Code of Fair Practices

Code of Fair Practices

CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION (UPSI)


The Sukhjit Starch & Chemicals Limited ('the  Company') endeavours to maintain the confidentiality of Unpublished  Price Sensitive Information and to prevent misuse of the same. The  Company is committed towards the transparency and fairness in dealing  with all stakeholders and to ensure adherence to all applicable laws and  the SEBI (Prohibition of Insider Trading) Regulations, 2015 including  amendments thereto, from time to time.
             
In view of the SEBI (Prohibition of Insider Trading)  (Amendment) Regulations, 2018 effective from 1st April, 2019, the code  has been amended /approved by the Board of Directors of the Company  w.e.f. 1st April, 2019.
             
The Objective of the Code of Fair Disclosures is to ensure  timely and adequate disclosure of the Unpublished Price Sensitive  Information which would impact the price of the company's securities and  to maintain the uniformity, transparency and fairness in dealing with  all stakeholders and in ensuring adherence to applicable laws and  regulations.
             
In terms of Regulation 8 read with 3(2A) of the said  Regulations, the Board of Directors of the Company has formulated this  Code of practices and procedures for fair disclosure of Unpublished  Price Sensitive Information to be followed as under :


  • The Company shall make prompt public disclosure of Unpublished Price Sensitive Information that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available.


  • The Company shall make uniform and universal dissemination of Unpublished Price Sensitive Information to avoid selective disclosure.


  • The Compliance Officer of the Company is designated as Chief Investor Relation Officer to deal with dissemination of information and disclosure of Unpublished Price Sensitive Information.


  • The Company shall make efforts to promptly dissemination of Unpublished Price Sensitive Information in relation to the Company that gets disclosed selectively, inadvertently or otherwise to make such information generally available.


  • The Company shall endeavour to provide appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities.


  • The Company shall ensure that information shared with analysts and research personnel is not Unpublished Price Sensitive Information in relation to the company.


  • The Company will develop best practices to make transcripts or records of proceedings of meetings with analysts and other investor relations conferences, if any, on the Company's website to ensure official confirmation and documentation of disclosures made.


  • The Company shall handle all unpublished price sensitive information on a need-to-know basis and for legitimate purpose.


Sharing of Unpublished Price Sensitive Information (UPSI) for legitimate purpose:

The UPSI shall be shared by any person(s) authorized  by the Board of Directors / Managing Director / Executive Director/  Company Secretary of the Company in this behalf, only in furtherance of  legitimate purpose(s) which shall include the following;


  • Sharing of relevant UPSI with consultants, legal advisors, attorneys, investment bankers, merchant bankers etc. engaged by the Company in relation to the subject matter of the UPSI;


  • Sharing of relevant UPSI with auditors, insolvency professionals, other advisors, in order to avail professional services from them in relation to the subject matter of the UPSI;


  • Sharing of the relevant UPSI where such communication is required for performance of duties or discharge of legal obligations or as may be required by the Government / Court of law / Tribunal / Statutory Authority etc;


  • Sharing of relevant UPSI for any other genuine or reasonable purpose as may be determined by the Company.


  • Sharing of relevant UPSI with persons who have expressly agreed in writing to keep the information confidential including customers, suppliers, lenders, other developers, joint venture partners etc.


  • Sharing of relevant UPSI for any other purpose as may be prescribed under the Securities Regulations or Company Law or any other applicable law for the time being in force, and amended from time to time.


The Board of Directors may review / modify / revise / amend this Code from time to time.


However, provisions of / amendments in the SEBI (Prohibition of Insider Trading) Regulations/other applicable laws/Regulations shall be binding, even if not incorporated in the Code.