BSECompany Update12 Aug 2026 · 12 Aug 2026, 10:25 pm
Enclosed.
Mach Travel Solutions Ltd · 544248
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Mach Travel Solutions Ltd has amended its Code of Conduct for Prevention of Insider Trading, as per SEBI (PIT) Regulations, 2015, and has adopted the updated code for use by all insiders, including designated persons and their immediate relatives.
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Mach Travel Solutions Ltd - 544248 - Announcement under Regulation 30 (LODR)-Code of Conduct under SEBI (PIT) Regulations, 2015
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Date: August 12, 2026
Corporate Relationship Department,
BSE Limited,
P J Towers, Dalal Street, Fort, Mumbai – 400001
Scrip Code: 544248 Scrip Name: MACHLTD
Subject: Amendment to Code of Conduct for Prevention of Insider Trading
Dear Sir/Madam,
Pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, the Board
of Directors of the Company, at its meeting held on August 12, 2026, approved the amendment to the
Code of Conduct for Prevention of Insider Trading.
A copy of the same is enclosed herewith.
Kindly take the same on record
Your Sincerely,
For Mach Travel Solutions Limited
(Formerly known as Mach Conferences and Events Limited)
Amit Bhatia
Chairman & Managing Director
DIN:00351412
MACH TRAVEL SOLUTIONS LIMITED
(Formerly known as Mach Conferences and Events Limited)
CODE
OF CONDUCT
FOR PREVENTION
OF INSIDER TRADING
This Code was approved by the Board of Directors at its meeting held on June 21, 2024 and modified on August
12, 2026.
1 | Page
CODE OF CONDUCT FOR PREVENTION OF INSIDER TRADING
(Under Regulation 9(1) and (2) of SEBI (Prohibition of Insider Trading Regulations, 2015)
1. INTRODUCTION
1.1 The Securities and Exchange Board of India (“SEBI”), for protection of investors and to regulate the securities
market, had formulated the SEBI (Prohibition of Insider Trading) Regulations, 2015 (“The Regulations”) under
the powers conferred on it under the SEBI Act, 1992.
1.2 Regulation 9 of SEBI (Prohibition of Insider Trading) Regulations, 2015, mandates every Listed Company
to formulate code of conduct to regulate, monitor and report trading by its designated persons and immediate
relatives of designated persons towards achieving compliance with these regulations, adopting the minimum
standards set out in Schedule B to the regulations.
1.3 In line with the amended Insider Trading Regulations, Mach Travel Solutions Limited (Formerly known as
Mach Conferences and Events Limited) (“the Company”) has amended the following Code of Conduct (“the
Code”) & has been adopted by the Board of Directors of the Company for use by all Insiders (as defined below)
of the Company including Designated Persons and Immediate Relatives of Designated Persons as defined in this
policy.
1.4 The Code is based on the principle that Designated Persons of the Company owe a fiduciary duty to, among
others, the shareholders of the Company to place the interest of the shareholders above their own and conduct
their personal securities transactions in a manner that does not create any conflict-of-interest situation.
2. DEFINITIONS
i. “Act” shall mean the Securities and Exchange Board of India Act, 1992 (15 of 1992) and any
amendments thereto.
ii. “Audit Committee” shall mean Committee of the Board of the Company constituted pursuant to Section
177 of the Companies Act, 2013.
iii. “Board” shall mean the board of directors of the Company.
iv. “CEO” shall mean the Chief Executive Officer of the Company.
v. “Company” means “Mach Travel Solutions Limited (Formerly known as Mach Conferences and
Events Limited)” or “MACHLTD”.
vi. “Compliance Officer” means Company Secretary of the company unless any senior officer, designated
so and reporting to the board of directors, who is financially literate and is capable of appreciating
requirements for legal and regulatory compliance under these regulations and who shall be responsible
for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the
preservation of unpublished price sensitive information, monitoring of trades and the implementation of
the codes specified in these regulations under the overall supervision of the Board.
vii. “Connected Person” shall mean:
a) any person who is or has been, during the six months prior to the concerned act, associated with a
company, in any capacity, directly or indirectly, including by reason of frequent communication with its
officers or by being in any contractual, fiduciary or employment relationship or by being a director,
officer or an employee of the company or holds any position including a professional or business
relationship, whether temporary or permanent, with the company, that allows such a person, directly or
indirectly, access to unpublished price sensitive information or is reasonably expected to allow such
access.
b) without prejudice to the generality of the foregoing, the persons falling within the following categories
shall be deemed to be connected persons unless the contrary is established:
• a Relative of Connected Persons specified in clause (a); or
2 | Page
• a holding company or associate company or subsidiary company; or
• an intermediary as Specified in Section 12 of the Act or an employee or director thereof; or
• an investment company, trustee company, asset management company or an employee or director
thereof; or
• an official of a stock exchange or of clearing house or corporation; or
• a member of board of trustees of a mutual fund or a member of the board of directors of the asset
management company of a mutual fund or is an employee thereof; or
• a member of the board of directors or an employee, of a public financial institution as defined in section
2 (72) of the Companies Act, 2013; or
•an official or an employee of a self-regulatory organization recognised or authorized by SEBI; or
• a banker of the company; or
• a concern, firm, trust, Hindu undivided family, company or association of persons wherein a director
of a company or his relative or banker of the company, has more than ten per cent of the holding or
interest; or
• a firm or its partner or its employee in which a connected person specified in sub-clause (a) of clause
(vii) is also a partner; or
• a person sharing household or residence with a connected person specified in sub-clause (a) of clause
(vii);]
viii. “Designated Persons” means:
(i) Promoters of the Company;
(ii) Directors of the Company and its subsidiaries;
(iii) KMP of the company and Executive Secretaries of Directors;
(iv) Secretaries / Executive Assistants/ Personal Assistants of CEO, Managing Director, Whole Time
Director, Chief Financial Officer (CFO), Presidents, Vice Presidents.
(v) Chief Executive Officer and All Employees up to two levels below of Chief Executive Officer of
the Company and its material subsidiaries, if any, irrespective of their functional role in the
Company;
(vi) Immediate Relatives of persons specified in (i) to (v) above.
(vii) Any other Person designated by the Company on the basis of their function and role and the access
that such role and function would provide to unpublished price sensitive information.
ix. “Generally available information” means information that is accessible to the public on a non-
discriminatory basis and shall not include unverified event or information reported in print or electronic
media.
x. “Immediate Relative” means a spouse of a person, and includes parent, sibling, and child of such person
or of the spouse, any of whom is either dependent financially on such person, or consults such person in
taking decisions relating to trading in securities.
xi. “Insider” shall mean any person who is:
a) a Connected Person; or
b) in possession of or having access to Unpublished Price Sensitive Information.
xii. “Material financial relationship” shall mean a relationship in which one person is a recipient of any
kind of payment such as by way of a loan or gift from a Designated Person during the immediately
preceding twelve months, equivalent to at least 25% such Designated Persons of the annual income of
such Designated Person but shall exclude relationships in which the payment is based on arm’s length
transactions.
xiii. “Promoter” shall have the meaning assigned to it under the Securities and Exchange Board of India
(Issue of Capital and Disclosure Requirements) Regulations, 2018 or any modification thereof.
xiv. “Promoter group” shall have the meaning assigned to it under the Securities and Exchange Board of
Ind
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