SEBI/HO/ISD/ISD -PoD -2/P/CIR/2025/55 — THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992

CIRCULAR SEBI/HO/ISD/ISD -PoD -2/P/CIR/2025/55 To All Recognized Stock Exchanges All Depositories All Listed Companies Dear Sir/Madam, Sub: Trading Window closure period under Clause 4 of Schedule B read with Regulation 9 of Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 ( " PIT Regulations") – Extension of automated implementation of trading window closure to Immediate Relatives of Designated Persons, on account of declaration of financial results . Clause 4 (1) of Schedule B read with Regulation 9 of PIT Regulations, interalia, states that "Designated persons may execute trades subject to compliance with these regulations. Towards this end, a notional trading window shall be used as an instrument of monitoring the trading by the designated persons. The trading window 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 UPSI. Such closure shall be imposed in relation to such securities to which such UPSI relates. Designated persons and their immediate relatives shall not trade in securities when the trading window is closed". One of the instances of closure of trading window is provided in clause 4 (2) of Schedule B read with regulation 9 of PIT Regulations, which inter alia states that "trading restriction period shall be made applicable from the end of every quarter till 48 hours after the declaration of financial results…...". . April 21, 2025 In order to ease the compliance with Clause 4 of Schedule B read with Regulation 9 of PIT Regulations and to prevent inadvertent non-compliances of provisions of PIT Regulations by designated persons ("DPs " ) , clause 3.4.2 of the Master Circular on Surveillance of Securities Ma