Key Takeaways
- • Gaja Alternative Asset Management filed an updated Code of Conduct with NSE and BSE on August 26, 2026, establishing compliance frameworks under SEBI's Prohibition of Insider Trading Regulations 2015.
- • The code mandates pre-clearance for trades exceeding ₹10 lakh in value per quarter by all designated persons, including promoters, directors, key managerial personnel, and senior management up to two levels below the managing director.
- • Trading windows are restricted during quarter-end periods, closing completely from quarter-end until 48 hours after financial results are declared, enforcing blackout periods for unpublished price-sensitive information (UPSI).
- • The policy extends to immediate relatives of designated persons who are financially dependent or consult with designated persons regarding securities trading decisions, broadening the regulatory scope beyond officers alone.
- • The Board-approved code operationalizes Schedule B of the SEBI PIT Regulations, establishing structural controls to ensure fair disclosure norms and prevent insider trading violations across the asset management firm.
Summary
Gaja Alternative Asset Management Limited notified both the National Stock Exchange (NSE) and BSE Limited on August 26, 2026, of its updated Code of Conduct governing trading activities by designated persons. The filing, submitted under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations 2015, demonstrates the firm's commitment to regulatory compliance and fair disclosure standards for unpublished price-sensitive information.
The Board of Directors approved the updated code to ensure full adherence to Schedule B of the SEBI PIT Regulations, establishing a comprehensive framework applicable to all designated persons within the organization. This category includes promoters, directors, key managerial personnel, and senior management positioned up to two levels below the managing director. Notably, the code also binds immediate relatives of these designated persons if they are financially dependent on or regularly consult with the designated person regarding securities trading decisions, expanding the regulatory perimeter beyond corporate officers.
The updated code introduces several critical operational controls centered on trading window restrictions and pre-clearance requirements. Designated persons may execute trades only during open trading windows; these windows close entirely from the end of each quarter until 48 hours following the formal declaration of financial results. This blackout period mechanism is designed to prevent trading on unpublished price-sensitive information. Additionally, any trade exceeding ₹10 lakh in value per quarter requires mandatory pre-clearance from the compliance officer, establishing a gatekeeping function for significant transactions.
The filing underscores Gaja's proactive stance on insider trading prevention at a time when SEBI continues to emphasize robust compliance with its PIT Regulations across the asset management industry. The structural controls embedded in the code—including trading window restrictions, pre-clearance thresholds, and extended applicability to connected family members—reflect regulatory best practices highlighted in recent NSE circulars and SEBI enforcement guidance.
The Board of Directors approved the updated code to ensure full adherence to Schedule B of the SEBI PIT Regulations, establishing a comprehensive framework applicable to all designated persons within the organization. This category includes promoters, directors, key managerial personnel, and senior management positioned up to two levels below the managing director. Notably, the code also binds immediate relatives of these designated persons if they are financially dependent on or regularly consult with the designated person regarding securities trading decisions, expanding the regulatory perimeter beyond corporate officers.
The updated code introduces several critical operational controls centered on trading window restrictions and pre-clearance requirements. Designated persons may execute trades only during open trading windows; these windows close entirely from the end of each quarter until 48 hours following the formal declaration of financial results. This blackout period mechanism is designed to prevent trading on unpublished price-sensitive information. Additionally, any trade exceeding ₹10 lakh in value per quarter requires mandatory pre-clearance from the compliance officer, establishing a gatekeeping function for significant transactions.
The filing underscores Gaja's proactive stance on insider trading prevention at a time when SEBI continues to emphasize robust compliance with its PIT Regulations across the asset management industry. The structural controls embedded in the code—including trading window restrictions, pre-clearance thresholds, and extended applicability to connected family members—reflect regulatory best practices highlighted in recent NSE circulars and SEBI enforcement guidance.
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