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Trading Window closure period under Clause 4 of Schedule B read with Regulation 9 of SEBI (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”) – Framework for restricting trading by Designated Persons (“DPs”) by freezing PAN at security level

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....PAN at security level 1. Clause 4 (1) of Schedule B read with Regulation 9 of PIT Regulations, inter-alia, states that "Designated persons may execute trades subject to compliance with these regulations. Towards this end, a notional trading window shall be used as an instrument of monitoring trading by the designated persons. The trading window shall be closed when the compliance officer determines that a designated person or class of designated persons can reasonably be expected to have possession of unpublished price sensitive information ("UPSI"). Such closure shall be imposed in relation to such securities to which such UPSI relates. Designated persons and their immediate relatives shall not trade in securities when the trading window ....

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....uarter ending September 30, 2022. 7. The Compliance Officer and DPs of listed companies shall continue to independently comply with the obligations under PIT Regulations, as applicable to them, till further communication. 8. The Depositories and Stock Exchanges are directed to: 8.1. take necessary steps to put in place systems for implementation of this circular. 8.2. bring the provisions of this circular to the notice of all listed companies and also disseminate the same on their websites. 9. This circular is issued in exercise of the powers conferred under Section 11(1) of the Securities and Exchange Board of India Act, 1992, read with Regulations 4(3) and 11 of the PIT Regulations, to protect the interests of investors in securiti....

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....cases) of DPs. In the event any updation is required to the aforementioned details, the listed company shall take necessary steps as per para 10 below. 4. DD shall provide a facility to the listed company to specify the 'Trading Window Closure Period' i.e. 'Commencement Date' and 'End Date' on portal/platform. 4.1. With respect to financial results, the listed company shall specify the 1st day (T- day) immediately after the end of every quarter for which results are to be announced as 'Trading Window Closure commencement date' and the date on which 48 hours ends post disclosure of financial results as 'Trading Window Closure End date' in the portal/platform. 5. The listed company shall provide the aforesaid details atleast 2 trading days....

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....period. As per the example mentioned above, Commencement Date of trading window closure period shall be October 01, 2022, for the quarter ending September 30, 2022. 10. In case of any addition/deletion/updation pertaining to the details of DP, the listed company has to follow the procedure specified in terms of SEBI Circular No. SEBI/HO/ISD/ISD/CIR/P/2020/168 dated September 09, 2020 and shall be required to separately provide the details as mentioned at paras 3 and 4 above. Such instances shall be effected within 2 trading days of receipt of intimation from the listed company. For example, assuming the trading window closure period is October 01 - 15, 2022 and if the listed company adds any DP on October 10, 2022, then the change i.e. fre....