SEBI insider trading rules for a listed operating company

Does SEBI's insider trading code apply to your company if you are an exporter or manufacturer, not a financial firm?

Yes, and the regime does not soften for you. The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 [Last amended on March 12, 2025] is status-based, not sector-based . Regulation 8(1) binds "the board of directors of every company, whose securities are listed on a stock exchange". Regulation 9(1) binds "the board of directors of every listed company". There is no carve-out for non-financial issuers, no turnover floor, and no market-capitalisation threshold. A Rs 300 crore auto-component maker and a large private bank read the same words.

The reach starts before the shares ever trade. Regulation 4(1) prohibits trading by any insider in securities that are "listed or proposed to be listed", and regulation 2(1)(hb) defines proposed to be listed to include an unlisted company that has filed offer documents with SEBI, the stock exchanges or the registrar of companies in connection with listing, or that is getting listed pursuant to a merger or amalgamation and has filed the scheme under the Companies Act, 2013. A promoter-led exporter mid-IPO, working through the SEBI (Issue of Capital and Disclosure Requirements) Regulations 2018 , is already inside the insider trading regime.

"Securities" carries its Securities Contracts (Regulation) Act, 1956 meaning. SEBI's Comprehensive FAQs on SEBI (PIT) Regulations, 2015 (December 31, 2024) confirm at FAQ 2 that the prohibition covers shares, bonds, debentures and derivatives, and at FAQ 44 that contra-trade restrictions apply to debt securities. So a company with listed NCDs and unlisted equity should read the instrument rather than assume it is out. Its continuous-disclosure companion is the Master Circular for listing obligations and disclosure requirements for Non-convertible Securities, Securitized Debt Instruments and/ or Commercial Paper dated 11 July 2025, not the equity master circular, but the PIT obligations still attach.

Where the rule bites differently for a mid-cap operating company is not in the text but in the plumbing. A broker or a fund has a compliance department purpose-built for this: information barriers, restricted lists, pre-clearance workflows, staff who joined knowing their personal trading is monitored. A manufacturer does not. Its unpublished price sensitive information is created in the sales meeting where a European buyer signs, on the shop floor when a pollution-board notice arrives, and in the treasury call where a lender proposes a restructuring. By people whose job description contains no reference to securities law. The regulation treats both companies identically; only one of them has a system built for it.

And the definition of insider is deliberately wider than your list. Regulation 2(1)(g) makes an insider anyone who is a connected person or is in possession of or has access to unpublished price sensitive information. SEBI's FAQ 3 confirms that a person who is not on the designated-person list is still an insider if they have access. The designated-person list limits the scope of your code of conduct; it does not limit liability.

What actually counts as unpublished price sensitive information inside a manufacturing or export business?

Start with the test, not the list. Regulation 2(1)(n) defines unpublished price sensitive information as information relating to a company or its securities, directly or indirectly, that is not generally available , which upon becoming generally available is likely to materially affect the price of the securities. Everything else in the definition is illustration.

The illustrations now run to sixteen items , and this is the change that matters most to an operating company: items (vi) to (xvi) were inserted, and items (iv) and (v) expanded, by the Securities and Exchange Board of India (Prohibition of Insider Trading) (Amendment) Regulations, 2025 with effect from June 10, 2025 . Before that amendment the list was short and financial-statement-shaped. After it, ordinary operating events are named on the face of the regulation.

Item (iv) now reads "mergers, de-mergers, acquisitions, delistings, disposals and expansion of business, award or termination of order/contracts not in the normal course of business and such other transactions". A three-year OEM supply contract and the loss of an anchor customer are expressly on SEBI's own list. Item (xvi) covers "granting, withdrawal, surrender, cancellation or suspension of key licenses or regulatory approvals". The pollution-board consent, the factory licence, the export authorisation. Item (xiii) covers actions initiated or orders passed within India or abroad by any regulatory, statutory, enforcement authority or judicial body against the company, its directors, key managerial personnel, promoter or subsidiary.

