INSIDER TRADING CODE


Guidelines/Circulars for Trading in the Shares of Sumeet Industries Limited

All the directors/ officers/designated employees of the company be and is hereby informed that all their dealings in the shares & securities of the Company shall be made only in a valid Trading Window and shall not deal in any transaction involving the purchase or sale of the company’s shares & securities during the periods when trading window is closed or during any other period as may be specified by the Company from time to time.

Trading window

The trading window shall be closed during the time the information referred below is un-published and it shall be opened 24 hours after the information referred below to be made public/announced.

a. Declaration of Financial results (quarterly, half-yearly and annual)

b. Declaration of dividends (interim and final)

c. Issue of securities by way of public/ rights/bonus etc.

d. Any major expansion plans or execution of new projects

e. Amalgamation, mergers, takeovers and buy-back

f. Disposal of whole or substantially whole of the undertaking

g. Any changes in policies, plans or operations of the company

When the trading window is closed, the employees/directors shall not trade in the company’s shares & securities in such period.

Reporting Requirements for transactions in securities

All the directors/officers/designated employees of the company shall be required to forward following details of their shares & securities’ transactions including the statement of dependent family members to the Company.

a) All holdings in shares & securities of the company.

b) Periodic / monthly statement of any transactions in shares & securities of the company.

c) Annual statement of all holdings in shares & securities.

Penalty for contravention of code of conduct

Any employee/ officer / director who trades in securities or communicates any information for trading in securities, in contravention of the code of conduct disciplinary action may be taken by the company.