MASTER CIRCULAR
HO/43/15/12(3)2025-ISD-POD2/I/11734/2026 Issued on: March 23, 2023
Last updated on: May 15, 2026
To
1. All Recognized Stock Exchanges
2. All Depositories
3. All Listed Companies
4. Intermediaries registered with Securities and Exchange Board of India
5. Fiduciaries as per Securities and Exchange Board of India (Prohibition of Insider
Trading) Regulations, 2015
Dear Sir/Madam,
Sub: Master Circular on Surveillance of Securities Market
1. For effective surveillance of the securities market, the Securities and Exchange Board of India
(“SEBI” or “the Board”) has been issuing various Circulars from time to time.
2. In order to enable the market stakeholders to have access to all applicable circulars pertaining
to surveillance of securities market at one place, the Master Circular dated September 23,
2024, on the subject, is being further updated to incorporate the provisions of the following
circulars:
a. “Framework of “Financial Disincentives for Surveillance Related Lapses” at Market
Infrastructure Institutions” dated June 06, 2024 with reference number SEBI/HO/ISD/ISD-
PoD-1/P/CIR/2024/73;
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b. “Allowing subscription to the issue of Non-Convertible Securities during trading
window closure period” dated December 30, 2024 with reference number
SEBI/HO/ISD/ISD-PoD-2/P/CIR/2024/180; and
c. “Trading Window closure period under Clause 4 of Schedule B read with Regulation
9 of Securities and Exchange Board of India (Prohibition of Insider Trading)
Regulations, 2015 – Extension of automated implementation of trading window
closure to Immediate Relatives of Designated Persons, on account of declaration of
financial results” dated April 21, 2025 with reference number SEBI/HO/ISD/ISD-PoD-
2/P/CIR/2025/55.
3. With the issuance of this Master Circular, all directions/ instructions contained in the Circulars
listed out in the Appendix to this Master Circular shall stand rescinded to the extent they relate
to Surveillance of Securities Market.
4. Notwithstanding such rescission:
a) anything done or any action taken or purported to have been done or taken under the
rescinded circulars, prior to such rescission, shall be deemed to have been done or
taken under the corresponding provisions of this Master Circular; and
b) any application made to the Board under the rescinded circulars prior to such
rescission, and pending before it, shall be deemed to have been made under the
corresponding provisions of this Master Circular; and
c) the previous operation of the rescinded circulars or anything done or suffered
thereunder, any right, privilege, obligation or liability acquired, accrued or incurred
under the rescinded circulars, any penalty, incurred in respect of any violation
committed against the rescinded circulars, or any investigation, legal proceeding
or remedy in respect of any such right, privilege, obligation, liability, penalty
as aforesaid, shall not be affected by such rescission and shall be enforceable as if
the rescinded circulars have continued to be in force.
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5. This Master Circular is issued in exercise of powers conferred under Section 11 (1) of the
Securities and Exchange Board of India Act, 1992 to protect the interest of investors in
securities and to promote the development of, and to regulate, the securities market.
6. This Master Circular is available on the SEBI website at https://www.sebi.gov.in/ in the path
“LegalMaster Circulars”.
Yours sincerely,
A. Vijayan
Deputy General Manager
Phone: +91-22-26449631
E-mail: vijayan@sebi.gov.in
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TABLE OF CONTENTS
Sl. Subject Page
No. No.
