1.1 SEBI vide its Circular No. LAD-NRO/GN/2014-15/21/85 dated 15.01.2015 has
2. DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION:
As per this Archival Policy-
introduce the insider trading Regulations effective from 15.05.2015
1.2 Regulation 8 of SEBI (Prohibition o f Insider Trading ) Regulations, 2015 provides for
the Code of Fair Disclosure.
1.3 The Code of Fair Disclosure shall be applicable to the Prommoters, key Managerial
Personnel, Board Members and Employees of the Company.
2.1 The Company will make Prompt public disclosure of unpublished price sensitive
information in relation to the Company that would impact price discovery of the
securities of the Company no sooner than credible and concrete information comes
into being in order to make such information generally available.
2.2 The Company will ensure uniform and universal dissemination of unpublished price
sensitive information in relation to the Company in order to avoid selective
2.3 The Compliance Officer of the Company shall act as the Chief Investor Relations
Officer to deal with dissemination of information and disclosure of unpublished
sensitive information in relation to the Company.
2.4 The Company will make efforts to promptly disseminate any unpublished price
sensitive information in relation to the Company that gets disclosed sensitivity,
inadvertently or otherwise to make such information generally available.
2.5 The Company will endeavor to provide appropriate and fair response to queries on
news reports and requests for verification of market rumors by regulatory authorities.
2.6 The Company will ensure that information shared with analysts and research
personnel is not unpublished price sensitive information in relation to the Company.
2.7 The Company will develop best practices to make transcripts or records of
proceedings of meetings with analysts and other investor relations conferences
the Company’s website www.gautamexim.com to ensure official confirmation and
documentation of disclosures made.
2.8 The Company executive will handle all unpublished price sensitive information on a
The Board of Directors of the Company may amend, abrogate, modify or revise any of or all
clauses of this code in accordance with the applicable provisions of the regulations, listing
agreement and guidance note issued by stock exchanges.