Srit India frames code for fair disclosure of UPSI under SEBI rules
- Srit India Limited adopted a Code of Practices for Fair Disclosure of UPSI under SEBI PIT Regulations, 2015
- The Code was approved by the Board on August 10, 2026, and submitted to NSE and BSE on October 6, 2026
- Provisions mandate a "need to know" basis for handling sensitive information and require digital database maintenance
- The Company Secretary serves as the Investor Relations Officer responsible for disclosure compliance
*this image is generated using AI for illustrative purposes only.
Srit India Limited has framed a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) in compliance with the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015.
The company submitted this intimation to the National Stock Exchange of India Limited and BSE Limited on October 6, 2026. The Code was initially released and approved by the Board of Directors on August 10, 2026. It is now available on the company's official website.
Key provisions of the code
The framework mandates that UPSI be handled on a "need to know" basis, ensuring that sensitive information is disclosed only to those who require it for official duties or legal obligations. The Code outlines specific procedures for responding to regulatory queries regarding news reports or market rumors, requiring responses to be prompt, consistent, and non-selective.
Key operational guidelines include:
- Investor Relations Officer (IRO): The Company Secretary currently serves as the IRO, responsible for disseminating information and handling UPSI disclosures.
- Analyst Interactions: The company must ensure that information shared with analysts and research personnel does not constitute UPSI. Meetings with analysts are to be transcribed or recorded on the official website to ensure documentation.
- Legitimate Purposes: Sharing of UPSI is permitted only for legitimate purposes such as ordinary business dealings with partners, lenders, auditors, or advisors, provided confidentiality agreements are executed.
Governance and compliance mechanisms
The Code establishes strict protocols for maintaining a structured digital database of all persons who have shared or received UPSI. This database must include names, Permanent Account Numbers (PAN), and timestamps, and must be preserved for at least eight years after the completion of relevant transactions.
In the event of a suspected leak of UPSI, the Compliance Officer is required to promptly inform the Chairman of the Audit Committee or the Board of Directors. The company may engage external consultants to investigate such incidents, with findings reported to the stock exchanges where its securities are listed.
Disclosure obligations
The policy aligns with Chapter III of the SEBI PIT Regulations, mandating initial disclosures by key managerial personnel, directors, and promoters within seven days of appointment. Continual disclosures are required for trades exceeding ₹10 lakh in value within a calendar quarter, which must be reported to the stock exchanges within two trading days.
The Board retains the authority to amend or substitute provisions of the Code, subject to applicable laws. Any amendments will be intimated to the stock exchanges and updated on the company's website.
Historical Stock Returns for SRIT
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| +19.30% | +19.30% | +19.30% | +19.30% | +19.30% | +19.30% |
How will the mandatory recording of analyst interactions impact Srit India's engagement strategy with sell-side research firms?
What specific technological infrastructure is Srit India deploying to maintain the eight-year digital UPSI database while ensuring data privacy compliance?
Could the strict 'need to know' protocols slow down decision-making processes for strategic partnerships or financing deals involving external advisors?
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