Emkay Global Financial Services Amends Fair Disclosure Code for UPSI Compliance
Emkay Global Financial Services Limited has amended its Code of Practices and Procedures for Fair Disclosure of UPSI, approved by the Board on January 27, 2026. The updated code establishes comprehensive guidelines for handling price-sensitive information, designates Managing Directors as Chief Investor Relations Officers, and includes policies for legitimate purpose sharing and leak investigation procedures. The framework ensures compliance with SEBI regulations while maintaining robust corporate governance standards.
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Emkay Global Financial Services Limited has updated its regulatory compliance framework by amending its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI). The amendment was recommended by the Audit Committee and approved by the Board of Directors at their meeting held on January 27, 2026, demonstrating the company's commitment to maintaining robust corporate governance standards.
Regulatory Compliance Framework
The amended code operates under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, ensuring compliance with current regulatory requirements. The code was originally effective from April 01, 2019, with the latest amendment reviewed on January 27, 2026. This comprehensive framework governs the handling and disclosure of price-sensitive information across all company operations.
| Parameter | Details |
|---|---|
| Effective Date | April 01, 2019 |
| Last Amendment | January 27, 2026 |
| Regulatory Framework | SEBI PIT Regulations 2015 |
| Approval Authority | Board of Directors |
Key Principles and Procedures
The updated code establishes six fundamental principles for fair disclosure practices. The company commits to prompt public disclosure of UPSI that impacts price discovery, ensuring uniform and universal dissemination while avoiding selective disclosure. The framework mandates appropriate responses to regulatory queries and market rumor verification requests.
The code designates Managing Directors as Chief Investor Relations Officers (CIRO) responsible for overseeing information dissemination. These officers ensure timely, adequate, uniform and universal disclosure of UPSI to avoid selective disclosure practices. All UPSI handling follows a strict "Need-to-Know" basis protocol.
UPSI Definition and Coverage
The amended code provides comprehensive definitions of UPSI, covering various categories of sensitive information. These include financial results, dividends, capital structure changes, mergers and acquisitions, key personnel changes, rating modifications, fund raising activities, and regulatory actions. The framework also addresses fraud detection, litigation outcomes, guarantee provisions, and license-related matters.
Categories of UPSI Include:
- Financial results and dividend declarations
- Capital structure modifications and business expansions
- Key managerial personnel changes and auditor resignations
- Credit rating changes and fund raising initiatives
- Regulatory actions and judicial proceedings
- Forensic audit initiations and outcomes
- License grants, withdrawals, or suspensions
Analyst and Investor Relations
The code establishes specific guidelines for interactions with analysts, research personnel, and institutional investors. Only authorized personnel may disclose company-related information, with strict adherence to providing only publicly available information. The framework requires at least two company representatives during group meetings or conference calls to prevent misquoting or misrepresentation.
Transcripts or audio/video recordings of post-earnings calls must be posted on the company website within prescribed timelines. This ensures official confirmation and documentation of all disclosures made during investor interactions.
Legitimate Purpose Policy
The amended code includes a comprehensive policy for determining legitimate purposes for UPSI sharing. This covers sharing with designated persons, partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, and other consultants in the ordinary course of business. Recipients of UPSI must maintain confidentiality and refrain from trading while possessing such information.
The company maintains a Structured Digital Database (SDD) of UPSI recipients with adequate internal controls, time stamping, and audit trails to prevent tampering. The Compliance Officer oversees this database maintenance in accordance with regulatory requirements.
Investigation Procedures
The code establishes structured procedures for investigating UPSI leaks or suspected leaks. Information regarding potential leaks may come from internal whistleblowers, internal controls, or external entities including regulatory authorities. The Compliance Officer reports complaints to the Audit Committee, which reviews and determines appropriate investigation steps.
Investigation panels may include internal employees or external agencies, with findings reported to the Audit Committee and Board for final decision-making. The framework ensures comprehensive coverage of potential leak scenarios while maintaining appropriate oversight mechanisms.
The updated code will be available on the company website at www.emkayglobal.com/investor-relations , ensuring transparency and accessibility for all stakeholders. This amendment reinforces Emkay Global Financial Services Limited's commitment to maintaining the highest standards of corporate governance and regulatory compliance.
Historical Stock Returns for Emkay Global Financial Services
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -3.57% | -8.29% | +1.80% | +4.43% | -1.76% | +291.55% |
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