UPS Code.pdf

Key Provisions:

1. Corporate Disclosure Policy: Ensure timely and adequate disclosure of UPSI, handle UPSI on a need-to-know basis, and prevent sharing except for legitimate purposes.
2. Prompt Public Disclosure: Disclose UPSI promptly and uniformly to stock exchanges, avoiding selective disclosure.
3. Overseeing and Co-ordinating Disclosure: Designate a Chief Investor Relations Officer (CIRO) to ensure prompt dissemination of information to stock exchanges and the company's website.
4. Responding to Market Rumours: Provide fair response to queries on news reports and market rumours, with the Disclosure Committee deciding on public announcements.
5. Medium of Disclosure/Dissemination: Use various media for maximum reach and quick dissemination, including the company's website.
6. Policy for Determination of "Legitimate Purposes": Define legitimate purposes for sharing UPSI, including sharing with designated persons, partners, and advisors, and require confidentiality and compliance with PIT Regulations.
7. Amendment: The Board reserves the right to amend or modify the Code, with updates to be posted on the company's website and intimated to stock exchanges.

Key Responsibilities:

CIRO: Ensure prompt dissemination of information to stock exchanges and the company's website.
Disclosure Committee: Decide on public announcements in response to market rumours.
Compliance Officer: Provide clarifications on sharing UPSI and ensure compliance with PIT Regulations.
Insiders: Maintain confidentiality of UPSI, avoid trading in securities while in possession of UPSI, and obtain prior written consent for using UPSI for purposes other than legitimate purposes.