CLOSURE OF TRADING WINDOW CHECKLIST FOR SEPTEMBER QUARTER

The following document provides a comprehensive checklist for closing the trading window for the September quarter. It outlines the steps, procedures, and deadlines required for compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015 (as amended).

Checklist for Trading Window Closure

Frequently Asked Questions (FAQs)

1. End Date Modification in Depository System:

• Question: Can the end date of the trading window closure be modified in the depository system?
• Answer: Yes, the end date will be modifiable. The issuer can initially set a notional end date. Once the board meeting date is decided, the end date can be modified, based on T-2 days.

2. Pledge Invocation During PAN Freeze:

• Question: Can pledge invocation occur during the PAN freeze period?
• Answer: No, pledge invocation is not allowed during the PAN freeze period unless the pledge was marked before the trading window closure.

3. Freezing Across Multiple Accounts in Depositories:

• Question: If there are multiple accounts across both depositories, will both depositories freeze the PAN?
• Answer: Yes, the freezing will occur on a PAN-ISIN level basis. If a client has multiple accounts in both depositories, the PAN will be frozen in both. The issuer needs to update the DP details with the Designated Depository only, not both depositories.

4. Depository Intimations to DPs:

• Question: Will depositories send intimation to DPs when a PAN is frozen?
• Answer: Yes, the respective depository will send an SMS or email to the Demat account holder. However, the issuer must also send an intimation to their respective DPs.

5. Freezing of PANs of Immediate Relatives:

• Question: Will the freezing of PANs apply to immediate relatives of Designated Persons (DPs)?
• Answer: Yes, the PANs of immediate relatives, as provided by the issuer, will also be frozen.

Format for Submission to Stock Exchanges

BSE Limited
The General Manager,
Corporate Relation Department,
Phiroze Jeejeebhoy Tower,
44th Floor, Dalal Street,
Mumbai – 400 001
Scrip Code: (Insert Code)

National Stock Exchange of India Limited
Listing Department,
Exchange Plaza, Bandra Kurla Complex,
Bandra (E), Mumbai – 400 051
NSE Symbol: (Insert Symbol)

Subject: Closure of Trading Window

Dear Sir / Madam,

We would like to inform you that in terms of the "Code of Conduct to Regulate, Monitor, and Report Trading by Designated Persons" adopted by the Company pursuant to the SEBI (Prohibition of Insider Trading) Regulations, 2015 (as amended), the trading window for dealing in the Company’s equity shares by Designated Persons, including Promoters, Promoter Group persons, Directors, Key Managerial Personnel (KMPs), employees, auditors (statutory, secretarial, internal), and their immediate relatives, will be closed from October 1, 2024 until 48 hours after the declaration of the Company's un-audited financial results for the quarter ending September 30, 2024.

During this period, Designated Persons are prohibited from trading in the Company's shares/securities.

The date of the Board Meeting for the declaration of the financial results will be communicated in due course.

Kindly take the above on record for your compliance.

Thanking you,

For (Company Name)

(Director/Company Secretary)
(DIN/CIN)

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Article Compiled by:-

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