General Update on Review and Revision of Code of Conduct and Procedure for Fair Disclosure of UPSI.
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Sulabh Engineers & Services Limited has submitted a revised internal policy document covering its Code of Conduct and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) to the Bombay Stock Exchange. The revised code was last amended on July 5, 2025 and became effective from July 7, 2025, superseding the earlier version originally approved on April 30, 2019. The policy has been updated in line with Regulation 8(1) and 9(1) of SEBI's Prohibition of Insider Trading Regulations, 2015, and defines who qualifies as an insider, connected person, or immediate relative. It also sets out fair disclosure principles, trading window restrictions around quarterly results, pre-clearance requirements for designated persons, and maintenance of a digital database to track UPSI sharing. This is a routine regulatory compliance submission and does not pertain to any financial results, business event, or corporate action.
This is a procedural compliance filing with no material impact on the company's financials, operations, or stock price. It simply reflects the company's adherence to SEBI insider trading disclosure norms and is standard governance housekeeping expected from all listed companies.