The remaining new items read like a list of the things a mid-cap's board actually discusses: item (x), a resolution plan, restructuring or one-time settlement of bank borrowings; item (xii), the initiation of a forensic audit and the receipt of the final report; item (ix), fraud or default by the company, promoter, director, key managerial personnel or subsidiary, or the arrest of any of them, whether in India or abroad; item (vii), fund raising proposed to be undertaken; item (vi), a change in rating other than ESG ratings; and item (v), changes in key managerial personnel other than superannuation or end of term, and the resignation of a Statutory Auditor or Secretarial Auditor.

Materiality is not left to instinct. Explanation 2 to regulation 2(1)(n) imports the materiality guidance in paragraph A and paragraph B of Part A of Schedule III of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 for identifying these events, which means the LODR materiality policy and the PIT classification have to be run off the same yardstick. If your disclosure committee applies one threshold and your compliance officer applies another, one of them is wrong by construction.

Finally, the other half of the test. Regulation 2(1)(e) defines generally available information as information accessible to the public on a non-discriminatory basis, and expressly excludes an unverified event or information reported in print or electronic media . A leak to a newspaper does not cleanse the information; if anything it increases the risk, because trading now looks informed against a published rumour. Information published on a stock exchange website would ordinarily be considered generally available.

Run it against regulation 2(1)(n): first the general limb, then the sixteen illustrative items, checking specifically whether it is an award or termination of an order or contract not in the normal course of business under item (iv), a change affecting key licences or regulatory approvals under item (xvi), or a regulatory or judicial action under item (xiii). Apply the materiality guidance in paragraph A and paragraph B of Part A of Schedule III of LODR 2015, which Explanation 2 to 2(1)(n) imports. Confirm it is not already generally available under regulation 2(1)(e). And remember that an unverified press report does not make it generally available. </>), soThat: (<> You classify the event before anyone circulates it, rather than reverse-engineering a classification after a trade has been questioned. </>), }, , , , , , ]} conclusion= />

Who are your designated persons, and how far does the rule reach into their families?

Regulation 9(4) requires the board, in consultation with the compliance officer, to specify designated persons on the basis of role, function and access to UPSI in addition to seniority and professional designation. And then mandates five inclusions: (i) employees designated on functional role or access; (ii) employees of material subsidiaries so designated by their boards; (iii) all promoters of listed companies; (iv) the Chief Executive Officer and employees up to two levels below the CEO of the listed company, intermediary, fiduciary and its material subsidiaries irrespective of functional role or ability to access UPSI; and (v) support staff such as IT staff or secretarial staff who have access to UPSI.

For an operating company, item (iv) is the sweeper. Two levels below the CEO in a manufacturer is not a row of finance managers. It is the plant head, the export sales head, the head of procurement. They are in irrespective of whether they can access UPSI. And item (v) catches the people no org chart flags: the secretary who typed the board note and the IT administrator who backs up the shared drive where the draft contract sits. SEBI's FAQ 49 confirms that IT and secretarial staff with access must be listed.

Two more FAQs close common gaps in a group structure. FAQ 50 confirms that a whole-time director or managing director of a holding company should be added as a designated person of the subsidiary where the role gives access to the subsidiary's UPSI. FAQ 51 confirms that regulation 9(4)(iii) covers all promoters, and that promoter group members with access to UPSI must also be brought in. Which in a promoter-led exporter usually means several family members who hold no office at all.

Then the family reach. Regulation 2(1)(f) defines an immediate relative as a spouse of a person, and includes the parent, sibling and child of that person or of the spouse, any of whom is either dependent financially on such person or consults such person in taking decisions relating to trading in securities. SEBI's FAQ 57 states that a spouse is presumed to be an immediate relative unless rebutted. So the burden runs the wrong way for anyone hoping a spouse's account sits outside the code.

Separately (and this is a different definition doing a different job) regulation 2(1)(hc), inserted by the Third Amendment Regulations, 2024 with effect from December 6, 2024 , defines "relative" as spouse; parent of the person and of the spouse; sibling of the person and of the spouse; child of the person and of the spouse; and the spouses of those siblings and children. Regulation 2(1)(d)(ii)(a) then deems a relative of a connected person to be a connected person unless the contrary is established . The same amendment added two deemed categories that catch a family business hard: 2(1)(d)(ii)(k), a firm, its partner or its employee where a connected person is also a partner; and 2(1)(d)(ii)(l), a person sharing household or residence with a connected person.

