Inside Trading Caution

Code of Practices and Procedures for

Fair Disclosure of Unpublished Price Sensitive Information

(Approved by the Board of Directors in their meeting held on 13th November, 2015)

This document forms the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Code”) adopted by Shikhar Consultants Limited (SHIKHAR). This Code is consistent with the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015.

The Principles of Fair Disclosure adopted by SHIKHAR are as follows :

  1. To promptly make public disclosure of unpublished price sensitive information that would impact price discovery. Such disclosures are made no sooner than credible and concrete information comes into being in order to make such information generally available.
  1. To make public disclosure of unpublished price sensitive information, as and when made, in a universal and uniform manner through forums like widely circulated media and / or through Stock Exchanges where its equity shares are listed. Selective disclosure of make public disclosure of unpublished price sensitive information is to be avoided.
  1. SHIKHAR Compliance Officer serves as its Chief Investor Relations Officer(s) to deal with disseminations of information and disclosure of unpublished price sensitive information.
  1. To promptly disseminate unpublished price sensitive information that gets disclosed selectively, inadvertently or otherwise if at all, to make such information generally available.
  1. To provide appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities.
  1. To ensure that information shared with analysts and research personnel is not unpublished price sensitive information.
  1. To publish proceedings of meetings with analysts and of other investor relations conferences on its official website www.shikharconsultants.com.
  1. To handle all unpublished price sensitive information on a need to know basis only.