trading during possession of UPSI, and requires quarterly disclosures. A Monitoring Committee will oversee compliance, with penalties for violations including wage freeze and suspension.

*this image is generated using AI for illustrative purposes only.
Shree Refrigerations Limited has adopted an amended Code of Conduct for Insider Trading to comply with Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015. The policy, approved by the Board of Directors on May 25, 2026, establishes a framework to regulate, monitor, and report trading by Designated Persons and their Immediate Relatives. The code aims to maintain high ethical standards and prevent the misuse of Unpublished Price Sensitive Information (UPSI).
The new code defines UPSI as any information relating to the company or its securities that is not generally available and could materially affect the price of securities upon becoming public. This includes financial results, dividends, changes in capital structure, mergers, acquisitions, and key managerial personnel changes. The company has implemented a “Need-to-Know” basis for information disclosure, ensuring that UPSI is shared only with personnel who require it to discharge their duties.
Trading Restrictions and Pre-Clearance
Designated Persons are prohibited from trading in company securities while in possession of UPSI. The code mandates pre-clearance from the Compliance Officer for trades where the market value of securities involved in a transaction or series of transactions over any calendar quarter exceeds ₹10 Lakhs. Pre-clearance applications must be accompanied by an undertaking confirming that the applicant is not in possession of UPSI.
Once approved, the trade must be executed within seven Trading Days. If the trade is not executed within this period, the Designated Person must secure fresh pre-clearance. The code also prohibits Designated Persons and their Immediate Relatives from entering into an opposite transaction during the six months following a prior transaction, except with written relaxation from the Compliance Officer.
Disclosure Requirements
The policy outlines specific disclosure requirements for Designated Persons. They must furnish details of Immediate Relatives, persons with whom they share a Material Financial Relationship, and their current securities holdings to the company annually. Additionally, any promoter, member of the promoter group, or director must disclose the number of securities acquired or disposed of within two Trading Days if the aggregate value traded in a quarter exceeds ₹10 Lakhs.
The company is required to notify the stock exchanges of these disclosures within two Trading Days of receipt. The Compliance Officer may also require other Connected Persons to make disclosures of holdings and trading activities to monitor compliance.
Monitoring and Penalties
A Monitoring Committee, comprising the Managing Director, Whole Time Directors, Chief Financial Officer, and the Compliance Officer, has been constituted to review the list of Designated Persons and conduct inquiries into alleged violations. The Compliance Officer is responsible for monitoring the code, maintaining records, and deciding on “Fixed Closed Periods” and “Special Closed Periods” during which trading is prohibited.
Violations of the code may result in penalties, including wage freeze, suspension, and ineligibility for future participation in the company’s ESOP Scheme. Any amount collected due to violations will be remitted to SEBI for credit to the Investor Protection and Education Fund. The policy also includes a procedure for inquiry in case of leaks or suspected leaks of UPSI, with provisions for protecting whistleblowers against discrimination or harassment.
Historical Stock Returns for Shree Refrigerations
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -4.29% | +11.17% | +23.54% | +20.97% | +44.38% | +44.38% |
How will the stricter pre-clearance requirements impact trading liquidity for company insiders?
What specific criteria will the Monitoring Committee use to determine 'Fixed' and 'Special' Closed Periods?
Could the new disclosure requirements influence the company's attractiveness to potential investors or board members?


































