Articles 30th Nov 2023

A Compliance Officer Doesn’t Need Prying Eyes


Harshvardhan Nankani Senior Associate | Mumbai

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In a recent ruling, the Hon’ble SAT has absolved a company and its compliance officer for wrongful disclosure made to the stock exchanges. The ruling was based on the argument that the misinformation originated from a KMP of the company. In this ruling the Hon’ble SAT has provided valuable guidance as to the duties of a compliance officer and the company, and the extent of due diligence they are required to exercise with respect to disclosures received from a KMP.

The ruling is also significant because it elucidates the position that Unpublished Price Sensitive Information would only come into existence once the information is crystallized with a reasonable degree of certainty, which in the case of financial results is usually when they are finalized and communicated to the management.

Against this backdrop, Abhiraj Arora, Associate Partner & Harshvardhan Nankani, Senior Associate, Economic Laws Practice have co-authored an article “A Compliance Officer Doesn’t Need Prying Eyes” published on Mondaq.

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