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Code of Practices and Procedure for Fair Disclosure of Unpublished Price Sensitive Information (“Code”)
Pursuant to Regulation 8(1) of the Securities Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 ("Regulations")

Altico Capital India Private Limited (the “Company”) has formulated this Code in adherence to the principles set out in Schedule A of the Regulations. The Company shall follow below principles to ensure timely, fair and adequate disclosure of Unpublished Price Sensitive Information (“UPSI”):

  • The Company shall promptly disclose the UPSI that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available.

  • The Company shall ensure uniform and universal dissemination of UPSI to avoid selective disclosure.

  • The Compliance Officer of the Company shall act as the “Chief Investor Relations Officer” to deal with dissemination of information and disclosure of UPSI. The UPSI shall be hosted in the website of the Company after the information is furnished to the Stock Exchanges.

  • The Company shall ensure prompt dissemination of UPSI that gets disclosed selectively, inadvertently or otherwise to make such information generally available.

  • The Company shall make all efforts to clarify rumours/queries on news report and request for verification of market rumours by regulatory authorities, by providing fair and adequate response.

  • The Company shall ensure that the information shared with the analysts and research personnel is not UPSI.

  • The Company shall develop 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 disclosure is made.

  • All UPSI shall be handled only on a need to know basis.

This Code shall be published on the website of the Company. This Code is subject to review from time to time and every amendment thereto shall be intimated to the stock exchange(s) where the securities of the Company are listed. The Board of Directors of the Company reserves right to stipulate further guidelines, procedures and practices in order to ensure fair disclosure of UPSI.This Code shall come into effect from March 3, 2016.

This Code shall come into effect from March 3, 2016.

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