M/s AAA Limited is a public listed company. The company is undergoing into a high growth phase and its shares are highly traded in the recognized stock exchanges. You are the Company Secretary of M/s AAA Limited. It is r

In case of insider trading in the shares of the company by promoter or member of the promoter group or by any director of the company, the under given provision of SEBI (Prohibition of Insider Trading) Regulations 2015 would be relevant which are as under: Regulation 7(2) - Continual Disclosures Within 2 trading days of such transaction a) Every promoter, member of promoter groups and director of every company shall disclose to the company the number of such securities acquired or disposed of within two trading days of such transaction if the value of the securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of ten lakh rupees or such value as may be specified: b) Every company shall notify the particulars of such trading to the stock exchange on which the securities are listed within two trading days of receipt of the disclosure or from becoming aware of such information. (Transaction type include buy/sales/pledge/revoke/ invoke) The above disclosures shall be made in such form and such manner as specified by SEBI from time to time. Since the transactions were made on 30th December, 2022 while it is reported to the company after the expiry of 2 days, it would be non-compliance of the above referred provisions by the members of the promoters group. It would be appropriate that the company report such transactions to the concerned stock exchange within 2 days of the receipt of such information i.e. 6th January, 2023.