1 Trading Rules and Shareholding in dematerialized mode 7
2 Monitoring of unauthenticated news circulated by SEBI Registered 8
Market Intermediaries through various modes of communication
3 Financial disincentives for surveillance related lapses at Market 10
Infrastructure Institutions
4 Disclosure reporting under the SEBI (Prohibition of Insider Trading)
Regulations, 2015
4.1. Disclosures under Regulation 6 and Regulation 8 (Code of Fair 15
Disclosure) and Regulation 9 (Code of Conduct)
4.2. Reporting to Stock Exchanges regarding violations relating to 16
the Code of Conduct
4.3. Automation of Continual Disclosures under Regulation 7(2) of
17
SEBI (Prohibition of Insider Trading) Regulations, 2015 -
System driven disclosures
5 Trading Window Closure
5.1. Allowing subscription to the issue of Non-Convertible 19
Securities (NCS), Offer for Sale (OFS) and Rights
Entitlements (RE) transactions during trading window closure
period
5.2. Trading Window closure period under Clause 4 of Schedule B
19
read with Regulation 9 of PIT Regulations - Framework for
restricting trading by Designated Persons (“DPs”) and their
Immediate Relatives, by freezing Permanent Account Number
(PAN) at security level
Annexure 1 22
Annexure 2 27
Annexure 3 29
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Sl. Subject Page
No. No.
Annexure 4 31
Annexure 5 35
Annexure 6 36
Appendix- List of circulars rescinded 37
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LIST OF ABBREVIATIONS
Abbreviation Full Form
CIN Corporate Identification Number
CoC Code of Conduct
DD Designated Depository
DIN Director Identification Number
DPs Designated Persons
Securities and Exchange Board of India (Depositories and
DP Regulations
Participants) Regulations, 2018
ESOP Employee Stock Ownership Plan
FDSRL Financial Disincentives for Surveillance Related Lapses
IPEF Investor Protection and Education Fund
ISD Integrated Surveillance Department
ISIN International Securities Identification Number
KMP Key Managerial Personnel
MIIs Market Infrastructure Institutions
MIs Market Intermediaries
MOU Memorandum of Understanding
NCLT National Company Law Tribunal
NCS Non-Convertible Securities
NDUs Non-Disposal Undertakings
OFS Offer for Sale
OI Open Interest
PAN Permanent Account Number
Securities and Exchange Board of India (Prohibition of
PIT Regulations
Insider Trading) Regulations, 2015
RBI Reserve Bank of India
RE Rights Entitlements
SEBI Act Securities and Exchange Board of India Act, 1992
SCRA Securities Contracts (Regulation) Act, 1956
SECC Securities Contracts (Regulation) (Stock Exchanges and
Regulations Clearing Corporations) Regulations, 2018
SEBI Securities and Exchange Board of India
SRL Surveillance Related Lapse
TFT Trade for Trade
UPSI Unpublished Price Sensitive Information
VoIP Voice over Internet Protocol
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1. Trading Rules and shareholding in dematerialized mode1
1.1. In the following cases (except for the original scrips, on which derivatives products are
available or included in indices on which derivatives products are available), the trading
shall take place in Trade for Trade (TFT) segment for first 10 trading days with
applicable price band [***]2:
1.1.1. Merger, demerger, amalgamation, capital reduction/consolidation, scheme of
arrangement, in terms of the Companies Act and/or as sanctioned by the Courts,
in cases of rehabilitation packages approved by the National Company Law
Tribunal (NCLT) under the provisions of Companies Act, 2013 and Insolvency
and Bankruptcy Code, 2016 and in cases of Corporate Debt Restructuring (CDR)
packages by the CDR Cell of the RBI.
1.1.2. Securities that are being admitted to trading from another stock exchange by way
of direct listing/MOU/securities admitted for trading under permitted category.
1.1.3. Where suspension of trading is being revoked after more than one year.
1.2. Further, in all cases, the stock exchange(s) shall ensure that before starting trading in
scrips, the companies have complied with the disclosure requirements and the same is
publicly disseminated on the website of the stock exchange(s) to enable investors to
take informed decision.
