1

PRESIDENCY UNIVERSITY

SUB: SECURITIES LAW

ASSIGNMENT ON “DISCLOSURES UNDER INSIDER

TRADING REGULATIONS”

NAME: P.NITHIN PRAMOD KUMAR

ROLL NUMBER: 20191BAL0050
COURSE: B.A.LLB., (HONS.,)
SUBMITTED TO: PROF. ANJANA HARIDAS
 2

INSIDER TRADING DISCLOSURE AGREEMENT

Itish Trading Ltd.
06.12.2023

This Compliance Agreement (“Agreement”) is made and entered into by and between
Itish Trading Ltd.
(Residing at 5/506 G12, 2nd floor, Kondapur, Hyderabad, Telangana, India.)
AND
K. Varma
(Residing at 6/789 H3, Kachiguda, Hyderabad, Telangana, India.)

WHEREAS,
 Employee has access to Material Non-Public Information (“MNPI”) about Company, its
securities, and its business affairs.

 Company desires to ensure that Employee complies with the Regulations and avoids any
violation thereof.

Now therefore, in consideration of the collective covenants contained herein, and for
other good and precious consideration, the damage and adequacy of which are hereby
conceded, the parties agree as follows:

1) DEFINITIONS:
1.1. “Insider” means any person who is:
(i) a Connected Person or,
(ii) in possession of or having access to Unpublished Price Sensitive
Information.

1.2. “Unpublished Price Sensitive Information” means any information, relating to

the company or the Company’s material subsidiary or the securities of the
Company, directly or indirectly, that is not generally available which upon
becoming generally available, is likely to materially affect the price of the securities
and shall, ordinarily including but not restricted to, information relating to the
following:
1.2.1. financial results;
1.2.2. dividends;
 3

1.2.3. change in capital structure;

1.2.4. mergers, de-mergers, acquisitions, delistings, disposals and expansion of
business and such other transactions;
1.2.5. changes in key managerial personnel;
1.2.6. such other information as determined by the Board of Directors/Chief
Executive Officer/Chief Operating Officer/Chief Financial Officer in
consultation with the Compliance Officer.
2) EMPLOYEE’S OBLIGATIONS:
2.1. Employee shall:
 Comply with all applicable provisions of the Regulations.
 Not disclose any MNPI to any person except as authorized by the
Regulations or by the Company.
 Not trade in the Company’s securities or the securities of any other issuer
while aware of MNPI.
 Immediately report to the Company’s Compliance Officer any known or
suspected violation of the Regulations.
 Attend any training sessions on insider trading conducted by the Company.
 Complete and submit the required disclosures under the Regulations.
2.2. Employee shall not:
× Discuss MNPI with any person not authorized to receive such information.
× Use MNPI for personal gain or benefit.
× Dispose of MNPI in a careless or reckless manner.
3) COMPANY’S OBLIGATIONS:

3.1. Company shall:

 Provide Employee with training on insider trading and the Regulations.
 Establish and maintain a system of internal controls to prevent insider
trading.
 Designate a Compliance Officer responsible for administering the
Company’s insider trading compliance program.
 Provide Employee with access to legal and other resources necessary to
comply with the Regulations.
 Investigate any reported or suspected violations of the Regulations and take
appropriate disciplinary action.
 4

4) CONFIDENTIALITY:
Employee shall keep all MNPI confidential and shall not disclose it to any person
except as authorized by the Regulations or by the Company.
5) TERM AND TERMINATION:
 This Agreement shall remain in effect for as long as Employee remains employed
by the Company.
 This Agreement may be terminated by either party upon written notice to the
other party.
 The obligations of confidentiality and non-disclosure shall survive the
termination of this Agreement.
6) PROCESS FOR SHARING UNPUBLISHED PRICE SENSITIVE INFORMATION
(UPSI)
The insider shall conduct the following steps while sharing UPSI:
 Satisfy that information is UPSI and sharing is for legitimate purpose;
 Identify the persons with whom the information is to be shared;
 Notify the recipient that UPSI is being shared and enter into a confidentiality/non-
disclosure agreement;
 Mode of sharing UPSI shall be either by an email (address directly to the insider
without copying) or hard copy or any other electronic mode or device or provide
access to the information, data, server with acknowledgement.
 Maintain names of the persons along with PAN (or any other identifier where
PAN is not available) with whom information is shared. The database shall be
maintained with adequate internal controls and checks such as time stamping and
audit trails to ensure non-tampering of the database. This database shall be kept
confidential.
7) PENALTIES FOR VIOLATION :
The Employee understands that violations of this Agreement may result in disciplinary
actions, including termination and legal consequences.
8) GOVERNING LAW AND JURISDICTION:
This Agreement shall be governed by the laws of Telangana Jurisdiction. Any
controversies will be subject to the exclusive governance of the courts in Telangana
Jurisdiction.
9) ENTIRE AGREEMENT:
 5

This Agreement constitutes the entire agreement and understanding between the
parties with respect to the subject matter hereof and supersedes all prior or
contemporaneous communications, representations, or agreements, whether oral or
written.

IN WITNESS WHEREOF, the parties have executed this Insider Trading Disclosure
Agreement as of the date first written above.

SIGNATURE OF PARTIES:-
Itish Trading Ltd.
Name: Itish Trading
Date: 06.12.2023

Employee
Name: K. Varma
Date: 06.12.2023