CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION

(Pursuant to Regulation 8(1) of SEBI (Prohibition of Insider Trading) Regulations, 2015)
The Company shall adhere to the following principles of fair disclosure for purpose of code of practices and procedures for fair disclosure of unpublished price sensitive information.

  1. The Company shall ensure prompt public disclosure of unpublished price sensitive information that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally
  1. The Company shall ensure uniform and universal dissemination of unpublished price sensitive unpublished price sensitive information to avoid selective
  1. The Company Secretary / Compliance Officer of the Company shall act as a chief investor relations officer to deal with dissemination of information and disclosure of unpublished price sensitive
  1. The Company shall make prompt dissemination of unpublished price sensitive information that gets disclosed selectively, inadvertently or otherwise to make such information generally
  1. The Company shall provide appropriate and fair response to queries on news reports and request s for verification of market rumours by regulatory
  1. The Company shall ensure that information shared with analysts and research personnel is not unpublished price sensitive
  1. The Company shall develop best practices to make transcripts or records of proceedings of meetings with analysts and other investor relations conferences on the official website to ensure official confirmation and documentation of disclosures
  1. The Company shall handle of all unpublished price sensitive information on a need-to-know.

CODE OF CONDUCT AND ETHICS FOR THE BOARD OF DIRECTORS  & SENIOR MANAGEMENT

Objective

Gold Rock Investments Limited is committed to protecting and enhancing stakeholder’s value, meeting its contractual obligations and conducting its affairs ethically and lawfully.  In keeping with the core values of the organization and in compliance with the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and the Companies Act, 2013 the Board of Directors of the Company has adopted this code of Conduct (Code) that are intended to guide Directors and Senior Management of the Company in the performance of their duties and responsibilities and ensure compliance with the Company’s commitment to follow ethical and lawful code of conduct.

The Code of Conduct for Directors and Senior Management of Gold Rock Investments Limited

Applicability:

This code is applicable to all Directors of the Company and personnel of the senior management team of the Company. However, in the case of any person serving on the Board of the Company as a nominee of any institution or organization, this code shall apply to such person during his tenure as a Director of the Company, subject to any thing contained herein which is repugnant to the Code of conduct or the Service Rules of that institution or organization which has appointed such person as its nominee on the Board.

Definitions:

 In this Code, unless the context otherwise requires define the term as follows:- “Company” means Gold Rock Investments Limited “Code” means this Code of Conduct “Directors” mean a member of the Board of Directors of the Company including nominees of any institution or body corporate.

CODE OF CONDUCT FOR PREVENTION OF INSIDER TRADING AND CODE OF CORPORATE DISCLOSURE PRACTICES

[Pursuant to Regulation 12 (1) & (2) of the SEBI (Prohibition of Insider Trading) Regulations, 1992 as amended]

 CODE OF CONDUCT FOR PREVENTION OF INSIDER TRADING

 Background:

“Insider Trading’ in general means an act of dealing in the securities of a Company based on some unpublished price sensitive information to which a person may be privy to. The Securities and Exchange Board of India (SEBI), has issued the SEBI (Prohibition of Insider Trading) Regulation, 1992 (“the Regulations”) by which Insider Trading has been prohibited in India.

The Regulations require the Listed Companies to set up an appropriate mechanism and to frame and enforce a policy of internal procedures and conduct so as to curb Insider Trading.

In compliance with the above requirements, Gold Rock Investments Limited framed an Insider Trading Policy and with a view to simplify the understanding and implementation of the Policy, the Company replaced the Insider Trading Policy with the revised Insider Trading Policy (hereinafter referred to as “Policy”) w. e. f. 28th January, 2006.

Objective

The Company endeavors to preserve the confidentiality of all un-published price sensitive information(s) and to prevent misuse of such information(s). The Company is committed to transparency and fairness in dealing with all stakeholders and in ensuring adherence to all laws and regulations.

Every “Insider”, as defined in the SEBI Insider Trading Regulations, has a duty to safeguard the confidentiality of all such information(s) obtained in the course of his/her work at the Company or by virtue of his/her relationship with the Company. No Insider shall use his/her position to gain personal benefit or to provide benefit to any third party. Such persons are prohibited from communicating and/or counseling