1 Circular no. SEBI/Cir/ISD/ 1 /2010 dated September 02, 2010
2 Omitted in line with Circular no. CIR/MRD/DP/02/2012 dated January 20, 2012 which has been consolidated in Chapter
1 of SEBI Master Circular for Stock Exchanges and Clearing Corporations dated December 30, 2024
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2. Monitoring of unauthenticated news circulated by SEBI Registered Market
Intermediaries through various modes of communication3
2.1. It has been observed by SEBI that unauthenticated news related to various scrips are
circulated through social media platforms/ instant messaging services/ VoIP/ blogs/chat
forums/e-mail or any such medium by employees of Broking Houses/other
intermediaries without adequate caution as mandated in the Code of Conduct for Stock
Brokers and respective regulations of various intermediaries registered with SEBI.
2.2. It was also observed that the Intermediaries do not have proper internal controls and
do not ensure that proper checks and balances are in place to govern the conduct of
their employees. Due to lack of proper internal controls and poor training, employees of
such intermediaries are sometimes not aware of the damage which can be caused by
circulation of unauthenticated news or rumours. It is a well-established fact that market
rumours can do considerable damage to the normal functioning and behaviour of the
market and distort the price discovery mechanisms.
2.3. In view of the above facts, SEBI Registered Market Intermediaries are directed that:
2.3.1. Proper internal code of conduct and controls should be put in place.
2.3.2. Employees/temporary staff/voluntary workers etc. employed/working in the
offices of market intermediaries do not encourage or circulate rumours or
unverified information obtained from client, industry, any trade or any other
sources without verification.
2.3.3. Access to social media platforms/ instant messaging services/ VoIP / Blogs/Chat
forums/ websites/e-mail or any such medium should either be subject to
controlled supervision or access should not be allowed.
2.3.4. Logs for any usage of such social media platforms/ instant messaging services/
VoIP / Blogs/Chat forums/websites/e-mail or any such medium shall be treated
3 Circular nos. Cir/ ISD/1/2011 dated March 23, 2011 and Cir/ISD/2/2011 dated March 24, 2011
Page 8 of 38
as records and the same should be maintained as specified by the respective
regulations which govern the concerned intermediary.
2.3.5. Employees should be directed that any market related news received by them
either in their official mail/personal mail/blog or in any other manner, should be
forwarded only after the same has been seen and approved by the Compliance
Officer of the concerned Intermediaries. If an employee fails to do so, he/she
shall be deemed to have violated the various provisions contained in SEBI Act
and the Rules / Regulations framed thereunder, and shall be liable for action. The
Compliance Officer shall also be held liable for breach of duty in this regard.
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3. Financial Disincentives for Surveillance Related Lapses at Market Infrastructure
Institutions4
3.1. Regulation 49 (2) of SECC Regulations empowers SEBI to take action against a
recognised stock exchange or recognised clearing corporation for any contravention of
the SCRA, the SEBI Act, any rules or regulations framed thereunder and any circulars
or directions issued by SEBI. Similarly, Regulation 91A (2) of the DP Regulations
empowers SEBI to take action against a depository for any contravention of the SEBI
Act, the Depositories Act, 1996, any rules or regulations framed thereunder and any
circulars or directions issued by SEBI.
3.2. As per Regulation 28 (2) read with Part–C of Schedule II of the SECC Regulations, the
surveillance function of a Stock Exchange is considered as a core function. Similarly,
Regulation 2 (k) (iii) read with Fourth Schedule of the DP Regulations classifies
surveillance as part of the core functions of the Depository.
3.3. The general objective of surveillance by MIIs is thus to monitor the market to detect and
deter manipulation or abusive trading that affects the integrity of the market, and to
provide information that supports the Regulator’s enforcement actions. In this backdrop,
market surveillance by MIIs may be said to include, but not limited to the following broad
activities as may be applicable from time to time:
3.3.1. Monitoring the day-to-day activities in the markets including trading / margining /
settlement / demat transactions / holdings;
3.3.2. Monitoring the conduct of market intermediaries through generation and
processing of alerts, seeking trading rationale, carrying out snap analysis /
preliminary examination and if required, detailed analysis / examination and
timely submission of Report to SEBI;
3.3.3. Reporting of abnormal / suspicious activities as per the framework that is to be
communicated by SEBI;
4 Circular no. SEBI/HO/ISD/ISD-PoD-1/P/CIR/2024/73 dated June 06, 2024
Page 10 of 38
3.3.4. Promptly implementing the decisions taken in the surveillance meetings; and
3.3.5. Endeavouring to take pre-emptive surveillance measures as per any framework
that may be communicated by SEBI.