Clause 14 of Schedule B turns all of this into an annual data collection. Designated persons must disclose to the company, annually and as and when the information changes, the names and PAN of their immediate relatives, of persons with whom they share a material financial relationship, and the phone, mobile and cell numbers they use; and, on a one-time basis, the educational institutions from which they graduated and the names of past employers. A material financial relationship is defined there as a relationship in which one person receives any kind of payment such as a loan or gift from a designated person during the immediately preceding twelve months equivalent to at least 25% of that designated person's annual income , excluding arm's length transactions.

What has to go into the structured digital database, and can you run it on a vendor tool?

Regulation 3(5) requires the board of directors or head of the organisation of every person required to handle unpublished price sensitive information to ensure that a structured digital database is maintained containing the nature of the UPSI , the names of the persons who have shared the information, and the names of the persons with whom it was shared , along with the PAN or any other identifier authorised by law where PAN is not available. The same sub-regulation states that the database shall not be outsourced and shall be maintained internally with adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering.

The vendor question deserves a direct answer, because most mid-cap companies buy this rather than build it. SEBI's FAQ 8 states that where a third-party vendor provides the software on a login basis and the server is maintained by the vendor, the vendor may have access to those records, "which would be contrary to the regulations". FAQ 7 states that where the structured digital database is kept on cloud or by any other method, the Board of the company is solely accountable , and the board and the compliance officer must ensure confidentiality, integrity and security of the data and logs, and are responsible and accountable for any violation. Read together: the question is not whether software is involved, it is whether the records sit somewhere a third party can read them.

Two further clarifications remove common excuses. FAQ 10 makes clear that the database must be updated even when UPSI is shared only within the company , as and when the information gets transmitted. Internal circulation is not exempt. FAQ 9 confirms there is no requirement to publish the company's list of UPSI on its website, so the database is an internal control record, not a disclosure.

The proviso to regulation 3(5), inserted by the 2025 amendment with effect from June 10, 2025 , allows entry of information not emanating from within the organisation to be made not later than 2 calendar days from receipt of that information. That grace does not extend to UPSI your own people generate. Regulation 3(6) requires the database to be preserved for a period of not less than eight years after completion of the relevant transactions, and where SEBI communicates any investigation or enforcement proceedings, the relevant information must be preserved till completion of that proceeding.

None of this makes sense in isolation from the sharing rules that feed it. Regulation 3(1) prohibits communicating, providing or allowing access to UPSI except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations. Regulation 3(2A) requires the board to make a policy for determination of legitimate purposes as part of the Codes of Fair Disclosure and Conduct formulated under regulation 8, with the Explanation illustrating legitimate purpose as ordinary-course sharing with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals or other advisors or consultants, provided it is not done to evade or circumvent the regulations. Regulation 3(2B) then makes any person who receives UPSI for a legitimate purpose an insider , with due notice to be given to maintain confidentiality.

When must the trading window close, and when is it allowed to reopen?

Clause 4(1) of Schedule B makes the notional trading window the monitoring instrument: it shall be closed when the compliance officer determines that a designated person or class of designated persons can reasonably be expected to have possession of unpublished price sensitive information, and such closure shall be imposed in relation to the securities to which that UPSI relates . Designated persons and their immediate relatives shall not trade when the window is closed.

The proviso inserted by the 2025 amendment with effect from June 10, 2025 states that for UPSI not emanating from within the listed company, the trading window may not be closed. So the source of the information now decides whether closure is mandatory, and every classification note needs to record which side of that line the item falls on. That record is the only thing that later explains why the window stayed open.

Clause 4(2) imposes the calendar-driven closure that every operating company must run without being told: the trading restriction period shall be made applicable from the end of every quarter till 48 hours after the declaration of financial results , with the gap between clearance of accounts by the audit committee and the board meeting to be as narrow as possible and preferably on the same day, to avoid leakage. This closure needs no determination by anyone: it fires on 31 March, 30 June, 30 September and 31 December by operation of the clause.

SEBI's FAQ 33 answers "Shall the trading window be closed for every UPSI?" with a single word: Yes . FAQ 32 restates the clause 4(1) trigger. FAQ 31 is the one most often missed. The compliance officer must communicate the closure to designated persons, and merely rejecting their trades at the pre-clearance stage is not sufficient. FAQ 29 confirms that a pre-clearance obtained while the window was open becomes invalid once the window closes.

