Untitled document

Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information

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 Code of Practices and Procedures for Fair Disclosure of Unpublished
Price Sensitive Information.

[As originally approved and adopted under sub-regulation (1) of regulation 8 on 14.05.2015]

The Board of Directors of M/s PACT INDUSTRIES LIMITED is commited to manage the affairs of the Company in a fair, transparent and ethical manner keeping in view the needs and interest of all stakeholders. The Company upholds the basic tenets of Corporate Goveranance and to put in place a framework for prohibition of insider trading in securities and to strengthen the legal framework of the Company by prohibiting and regulating such activities within the applicable law.Regulation 8 of SEBI (Prohibition of Insider Trading) Regulations, 2015 ("Insider Regulations") prescribes all listed companies to formulate and publish on its official website a 'Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information' ("Code of Fair Disclosure") as per Schedule A of the Insider Regulations.

1. Preface

1.1 SEBI vide its Circular No. No. LAD-NRO/GN/2014-15/21/85 dated 15.01.2015 has introduced the Insider Regulations to be effective from 15.05.2015.

1.2 Regulation 8 in Chapter IV of SEBI (Prohibition of Insider Trading) Regulations, 2015 provides for the formulation of a Code of Fair Disclosure.

1.3 The Code of Fair Disclosure shall be applicable to the Promoters, Key Managerial Personnel, Board Members and Employees of the Company.

2. Prompt public disclosure of Unpublished price sensitive information.

2.1 There shall be prompt public disclosure of unpublished price sensitive information that would impact price discovery no sooner than credible and concrete information comes into being in order to make such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.

2.2 There shall be uniform and universal dissemination of unpublished price sensitive information to avoid selective disclosure. The Compliance Officer of the Company shall act as a chief investor relations Price Sensitive Information. officer to deal with dissemination of information and disclosure of unpublished price sensitive information.

2.4. There shall be prompt dissemination of unpublished price sensitive information that gets disclosed selectively, inadvertently or otherwise to make such information generally available.

3. Responding to market rumours.

3.1 There shall be appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities.

4. Information sharing with Analysts

4.1 The Company shall ensure that information shared with analysts and research personnel is not unpublished price sensitive information.

4.2 The Company shall develope best practices to make 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 made.

5. Information handling on need to know basis

5.1 All unpublished price sensitive information shall be handled on a need-to- know basis.

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