3.4. Since any lapse in monitoring to detect and deter manipulative or abusive trading would
show lacking adequate actions for surveillance related activity on the part of MIIs that
may have an adverse effect on the investors’ trust and confidence in the securities
market, it has been decided by SEBI, after consultation with MIIs, for MIIs to implement
a framework for Surveillance Related Lapses at MIIs as stated at para 3.5 below that
shall be applicable to Surveillance Related Lapses emanating from non-adherence to
the requisite surveillance activities / decisions taken in the surveillance meetings, which
does not involve any subjective discretionary deviations or discretionary value
judgments.
3.5. Framework of Financial Disincentives for Surveillance Related Lapses at MIIs:
3.5.1. Surveillance Related Lapses
3.5.1.1. Surveillance Related Lapse (“SRL”), shall mean and include the following:
3.5.1.1.1. any lapse observed in the implementation of decisions taken during
the Surveillance Meetings including any non-implementation or partial
implementation or delayed implementation of any decision or
communication of SEBI relating to surveillance as per agreed scope
and timelines;
3.5.1.1.2. any lapse observed in discharge of surveillance activities as per
agreed scope and timelines; and
3.5.1.1.3. any inadequate reporting or non-reporting of surveillance related
activity as per agreed timelines.
3.5.2. Amount of Financial Disincentives
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3.5.2.1. The amount of financial disincentives as per the framework of financial
disincentives for Surveillance Related Lapses (“FDSRL”) at MIIs, as detailed
below, shall be determined on the basis of total annual revenue of the MII, as
an indicator of the size and impact of the MII on the market ecosystem, during
the previous Financial Year as per the latest audited consolidated annual
financial statement and the number of instances of Surveillance Related
Lapses during the Financial Year.
Financial Disincentive (INR)
Total Annual Revenue >1000cr 1000cr – 300cr < 300cr
(INR) of MII
No. of
Instances of
SRL in FY
FIRST instance 25 Lakhs 5 Lakhs 1 Lakh
SECOND instance 50 Lakhs 10 Lakhs 2 Lakhs
THIRD instance onwards - for each 1 Crore 20 Lakhs 4 Lakhs
instance during the FY.
3.5.3. Procedure upon identification of SRL
3.5.3.1. Upon identification of SRL at MIIs, as indicated in para 3.5.1. above or upon
receipt of information of any such instances, SEBI shall provide an
opportunity to the concerned MII to make its submissions, in respect of the
SRL.
3.5.3.2. The submissions made by the concerned MII shall be considered by SEBI
before imposing any “Financial Disincentive” on the concerned MII as per the
framework.
3.5.3.3. The “Financial Disincentive(s)” under the framework of FDSRL, if imposed,
shall be credited by the MII concerned, within 15 working days, to the Investor
Protection and Education Fund (“SEBI–IPEF”) established under the SEBI
Act and a confirmation of payment in this regard shall be forwarded to SEBI.
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3.5.4. Disclosure
3.5.4.1. MIIs shall disclose on their websites (and in their respective annual reports)
the details pertaining to financial disincentive(s) if any, credited to the SEBI–
IPEF in terms of paragraph 3.5.3.3.. Further, listed MIIs shall make
appropriate disclosures required in terms of the Securities and Exchange
Board of India (Listing Obligations and Disclosure Requirements)
Regulations, 2015, regarding any financial disincentive(s) imposed by SEBI
under this framework.
