Code Of Conduct For Prevention of Insider Trading

(Based On Model Code Of Conduct For Prevention Of Insider Trading Issued By SEBI)

The Policy and Obligations
The Company endeavours to preserve the confidentiality of un-published price sensitive information and to prevent misuse of such information. The Company is committed to transparency and fairness in dealing with all stakeholders and in ensuring adherence to all laws and regulations.

Every director, officer, designated employee of the Company has a duty to safeguard the confidentiality of all such information obtained in the course of his or her work at the company. No director, officer, designated employee may use his or her position or knowledge of the Company to gain personal benefit or to provide benefit to any third party.

To achieve these objectives, Subros Ltd. (herein after referred to as "the Company") hereby notifies that this code of conduct is to be followed by all directors, officers, designated employees and connected persons.


Part A – Definitions

Part B

1. Compliance Officer
2. Preservation of "Price Sensitive Information"
3. Prohibition On Dealing, Communicating Or Counselling On Matters Relating To Insider Trading
4. Trading Restrictions
5. Pre-clearance of trades
6. Reporting Requirements for transactions in securities
7. Penalty for contravention of Code of Conduct
8. Information to SEBI in case of violation of the SEBI (Prohibition of Insider Trading) Regulations, 1992

Form A (Click to Download)

Form B (Click to Download)

Form C (Click to Download)