Swaraj Engines amends fair disclosure code for UPSI
- Swaraj Engines Limited amended its UPSI fair disclosure code effective October 12, 2026
- The update complies with Regulation 8(2) of SEBI (Prohibition of Insider Trading) Regulations, 2015
- Whole-time Director designated as Chief Investor Relations Officer to oversee disclosures
- New policy mandates digital database tracking of all individuals receiving UPSI

*this image is generated using AI for illustrative purposes only.
Swaraj Engines Limited amended its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) effective October 12, 2026. The revision aligns the company's internal policies with Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
The updated Code mandates prompt public disclosure of UPSI to ensure uniform dissemination and prevent selective disclosure. It designates the Whole-time Director as the Chief Investor Relations Officer (CIRO), who is responsible for overseeing disclosure to stock exchanges, analysts, and media. The CIRO must also address market rumors within 24 hours if they indicate impending material events.
Key provisions in the revised code
The amendment reinforces strict guidelines for handling interactions with analysts and institutional investors. Only publicly available information may be shared during these meetings. To ensure transparency, the company may record discussions and publish transcripts on its official website. Unanticipated questions involving price sensitive information must be addressed only after such information is made generally available.
Legitimate purpose framework
The Code includes a policy for determining "Legitimate Purposes" for sharing UPSI. This allows insiders to share information with designated persons, partners, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, credit rating agencies, and bankers on a need-to-know basis. Recipients must maintain confidentiality and refrain from trading while in possession of UPSI.
Compliance and digital tracking
Swaraj Engines will maintain a structured digital database of persons receiving UPSI under legitimate purposes. This database will include names and Permanent Account Numbers (PAN) or other authorized identifiers. Any violation of the sharing policy will be treated as a breach, potentially resulting in disciplinary action and reporting to SEBI.
What the numbers show
While no financial metrics are disclosed in this regulatory filing, the structural emphasis on digital database maintenance and 24-hour rumor response times highlights a tightening of internal controls. The designation of the Whole-time Director as CIRO centralizes accountability for disclosure, reducing potential gaps in communication between management and the market.
Historical Stock Returns for Swaraj Engines
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| +0.87% | +3.08% | +0.57% | -13.39% | -13.95% | 0.0% |
How might the requirement to publish transcripts of analyst meetings impact Swaraj Engines' investor relations strategy and market sentiment?
What operational challenges will Swaraj Engines face in maintaining a real-time digital database with PAN details for all UPSI recipients under the new SEBI guidelines?
Could the 24-hour rumor response mandate increase the frequency of public clarifications, potentially affecting stock price volatility for Swaraj Engines?


































