Diligent Media Corp amends Fair Disclosure Code to tighten UPSI rules

Core Change: DMCL’s Board approved Version 3 of the Fair Disclosure Code for Unpublished Price Sensitive Information (UPSI), adding:

• Updated definitions of UPSI and “legitimate purpose” for sharing it.
• Shorter disclosure timelines and mandatory use of the company website for dissemination.
• A required digital register to log every UPSI recipient.
• Specified penalties and disciplinary steps for breaches.

Effective Date: Not disclosed in the announcement (the code is now approved and ready for implementation).

Impacted Parties:

• Diligent Media Corporation Limited (DMCL) – its board, senior management, and compliance teams.
• Employees and officers who handle or receive UPSI.
• External parties (analysts, investors, consultants) who may be provided UPSI.
• The broader investor community, which benefits from clearer disclosure practices.

Why (as stated): To bring the company into full compliance with SEBI Regulation 8(2) and the SEBI (Prohibition of Insider Trading) (Amendment) Regulations, 2018, thereby reducing regulatory risk and enhancing corporate governance.

Key Compliance / Legal Requirements:

• Follow the tighter disclosure timelines set out in the new code.
• Use the company website as the primary channel for UPSI dissemination.
• Record every UPSI recipient in the mandatory digital register.
• Adhere to the clarified definition of “legitimate purpose” when sharing UPSI.
• Observe the prescribed penalties and disciplinary actions for any violation.