On October 10, 2019, the Securities and Exchange Board of India (“SEBI”) issued a circular setting out an amended framework for the issuance of Depository Receipts (“DRs”) by Indian companies (the “DR Circular”).
Month: October 2019
Conflicts of Interest of Investor Nominee Directors
Investors or other stakeholders routinely participate in the governance of an investee entity through nominees, often appointing a nominee as a director to safeguard its interests through the exercise of a veto or an affirmative vote (that is the right to approve or reject an act or resolution concerning the business and governance of the investee company).
Closing Trading Windows: To Trade or not to Trade
The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (Insider Trading Regulations) require listed companies to use a trading window for monitoring trades by designated persons and their immediate relatives. The compliance officer is responsible for closing the trading window under certain circumstances when designated persons are reasonably expected to be in possession of unpublished price sensitive information.