upsi procurement communication blanket
Yes, there is a blanket ban on communication and procurement of Unpublished Price Sensitive Information (UPSI) by insiders of a company. As per the SEBI (Prohibition of Insider Trading) Regulations, 2015, insiders are prohibited from communicating, providing, or causing to communicate any UPSI, directly or indirectly, to any person including other insiders or analysts, or procuring or causing procurement of such information.
However, there are some limited exemptions to this ban on communication and procurement of UPSI, such as:
Communication of UPSI in the ordinary course of business, profession, or employment, if such communication is necessary for the conduct of such business, profession, or employment.
Communication of UPSI to a statutory/regulatory authority, in order to comply with any law or regulation.
Communication of UPSI in the case of a lawful obligation or duty, such as responding to a subpoena or summons from a court or regulatory authority.
Communication of UPSI in the course of an investigation, enquiry, or audit, conducted by a regulatory authority.
Communication of UPSI between insiders who are in a "need to know" basis, for the purpose of discharging their legitimate functions or duties.
Communication of UPSI between persons who have made a public announcement of a proposed or impending transaction, in order to complete such transaction.
It is important to note that even if there is an exemption for communication or procurement of UPSI, the insider must ensure that such communication or procurement is legitimate and does not violate any other laws or regulations.
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Hi Abhishek
Regulation 3 of the SEBI (Prohibition of Insider Trading) Regulations 2015 deals with the restriction on communication and procurement of UPSI which states that no insider shall communicate, provide, or allow access to any UPSI relating to a company or securities listed or proposed to be listed to any person, including other insiders, except where such communication is in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.
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