Clause 5 governs reopening: the timing is determined by the compliance officer taking into account the UPSI becoming generally available and being capable of assimilation by the market, and in any event shall not be earlier than forty-eight hours after the information becomes generally available. Forty-eight hours is a floor, not a default. Assimilation by the market is a judgement the compliance officer has to make and record.

Clause 4(3) carves out a defined set of transactions from window restrictions. They do not apply to the transactions in clauses (i) to (iv) and (vi) of the proviso to regulation 4(1). Which include off-market inter-se transfers between insiders, block deal window trades, transactions carried out to satisfy a statutory or regulatory obligation, exercise of stock options at a pre-determined price, and trades executed under a trading plan approved under regulation 5. Nor do they apply to a pledge of shares for a bona fide purpose such as raising funds, subject to pre-clearance by the compliance officer; nor to transactions undertaken in accordance with SEBI regulations such as acquisition by conversion of warrants or debentures, subscribing to a rights issue, further public issue or preferential allotment, or tendering shares in a buy-back offer, open offer or delisting offer. Add FAQ 30 (the grant of an ESOP is not trading and can be made during window closure) and FAQ 4, which exempts transmission of shares from trading window closure, pre-clearance and contra trade, while leaving the disclosure norms intact.

How do the contra-trade and pre-clearance rules trap a director who has done nothing wrong?

Because these rules do not ask whether you had UPSI. They ask what you traded and when.

Clause 6 of Schedule B provides that when the trading window is open, trading by designated persons is subject to pre-clearance by the compliance officer if the value of the proposed trades is above such thresholds as the board of directors may stipulate . The threshold is a board decision, so there is no number to quote here. Read your own code. Clause 8 entitles the compliance officer to seek declarations that the applicant is not in possession of UPSI and to consider whether any such declaration is reasonably capable of being rendered inaccurate. Clause 9 caps the execution window: the code shall specify a reasonable timeframe, which in any event shall not be more than seven trading days , within which pre-cleared trades must be executed, failing which fresh pre-clearance is needed.

Clause 10 is the contra-trade rule and the one that catches honest people. The code shall specify a period, which in any event shall not be less than six months , within which a designated person who is permitted to trade shall not execute a contra trade. The compliance officer may be empowered to grant relaxation from strict application for reasons recorded in writing, provided the relaxation does not violate the regulations. And should a contra trade be executed, inadvertently or otherwise , the profits from that trade shall be liable to be disgorged for remittance to SEBI for credit to the Investor Protection and Education Fund . The proviso exempts trades pursuant to exercise of stock options.

The FAQ layer decides the real cases. FAQ 36 states that any buy/sell trade by a designated person and their immediate relatives within 6 months of an earlier sell/buy trade, where both trades were done in open market , is a contra trade; its footnote treats acquisitions or disposals through corporate actions (rights issue, FPO, OFS, bonus, split, exit offers, buy-back, open offer, merger, amalgamation, demerger) as non-open-market trades, with everything else being open market. FAQ 43 confirms the restriction runs date-wise from the most recent trade , not lot-wise. So a fresh purchase restarts the clock for the whole holding. FAQ 42 confirms contra-trade restrictions apply to the designated person and immediate relatives collectively , per clause 3 of Schedule B, and FAQ 42A confirms the restriction applies to all shares held under the designated person's PAN irrespective of the capacity in which they are held.

FAQ 47 confirms contra-trade restrictions apply to every trade regardless of whether it is above or below the pre-clearance threshold. A small trade escapes pre-clearance, not the six-month clock. FAQ 44 extends the restrictions to debt securities and FAQ 44A to rights entitlements. FAQ 45 confirms a gift is a trade requiring compliance with disclosure, pre-clearance and contra-trade restrictions. FAQ 37 states that a derivative contract physically settled on expiry is not a contra trade, but closing the contract before expiry (a cash-settled position) means taking a contra position, while index-derivative exposure need not be reported. On employee stock options, FAQ 27 requires pre-clearance for a cashless ESOP where exercise and sale happen simultaneously, while only the exercise itself is exempt; FAQ 28 requires pre-clearance for off-market transfers.

