Thanks Amar,

 

I found the following in schedule A of SECURITIES AND EXCHANGE BOARD OF
INDIA (PROHIBITION OF INSIDER TRADING) REGULATIONS, 2015 No.
LAD-NRO/GN/2014-15/21/85.

 

2. Uniform and universal dissemination of unpublished price sensitive
information to avoid selective disclosure.

 

Chapter IV section 8.(1), also specifies Principles such as equality of
access to information. Please see below excerpt from the notification.

 

 

 

CHAPTER - IV CODES OF FAIR DISCLOSURE AND CONDUCT

Code of Fair Disclosure.

 

8. (1) The board of directors of every company, whose securities are listed
on a stock exchange, shall formulate and publish on its official website, a
code of practices and procedures for fair disclosure of unpublished price
sensitive information that it would follow in order to adhere to each of the
principles set out in Schedule A to these regulations, without diluting the
provisions of these regulations in any manner.

NOTE: This provision intends to require every company whose securities are
listed on stock exchanges to formulate a stated framework and policy for
fair disclosure of events and occurrences that could impact price discovery
in the market for its securities. Principles such as, equality of access to
information, publication of policies such as those on dividend, inorganic
growth pursuits, calls and meetings with analysts, publication of
transcripts of such calls and meetings, and the like are set out in the
schedule.

 

As you said, we can request SEBI to issue specific note regarding
implementation of universal availability of information. See below section
11.

 

11. In order to remove any difficulties in the interpretation or application
of the provisions of these regulations, the Board shall have the power to
issue directions through guidance notes or

circulars: Provided that where any direction is issued by the Board in a
specific case relating to interpretation or application of any provision of
these regulations, it shall be done only after

affording a reasonable opportunity of being heard to the concerned persons
and after recording reasons for the direction.

Repeal and Savings.

 

I will draft an email in this regard, but I would first collect enough
examples that violate these guidelines.

 

Regards

Dinesh



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