Varmora Granito files code of conduct for fair disclosure of UPSI
- Varmora Granito filed its Code of Conduct for fair disclosure of UPSI with NSE and BSE on September 29, 2026.
- The code complies with Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
- The Head of Investor Relations will serve as the Chief Investor Relations Officer to manage disclosures.
- A structured digital database must be maintained to track sharing of UPSI with time-stamped audit trails.

*this image is generated using AI for illustrative purposes only.
Varmora Granito Limited submitted its Code of Conduct and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) to the National Stock Exchange of India and BSE Limited on September 29, 2026. This filing complies with Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015.
The document outlines the company’s framework for maintaining confidentiality and ensuring uniform dissemination of material information. It was approved by the Board of Directors on April 25, 2025, aligning with the principles of responsible business conduct as per the National Guidelines on Responsible Business Conduct and SEBI’s Business Responsibility and Sustainability Reporting framework.
Key Provisions of the Code
The code mandates that Varmora make prompt disclosure to stock exchanges whenever credible and concrete information impacting price discovery emerges. The company aims to prevent selective or speculative disclosure that could adversely affect market price discovery.
Key operational guidelines include:
- Designated Officer: The Head of Investor Relations will act as the Chief Investor Relations Officer (CIRO), coordinating with the Compliance Officer to ensure regulatory filings align with SEBI guidelines.
- Analyst Meetings: At least two company representatives must be present during meetings with analysts, brokers, or institutional investors. Transcripts or records may be made available on the official website where necessary.
- Need-to-Know Basis: UPSI shall be shared only for legitimate purposes, such as with partners, lenders, auditors, or legal advisors, provided such sharing does not circumvent regulatory prohibitions.
Structured Digital Database Requirements
The company is required to maintain a structured digital database containing names and Permanent Account Numbers (or other authorized identifiers) of persons or entities receiving UPSI. This database must include adequate internal controls, such as time stamping and audit trails, to ensure non-tampering and restrict access solely for implementing fair practices.
Definition of Unpublished Price Sensitive Information
The code defines UPSI as any information relating to the company or its securities that is not generally available but is likely to materially affect the security price once disclosed. This includes information regarding:
- Financial results and dividends
- Changes in capital structure
- Mergers, de-mergers, acquisitions, and delistings
- Expansion of business
- Changes in key managerial personnel
Any person receiving UPSI for a legitimate purpose is considered an insider and must maintain confidentiality in compliance with this code and the SEBI PIT Regulations.
Historical Stock Returns for Varmora Granito
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| +2.83% | +2.83% | +2.83% | +2.83% | +2.83% | +2.83% |
How will the implementation of the structured digital database impact Varmora Granito's operational costs and compliance infrastructure over the next fiscal year?
What specific internal audit mechanisms will Varmora employ to verify that the 'need-to-know' sharing of UPSI with external partners like lenders and auditors remains compliant?
Could the requirement for two representatives in analyst meetings alter the frequency or depth of Varmora's engagement with institutional investors compared to peers?



























