Keynote Financial Services Updates Code of Conduct for Prohibition of Insider Trading

Keynote Financial Services Updates Code of Conduct for Prohibition of Insider Trading​

Keynote Financial Services Limited has formalized updates to its Code of Practices for Prohibition of Insider Trading. The Board of Directors reviewed and updated the code during a meeting held on August 13, 2026.

The revised policy outlines robust standards for regulating, monitoring, and reporting trading by Designated Persons and their Immediate Relatives in adherence with relevant regulations.

Key Provisions of the Code​

The company's Code of Conduct specifies definitions and procedures covering insider trading practices. A "Designated Person" includes Promoters, Directors, Key Managerial Personnel (KMP), and all employees of the Company and its subsidiaries who are not administrative or support staff without access to Unpublished Price Sensitive Information (UPSI).

The definition of a 'Connected Person' encompasses various relationships including directors, KMP, officers, certain types of financial arrangements, and affiliated entities. A "Contra trade" is defined as trading in an opposite transaction involving buying or selling securities within six months following the prior transaction.

Trading Windows and Pre-clearance Procedures​

The policy mandates a specific framework for trading activity:

• Trading Window: The Compliance Officer notifies a 'trading window' during which Designated Persons may trade after securing pre-clearance.
• Blackout Periods: The trading window is generally closed for all Designated Persons at the end of every quarter until 48 hours after the disclosure of financial results. Blackout periods are also declared when the Compliance Officer determines that a Designated Person could reasonably be expected to possess UPSI.
• Pre-clearance Requirement: All Designated Persons intending to trade securities, including buying, selling, gifting, or pledging, must pre-clear the transaction if the aggregated value exceeds Rs. 10,00,000/- (Rupees Ten Lakh Only).

Insider Trading Restrictions and Penalties​

The code strictly prohibits insiders from:

• Communicating or allowing access to any UPSI in relation to the Company or its Securities, except where permitted by the Code or other regulations.
• Trading in company securities unless the trading window is open and they are not in possession of UPSI.
• Providing advice or tips regarding the Company's securities while in possession of UPSI.

Designated Persons are also prohibited from taking positions in derivative transactions involving the Company's securities at any time. Furthermore, a restriction against entering into a Contra Trade applies for six months following any prior transaction.

Reporting and Compliance Mechanisms​

The Code requires designated persons to adhere to strict disclosure mandates:

• Initial Disclosure: Upon appointment as KMP, Director, or upon becoming a Promoter, individuals must disclose their and their Immediate Relatives' holding of Securities as on the date of such appointment within seven days via a specific form.
• Continual Disclosure: Designated Persons and members of the promoter group must disclose the number of securities acquired or disposed of within two trading days if the traded value exceeds INR 10,00,000 (ten lakh rupees).

In the event of a violation of the Code by an Insider, penalties include disciplinary action by the Company (which may involve wage freeze, suspension, or termination) and mandatory reporting to regulatory authorities.

KEYFINSERV Stock Price Movement​

Keynote Financial Services Limited shares rallied today, settling at ₹265.65 after gaining 1.22% in trading. The stock traded within an intraday range, hitting a low of ₹258.15 and peaking at ₹267.70.