For anyone perpetually in possession of UPSI (a founder-CEO of a mid-cap exporter usually is) the structural answer is a trading plan under regulation 5. Regulation 5(2)(i) bars commencement of trading on behalf of the insider earlier than one hundred and twenty calendar days from public disclosure of the plan, substituted for the earlier six-month cool-off by the Second Amendment Regulations, 2024 with effect from September 24, 2024 . FAQ 16A confirms there is no minimum or maximum plan duration. FAQ 16B requires each trade to state either the value or the number of securities, the nature (buy or sell), and either a specific date or a period not exceeding five consecutive trading days. FAQ 16C makes the price limit optional but caps it at a range of up to 20% against the closing price on the day before submission. FAQ 16F confirms no pre-clearance is needed for trades under an approved plan. FAQ 16D requires the insider to inform the compliance officer within two trading days from the end of the plan's tenure where the plan is not implemented. And the contra-trade rule does not disappear inside a plan: FAQ 38 states contra trade is not allowed within the duration of the trading plan, and FAQ 16G applies contra-trade restrictions across two separate trading plans.

Meridian Alloys Limited is a listed auto-component exporter with a market capitalisation of about Rs 2,400 crore and no financial-services business. Its Q1 FY2026-27 ended on Tuesday 30 June 2026. On Monday 6 July 2026 it signs a three-year supply contract with a European OEM worth roughly 40% of last year's turnover. An order well outside its normal course of business. The board meeting to approve Q1 results is set for Tuesday 11 August 2026. The company's CFO bought 4,000 shares of Meridian in the open market on Wednesday 20 May 2026 and wants to sell them as soon as the window reopens. </> } result= >

What has to be reported to the company and the exchange, and what happens when it is missed?

Chapter III sets two layers of disclosure: an initial one on appointment, and a continual one on trading.

Regulation 7(1)(b) requires every person, on appointment as a key managerial personnel or director of the company, or on becoming a promoter or a member of the promoter group, to disclose their holding of securities of the company as on the date of appointment or of becoming a promoter, to the company within seven days .

Regulation 7(2)(a) then requires every promoter, member of the promoter group, designated person and director to disclose to the company the number of securities acquired or disposed of within two trading days of the 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 other value as may be specified. Regulation 7(2)(b) requires the company to notify the particulars to the stock exchange within two trading days of receipt of the disclosure or of becoming aware of the information. Its Explanation (reinforced by SEBI's FAQ 19) clarifies that once a disclosure has been made, the next disclosure falls due only when transactions effected after the prior disclosure themselves cross the ten lakh rupee threshold.

Regulation 6 widens all of this. Regulation 6(2) extends every disclosure under Chapter III to trading by the person's immediate relatives and by any other person for whom that person takes trading decisions. Confirmed at FAQ 22. Regulation 6(3) brings derivatives into the disclosure net and requires their traded value to be counted. Regulation 6(4) requires the company to maintain these disclosures for a minimum period of five years . And regulation 7(3) lets a listed company, at its discretion, require any other connected person or class of connected persons to disclose holdings and trading. The lever to use on a management consultant or a technical collaborator who must see UPSI but sits outside your payroll.

There is a system-driven layer on top. SEBI Circular SEBI/HO/ISD/ISD/CIR/P/2020/168 dated September 09, 2020 mandated system-driven disclosures for members of the promoter group and designated persons in addition to promoters and directors under regulation 7(2), as recorded at FAQ 17. FAQ 18 notes these will not trigger for a designated person who has no PAN or demat account, since such a person cannot trade in the Indian securities market. Which is a reason to keep the PAN field on your designated person register complete rather than a reason to relax. Separately, the proviso to regulation 4(1)(i) requires an off-market inter-se transfer between insiders to be reported by the insiders to the company within two working days, with the company notifying the particulars to the stock exchange within two trading days of receipt or of becoming aware.

Now the consequences, in ascending order and confined to what is verifiable on the face of the instruments. Schedule B clause 10: profits from a contra trade are liable to be disgorged for remittance to SEBI for credit to the Investor Protection and Education Fund. Schedule B clause 12: the code of conduct must stipulate sanctions and disciplinary actions including wage freeze, suspension and recovery for contravention of the code, and any amount collected must be remitted to SEBI for credit to the same fund. Schedule B clause 13: on observing a violation of the regulations, the listed company must promptly inform the stock exchange(s) where the concerned securities are traded, in the form and manner specified by SEBI.

