Introduction:
In adherence to the standards set forth by the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 [‘SEBI LODR’], listed companies are obligated to provide comprehensive disclosures to stock exchange regarding various appointments of senior management and key managerial personnel.
While we are aware that Schedule III Part A, Para A point 7 of SEBI LODR mandates listed entities to disclose change in senior management, director and key managerial personnel along with minimum data that is required to be provided while disclosing events given in Para A of schedule III of LODR regulations, we have come across various instances where certain listed entities have not provided certain data as required by law to be disclosed. On perusal of disclosures pertaining to appointment of senior management and key managerial personnel certain discrepancies have been observed.
Anomalies in disclosures given to stock exchange have been outlined concerning the appointment of key personnel:
CFO Appointment – Disclosure Missing in XBRL format: Disclosure of change in key managerial personnel is required to be disclosed in PDF as well as in XBRL format. In few cases it is observed that companies have failed to disclose to stock exchange CFO
Conclusion:
In conclusion, the observed anomalies and non-compliances in disclosures pertaining to the appointment of key personnel underscore the importance of stringent adherence to SEBI LODR regulations. It is imperative for listed companies to prioritize transparency, accuracy, and completeness in their disclosures to uphold investor confidence and regulatory integrity in the
Indian capital markets. Robust internal processes and diligent oversight to prevent recurrence of such discrepancies is the need of the hour for the listed companies
This article is published in Taxguru. The link to the same is as follows: –
https://taxguru.in/sebi/key-managerial-personnel-directors-senior-management-change-disclosures.html
This article is written by CS Vallabh M Joshi (Senior Manager – RND Team – vallabhjoshi@mmjc.in) & CS Ruchira Pawase (Research Associate – RND Team – ruchirapawase@mmjc.in)
https://www.bseindia.com/markets/MarketInfo/DispNewNoticesCirculars.aspx?page=20230127-37
https://nsearchives.nseindia.com/content/equities/NSE_Circular_20062018.pdf