"The key managerial personnel or promoters may have a chance of getting Unpublished Price Sensitive Information (UPSI) perpetually." Is there any mechanism for trading in securities of the Company by the insiders under t

In case where the key managerial personnel or promoters may have a chance of getting Unpublished Price Sensitive Information (UPSI) perpetually, they may trade in the securities by submitting Trading Plan and necessary compliance related thereto. Regulation 5 of the SEBI (Prohibition of Insider Trading) Regulations, 2015 states that an insider would be required to submit trading plan in advance to the compliance officer for his approval. The compliance officer is also empowered to take additional undertakings from the insiders for approval of the trading plan. Such trading plan on approval will also be disclosed to the Stock Exchanges, where the securities of the company are listed. The trading plan shall comply with the following requirements: It shall be submitted for a minimum period of 12 months. No overlapping of plan with the existing plan submitted by Insider It shall set out either the value of trades to be effected or the number of securities to be traded along with the nature of the trade and dates on which such trades shall be effected. Trading can only commence only after 6 months from public disclosure of plan. No trading between 20th day prior to closure of financial period and 2nd trading day after disclosure of financial results. Compliance officer to approve the plan. The trading plan once approved shall be irrevocable and the insider shall mandatorily have to implement the plan, without being entitled to either deviate from it or to execute any trade in the securities outside the scope of the trading plan. Upon approval of the trading plan, the compliance officer shall notify the plan to the stock exchanges on which the securities are listed.