Innovision Limited has submitted its Code of Practices and Procedures for fair disclosure of Unpublished Price Sensitive Information (UPSI) to BSE Limited and National Stock Exchange of India Limited. The submission was made pursuant to Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, with the code becoming effective from 16.07.2024.

Regulatory Compliance and Framework

The code has been framed in accordance with the model code prescribed under Schedule A of the SEBI (Prohibition of Insider Trading) Regulations, 2015. Chairman and Managing Director Randeep Hundal signed the intimation letter, confirming the company's commitment to regulatory compliance and transparent disclosure practices.

Key Provisions and Scope

The comprehensive code establishes detailed guidelines for handling UPSI across the organization. Designated Persons under the code include all directors, promoters, key managerial personnel, and employees in specific functions such as Finance, Accounts, Audit, Taxation, Legal and Secretarial, and Corporate Communication. The framework extends to employees up to two levels below the Managing Director and their immediate relatives.

UPSI is defined as information relating to the company or its securities that is not generally available and could materially affect security prices. This includes:

• Financial results and dividends
• Changes in capital structure
• Mergers, acquisitions, and business expansions
• Changes in Key Managerial Personnel

Disclosure Procedures and Controls

The code establishes the Chief Investor Relations Officer role, designated to the Compliance Officer, for managing information dissemination and UPSI disclosure. All information sharing follows a strict need-to-know basis principle, with employees required to handle UPSI only in furtherance of their organizational roles and duties.

Digital Infrastructure and Documentation

The company maintains a structured digital database containing names of persons or entities with whom UPSI is shared for legitimate purposes, along with Permanent Account Numbers or authorized identifiers. Adequate security measures including password protection and internal controls secure confidential documents and computer files.

Analyst and Media Interactions

Strict guidelines govern interactions with analysts, research personnel, and media. Only authorized personnel may disclose company information, with the Chief Investor Relations Officer required to attend analyst meetings. All discussions are recorded, and presentation materials are hosted on the company website following analyst meetings to ensure transparency and official documentation.

The code emphasizes that unanticipated questions containing potential UPSI require public announcements before responses are provided. This ensures equal access to information for all stakeholders and prevents selective disclosure practices.

Innovision's initial public offering has achieved a total subscription of 1.25x, reflecting mixed investor response across different categories. The subscription details reveal varying levels of interest among different investor segments.

Institutional Investor Response

The IPO witnessed strong participation from institutional investors, with Qualified Institutional Buyers (QIB) demonstrating exceptional demand by subscribing 13.13 times their allocated portion. This significant oversubscription in the QIB category indicates strong confidence from institutional investors in the company's prospects.

Subscription Breakdown by Category

Non-Institutional and Retail Performance

Among Non-Institutional Buyers, the big HNI (bHNI) category showed positive response with 3.81x subscription, while small HNI (sHNI) investors subscribed to 0.59x of their allocation. The retail segment attracted limited interest with only 0.29x subscription, and notably, the employee category recorded zero subscription.

Overall Assessment

The subscription pattern demonstrates a clear preference among institutional and high-net-worth investors, while retail participation remained subdued. The strong institutional backing, particularly from QIBs, provided the primary momentum for the IPO's overall subscription achievement.