Code on Prevention of Insider Trading
Framework prohibiting trading in company securities by designated persons on the basis of unpublished price-sensitive information, under SEBI (Prohibition of Insider Trading) Regulations 2015.
Scope
The code applies to designated persons of KW Group entities (directors, KMP, designated employees and their immediate relatives), connected persons, and any other persons identified by the Compliance Officer as having access to UPSI.
Trading window
The trading window is closed during periods when designated persons are likely to be in possession of UPSI — including from the end of every quarter until 48 hours after the publication of financial results. Pre-clearance is required for trades above prescribed thresholds.
Disclosure obligations
Designated persons disclose their holdings at the time of appointment, at the end of every financial year and whenever a trade above the prescribed threshold is executed. The Company maintains a structured digital database of UPSI and related access.
Penalties
Violations are reported to the Audit Committee and may attract disciplinary action including warning, withholding of bonus or termination — without prejudice to action by the regulator under the SEBI Act 1992.
About this policy