NEO CORP INTERNATIONAL LIMITED
Code of Fair Disclosure of Unpublished Price Sensitive Information under
Regulation – 8 of the SEBI (Prohibition of Insider Trading) Regulations, 2015
This Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Code”) is consistent with the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015.
B. PURPOSE OF THE CODE
This Code of Practices and Procedures for Fair Disclosures is required for the Company to ensure timely and adequate disclosure of unpublished price sensitive information (UPSI) which would impact the price of the Company’s securities and to maintain the uniformity, transparency and fairness in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. Further, the Company endeavors to preserve the confidentiality of unpublished price sensitive information and to prevent misuse of such information.
This code of practice and procedures for fair disclosure of Unpublished Price Sensitive Information shall come into force from 15th May, 2015.
D. PRINCIPLES OF FAIR DISCLOSURE
The Principles of Fair Disclosure adopted by SFL are as follows:
1. Prompt disclosure/ dissemination of credible and concrete unpublished price sensitive information which would impact price discovery no sooner than information comes into being in order to make such information generally available to the Stock exchanges, press and website of the Company.
2. Uniform and universal dissemination of unpublished price sensitive information to avoid selective disclosure.
3. Prompt dissemination of unpublished price sensitive information that gets disclosed selectively, inadvertently or otherwise to make such information generally available. The Company shall take effective steps to promptly disseminate such information to the Stock Exchanges, for public disclosure.
4. Appropriate and fair response to queries on news reports and requests for verification of market rumours to the concern regulatory authorities or to the Stock Exchange promptly.
5. To ensure that information shared with analysts and research personnel is not unpublished price sensitive information. If any question is related to UPSI, reply can be given later only after publication of the UPSI to the Stock Exchange and other concern authorities.
6. To ensure that transcripts or records of proceedings of meetings with analysts and other investor relations conferences on the official website to ensure official confirmation and documentation of disclosures of investor meet / investor relations conferences.
7. Handling of all unpublished price sensitive information on a needtoknow basis i.e. unpublished price sensitive information should be disclosed only to those within the Company who need the information to discharge their duties and whose possession of such information will not give rise to a conflict of interest or appearance of misuse of the information.
8. The Company Secretary of the Company is designated as the “Compliance Officer” to deal with all matters relating to dissemination of information and disclosure of UPSI in absence of Compliance Officer any other person as designated by the Chairman of the Board.
The Company shall promptly intimate this code of practices and procedures for fair disclosure of unpublished price sensitive information and every amendment thereto to the Stock exchanges.
This Code shall be published on official website of the Company www.neocorp.co.in