3.5.5. Applicability
3.5.5.1. The framework of FDSRL at MIIs shall not be applicable to matters /
instances wherein it:
3.5.5.1.1. has market wide impact; or
3.5.5.1.2. caused losses to a large number of investors; or
3.5.5.1.3. affected the integrity of the market; and
any such matter shall be subject to appropriate proceedings under the
SCRA/ SEBI Act/ Depositories Act, 1996.
3.5.5.2. The framework of FDSRL at MIIs shall not be applicable for matters /
instances that are procedural in nature, including the following:
3.5.5.2.1. Minor delays like 1-2 working days in providing information sought by
SEBI; or
3.5.5.2.2. Minor errors in the information provided which is corrected in a short
span of time; or
3.5.5.2.3. Minor errors in the submissions which are corrected on their own, or
3.5.5.2.4. Minor extension sought for submissions; or
3.5.5.2.5. Extension sought due to factors beyond the control of the MII; and any
delay/ error/ lapse that is considered as minor by SEBI may be subject
to administrative proceedings like warnings etc.
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3.6. The framework for FDSRL at MIIs shall be without prejudice to the right of SEBI to
initiate any other action(s) as deemed appropriate under the provisions of the SCRA,
the SEBI Act, the Depositories Act, 1996 and the rules and regulations framed
thereunder.
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4. Disclosure reporting under the SEBI (Prohibition of Insider Trading) Regulations,
2015
4.1. Disclosures under SEBI (Prohibition of Insider Trading) Regulations, 20155
Regulation 6
4.1.1. With reference to the requirements of Regulation 6 of PIT Regulations, the
disclosures may be maintained by the company in physical/electronic mode as
per the prescribed format (Annexure 1)
Regulation 8 & 9
4.1.2. With reference to the requirements of the Regulation 8 (Code of Fair Disclosure)
and Regulation 9 (Code of Conduct) of the Regulations, the companies shall also
ensure that:
4.1.2.1. Code of practices and procedures for fair disclosure of Unpublished Price
Sensitive Information (UPSI), formulated and published (on its official
website), is confirmed to the stock exchanges, immediately.
4.1.2.2. Formulated code of conduct is confirmed to the stock exchanges,
immediately.6
4.1.2.3. A company deals with only such market intermediary / every other
person, who is required to handle UPSI, who have formulated a code of
conduct as per the requirements of PIT Regulations.
5 Circular nos. CIR/ISD/01/2015 dated May 11, 2015, CIR/ISD/02/2015 dated September 16, 2015 and
SEBI/HO/ISD/ISD/CIR/P/2021/19 dated February 09, 2021
6 Added in line with Circular no. CIR/ISD/01/2015 dated May 11, 2015
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4.2. Reporting to Stock Exchanges regarding violations under SEBI (Prohibition of
Insider Trading) Regulations, 2015 relating to the Code of Conduct (CoC) 7
4.2.1. In terms of clause 13 of Schedule B (in case of listed companies) and clause 11
of Schedule C (in case of intermediaries and fiduciaries) read with Regulation 9
of PIT Regulations, the listed companies, intermediaries and fiduciaries shall
promptly inform the stock exchange(s) where the concerned securities are
traded, regarding violations relating to CoC under PIT Regulations in such form
and manner as may be specified by the Board from time to time.
4.2.2. The standard format as specified by SEBI for reporting of violations related to
CoC is placed at Annexure 2. The listed companies, intermediaries and
fiduciaries shall inform the violations of PIT Regulations relating to CoC as per
the format to the stock exchanges(s).
4.2.3. Further, in terms of clause 12 of Schedule B and clause 10 of Schedule C read
with Regulation 9 of the PIT Regulations, any amount collected by the listed
companies, intermediaries and fiduciaries under these clauses for violation(s) of
CoC shall be remitted to the Board for credit to the Investor Protection and
Education Fund (IPEF) administered by the Board under the SEBI Act.
