In appreciation of good services, Mohan Lal head of finance, has received an email regarding granting of 1000 ESOP (Employee Stock Option Plan) from XYZ Ltd on April 10, 2024 and these shares will be vested to him on Apr
CS Professional · Secretarial Audit, Compliance Management and Due Diligence · PYQS · June 2025
In appreciation of good services, Mohan Lal head of finance, has received an email regarding granting of 1000 ESOP (Employee Stock Option Plan) from XYZ Ltd on April 10, 2024 and these shares will be vested to him on April 10, 2025. XYZ Ltd has disclosed his Annual financial result on 25 April, 2024. Now, advise whether this transaction of 1000 shares of XYZ Ltd. to Mohan Lal (Designated person) will come under the preview of Insider Trading as per SEBI Regulations ? And which date will be the opening date of Trading window closure period of the company, for the quarter and financial year ending on March 31, 2024 ?
Answer & Explanation:
As per SEBI (Prohibition of Insider Trading) Regulations, 2015 read with FAQs on SEBI (PIT) Regulations dated December 31, 2024: Grant of ESOP refers to a right but not an obligation to acquire the shares of the company as and when the options are vested and correspondingly exercised by the Employees. Hence, grant of ESOP per se is not trading and accordingly can be made during trading window of closure. Granting of ESOP to employees does not involve trading in the shares of XYZ Ltd, moreover, that shares will vest to him on April 10, 2025 that means after a year. Hence, since no trading is involved. Hence, No Insider trading take place. Opening of trading window closure period: Clause 4 of Schedule B read with Regulation 9 of SEBI (Prohibition of Insider Trading) Regulations, 2015. Trading restriction period shall be made applicable from the end of every quarter till 48 hours after the declaration of financial results. Trading window closure period will be from April 1, 2024 to April 27, 2024. Hence opening of Trading window closure period will be from 27 April, 2024.i.e, 48 hours after the declaration of financial results by the XYZ Limited.
Topics: SEBI Regulations
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