Regulation 9A(5) requires every listed company to have board-approved written policies and procedures for inquiry into a leak or suspected leak of UPSI, to initiate inquiries on becoming aware, and to inform SEBI promptly of such leaks, inquiries and results. Regulation 10 leaves any contravention of the PIT Regulations to be dealt with by SEBI in accordance with the Securities and Exchange Board of India Act, 1992 , whose section 15G carries the monetary penalty for insider trading. SEBI's published text of section 15G states a penalty of twenty-five crore rupees or three times the amount of profits made out of insider trading, whichever is higher. Check the current text of section 15G before relying on that figure. Conduct that shades into manipulation is separately reachable under the SEBI (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003 , which are conduct-based and apply to any person dealing in securities.

Board-level insider trading compliance checklist for a listed operating company

Every item below is keyed to the clause that requires it, so a company secretary can put it straight into a board pack and mark each line against evidence rather than assertion.

The artefacts a board must be able to produce

• Code of practices and procedures for fair disclosure of UPSI adhering to the Schedule A principles, formulated by the board, published on the company's official website under regulation 8(1) and promptly intimated to the stock exchanges where the securities are listed under regulation 8(2).
• A chief investor relations officer. A senior officer designated to deal with dissemination of information and disclosure of UPSI (Schedule A clause 3). FAQ 56 notes it is the company's discretion whether the CIRO and the compliance officer are the same person, and that where both have overlapping functions they are jointly and severally responsible.
• A board policy for determination of legitimate purposes as part of the Codes of Fair Disclosure and Conduct (regulation 3(2A)), and a standing practice of serving notice on every recipient of UPSI that they are now an insider (regulation 3(2B)).
• A code of conduct adopting the Schedule B minimum standards , formulated by the CEO or managing director with the board's approval under regulation 9(1), fixing the pre-clearance threshold (clause 6), the execution window of not more than seven trading days (clause 9), the contra-trade period of not less than six months (clause 10), the sanctions under clause 12, and the formats under clause 11 for pre-clearance applications, reporting of executed trades, reporting of decisions not to trade after securing pre-clearance, and reporting of holdings.
• A compliance officer designated under regulation 9(3) meeting the regulation 2(1)(c) description (a senior officer reporting to the board of directors, financially literate, meaning able to read and understand a balance sheet, profit and loss account and cash flow statement) reporting to the board and in particular to the Chairman of the Audit Committee at a frequency set by the board but not less than once a year (Schedule B clause 1).
• A board-approved designated-person list built on regulation 9(4)(i) to (v), refreshed when the org chart moves rather than annually, because 9(4)(iv) is defined by reporting distance from the CEO.
• A structured digital database that is internal, time-stamped, audit-trailed and never outsourced (regulation 3(5)), with the eight-year retention rule wired into IT policy (regulation 3(6)).
• Internal controls under regulation 9A(1) and 9A(2) covering identification of designated persons, identification and confidentiality of UPSI, restrictions on communication and procurement, maintenance of lists with signed confidentiality agreements or served notices, compliance with all other requirements, and periodic process review of effectiveness.
• An Audit Committee review of compliance with these regulations at least once in a financial year, verifying that the internal control systems are adequate and operating effectively (regulation 9A(4)).
• Leak-inquiry policies and a whistle-blower policy. Board-approved written policies and procedures for inquiry into a leak or suspected leak of UPSI with prompt intimation to SEBI (regulation 9A(5)), and a whistle-blower policy that employees are made aware of, enabling them to report leaks of UPSI (regulation 9A(6)).
• Annual and change-triggered declarations from designated persons of immediate relatives, persons with whom they share a material financial relationship, and the phone, mobile and cell numbers they use, plus one-time disclosure of educational institutions and past employers (Schedule B clause 14).
• A documented wall-crossing process setting out how and when people are brought inside on sensitive transactions, making individuals aware of the duties, responsibilities and liability attaching to receipt of inside information (Schedule B clause 15).

Update history

• 2026-08-14 First published.