4.2.4. As per Regulation 4(2) of SEBI (IPEF) Regulations, 2009, such amounts shall be
credited to the IPEF through NEFT/RTGS/IMPS or online payment using the
SEBI Payment Gateway or any other mode as may be specified by the
Board from time to time. 8The remittances to SEBI IPEF shall be made through
the link provided in the Homepage of SEBI website (https://www.sebi.gov.in/)
under the head “Click here to make payment to SEBI IPEF”. The link enables the
remitter to make payment in any of the following manner:
- Net banking
- NEFT/RTGS
- Debit Cards
- UPI
7 Circular nos. SEBI/HO/ISD/ISD/CIR/P/2019/82 dated July 19, 2019 and SEBI/HO/ISD/ISD/CIR/P/2020/135 dated July
23, 2020
8 Circular no. SEBI/HO/GSD/TAD/P/CIR/2023/149 dated September 04, 2023
Page 16 of 38
4.3. Automation of Continual Disclosures under Regulation 7(2) of PIT Regulations -
System Driven Disclosures9
4.3.1. SEBI, vide circular no. CIR/CFD/DCR/17/2015 dated December 01, 2015,
CFD/DCR/CIR/2016/139 dated December 21, 2016 and SEBI/HO/CFD/
DCR1/CIR/P/2018/85 dated May 28, 2018, implemented the system driven
disclosures in phases, under SEBI (Substantial Acquisition of Shares and
Takeovers) Regulations, 2011 and PIT Regulations.
4.3.2. The system driven disclosures will be implemented for the promoter(s),
member(s) of promoter group, designated person(s) and director(s) of company
(hereinafter collectively referred to as “entities”) under Regulation 7(2) of PIT
Regulations.
4.3.3. The system driven disclosures shall pertain to trading by the entities in equity
shares, equity derivative instruments i.e. Futures and Options of the listed
company (wherever applicable) and listed debt securities of equity listed
companies.
4.3.4. The procedure for implementation of the system driven disclosures is provided
as Annexure 3.
4.3.5. The depositories and stock exchange(s) shall make necessary arrangements
such that the disclosures pertaining to PIT Regulations are disseminated on the
websites of respective stock exchange(s).
4.3.6. As currently done, the disclosures generated through the system shall be
displayed separately from the regular disclosures filed with the stock
exchange(s).
9 Circular nos. SEBI/HO/ISD/ISD/CIR/P/2020/168 dated September 09, 2020, SEBI/HO/ISD/ISD/CIR/P/2021/578 dated
June 16, 2021 and SEBI/HO/ISD/ISD/CIR/P/2021/617 dated August 13, 2021
Page 17 of 38
4.3.7. For the listed companies who have complied with the aforesaid requirements, the
manual filing of disclosures as required under Regulation 7(2) (a) & (b) of PIT
Regulations is not mandatory.
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5. Trading Window closure
5.1. Allowing subscription to the issue of Non-Convertible Securities (NCS), Offer for
Sale (OFS) and Rights Entitlements (RE) transactions during trading window
closure period 10
5.1.1. Clause 4 (3) (b) of Schedule B read with Regulation 9 of PIT Regulations, inter-
alia, states that trading window restrictions shall not apply in respect of
transactions mentioned therein or transactions undertaken through such other
mechanism as may be specified by the Board from time to time.
5.1.2. In addition to the transactions mentioned in Clause 4 (3) (b) of Schedule B read
with Regulation 9 of PIT Regulations, trading window restrictions shall not apply
in respect of subscription to the issue of Non- Convertible Securities11, Offer for
Sale and Rights Entitlements transactions, carried out in accordance with the
framework specified by the Board from time to time.
