Insider Trading Policy

Insider Trading Policy

1. Introduction :

As required by to Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 and SEBI Circular dated: 11-05-2015, Kumbhat Financial Services Limited. (‘the Company’) has evolved a Code of Fair Disclosure, Code of Conduct, Code of Internal Procedures for Regulating , Monitoring and Reporting of trading by Insiders for prevention of insider trading by Promoters I Directors I Designated Employees I Connected Person of the Company, in relation to the securities of the company.
Accordingly, the Board of Directors (“the Board”) of the Company has adopted and formulated Codes, in compliance with the applicable regulations of the SEBI and the Listing Agreement and also to upload those codes on Company’s website at www.kumbhatfinancialservieslimited.com under the section heading Investors.

2. Definitions:

i) “Compliance Officer” means the senior officer designated so from time to time of the company for the
ii) Purpose of administration of the insider trading policy, in compliance with the provisions of SEBI insider Trading Regulations.
iii) “Connected Persons” means: any person who is or has during the six months prior to the concerned act been associated with the Company, directly or indirectly, in any capacity including by reason of frequent communication with its officers or by being in any contractual, fiduciary or employment relationship or by being a Promoter, director, designated officer or an designated employee of the Company or holds any position including a
professional or business relationship between himself and the Company whether temporary or permanent, that allows such person, directly or indirectly, access to unpublished price sensitive information or is reasonably expected to allow such access.