5.2. Trading Window closure period under Clause 4 of Schedule B read with
Regulation 9 of PIT Regulations - Framework for restricting trading by
Designated Persons (“DPs”) and their Immediate Relatives, by freezing
Permanent Account Number (PAN) at security level12
5.2.1 Clause 4 (1) of Schedule B read with Regulation 9 of PIT Regulations,
inter-alia, states that “Designated persons may execute trades subject to
compliance with these regulations. Towards this end, a notional trading
window shall be used as an instrument of monitoring the trading by the
designated persons. The trading window shall be closed when the
compliance officer determines that a designated person or class of
designated persons can reasonably be expected to have possession of
10 Circular nos. SEBI/HO/ISD/ISD/CIR/P/2020/133 dated July 23, 2020 and SEBI/HO/ISD/ISD-PoD-2/P/CIR/2024/180 dated
December 30, 2024
11 Circular no. SEBI/HO/ISD/ISD-PoD-2/P/CIR/2024/180 dated December 30, 2024
12 Circular nos. SEBI/HO/ISD/ISD-SEC-4/P/CIR/2022/107 dated August 05, 2022, SEBI/HO/ISD/ISD-PoD-2/P/CIR/2023/124
dated July 19, 2023 and SEBI/HO/ISD/ISD-PoD-2/P/CIR/2025/55 dated April 21, 2025.
Page 19 of 38
UPSI. Such closure shall be imposed in relation to such securities to
which such UPSI relates. Designated persons and their immediate
relatives shall not trade in securities when the trading window is closed”.
5.2.2 One of the instances of closure of trading window is provided in Clause 4
(2) of Schedule B read with Regulation 9 of PIT Regulations, which inter-
alia states that “trading restriction period shall be made applicable from
the end of every quarter till 48 hours after the declaration of financial
results…...”
5.2.3 In order to rationalize the compliance requirement under Clause 4 of
Schedule B read with Regulation 9 of PIT Regulations, improve ease of
doing business and prevent inadvertent non-compliances of provisions of
PIT Regulations by DPs and their immediate relatives, stock exchanges
and depositories shall develop a system to restrict trading by DPs of listed
company and their immediate relatives, during trading window closure
period.
5.2.4 The framework for freezing of PAN of DPs and their immediate relatives,
at security level (‘PAN-ISIN freeze framework’), shall apply to trading
window closure due to declaration of financial results of the listed
companies. Further, the restriction on trading shall be for on-market
transactions, off-market transfers and creation of pledge in equity shares
and equity derivatives contracts (i.e. Futures and Options) of such listed
companies. The procedure for implementation of the system is enclosed
as Annexure 4. The flow chart of the same is enclosed as Annexure 5.
5.2.5 For the companies newly listed on Stock Exchanges, the freezing of PAN
of DPs and their immediate relatives, at security level, will start from 1st
day of the second quarter from the quarter in which the company gets
listed. For example, for a company getting listed during April 01 to June
30, 20XX, PAN of DPs and their immediate relatives should be frozen at
security level as per prescribed framework, latest from October 01, 20XX.
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5.2.6 The Compliance Officer, DPs of listed companies and their immediate
relatives, shall continue to independently comply with the obligations
under PIT Regulations, as applicable to them, till further communication.
5.2.7 The depositories shall submit the quarterly report to SEBI in the format
placed as Annexure 6.
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Annexures
Annexure 1 - Formats for Disclosures under SEBI (Prohibition of Insider Trading) Regulations,
2015
FORM A13
SEBI (Prohibition of Insider Trading) Regulations, 2015 [Regulation 7 (1) (b)
read with Regulation 6(2) – Disclosure on becoming a Key Managerial
Personnel/Director/Promoter/Member of the promoter group]
Name of the company:
ISIN of the company:
Details of Securities held on appointment of Key Managerial Personnel (KMP) or Director or upon becoming
a Promoter or member of the promoter group of a listed company and immediate relatives of such persons
and by other such persons as mentioned in Regulation 6(2).
Name, PAN, Category of Date of Securities held at the time of % of Shareholding
CIN/DIN & Person (KMP / appointment of appointment of KMP/Director or
Address with Director or KMP/Director/ upon becoming Promoter or
contact nos. Promoter or OR Date of member of the promoter group
member of the becoming
promoter group/ Promoter/
Immediate member of the Type of securities No.
relative promoter group (For eg. – Shares,
to/others, etc.) Warrants,
Convertible
Debentures, Rights
entitlements, etc.)
1 2 3 4 5 6
Note: “Securities” shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading)
Regulations, 2015.
Details of Open Interest (OI) in derivatives on the securities of the company held on appointment of KMP or
Director or upon becoming a Promoter or member of the promoter group of a listed company and immediate
relatives of such persons and by other such persons as mentioned in Regulation 6(2).
Open Interest of the Future contracts held at the time Open Interest of the Option Contracts held at the time
of appointment of KMP/Director or upon becoming of appointment of KMP/Director or upon becoming
Promoter/member of the promoter group Promoter/member of the promoter group
Contract Number of units Notional value in Contract Number of units Notional value in
specifications (contracts Rupee terms specifications (contracts Rupee terms
* lot size) * lot size)
7 8 9 10 11 12
Note: In case of Options, notional value shall be calculated based on premium plus strike price of options
Name & Signature:
Designation:
Date:
Place:
13 Erstwhile title of the Form ‘B’ of the Circular SEBI/HO/ISD/CIR/P/2021/19 dated February 09, 2021 has been changed
to Form ‘A’.
Page 22 of 38
FORM B 14
SEBI (Prohibition of Insider Trading) Regulations, 2015
[Regulation 7 (2) read with Regulation 6(2) – Continual Disclosure]
Name of the company:
ISIN of the company:
Details of change in holding of Securities of Promoter, Member of the Promoter Group, Designated Person or Director of a listed company
and immediate relatives of such persons and other such persons as mentioned in Regulation 6(2).
Name, Category of Securities held Securities acquired/Disposed Securities held Date of allotment Date of Mode of Exchange
PAN, Person prior to post acquisition/ advice/ intimation acquisition on which
CIN/DIN, (Promoter/m acquisition/ disposal acquisition of to /disposal the trade
& address ember of the disposal shares/ company (on market/ was
with promoter disposal of shares, public/ executed
contact group/desig specify rights/
nos. nated Type of No. and Type of No. Value Transac Type of No. From To preferential
person/ securiti % of securiti tion securities and % offer/
Director es (For share es (For Type (For e.g. of off market/
s/immediate e.g. holding e.g. (Purcha – Shares, shareh Inter-se
relative – Shares, – se/sale Warrants, olding transfer,
to/others Warrants, Shares, Pledge / Converti ESOPs,
etc.) Convert Warrants, Revocat ble etc.)
ible Convertib ion / Debentur
Debentu le Invocati es,
res, Debentur on/ Rights
Rights es, Others- entitleme
entitlem Rights please nt, etc.)
ents specify)
entitleme
etc.)
nt, etc.)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Note: (i) “Securities” shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015.
(ii) Value of transaction excludes taxes/brokerage/any other charges
14 Erstwhile title of the Form ’C’ of the Circular SEBI/HO/ISD/CIR/P/2021/19 dated February 09, 2021 has been changed to Form ‘B’.
Page 23 of 38
Details of trading in derivatives on the securities of the company by Promoter, member of the promoter group,
designated person or Director of a listed company and immediate relatives of such persons and other such persons as
mentioned in Regulation 6(2).
Trading in derivatives (Specify type of contract, Futures or Options etc.) Exchange on which
the trade was
executed
Type of Contract Buy Sell
contract specifications
Notional Number of Notional Value Number of units
Value units (contracts * lot
(contracts * lot size)
size)
16 17 18 19 20 21 22
Note: In case of Options, notional value shall be calculated based on Premium plus strike price of options.
Name & Signature:
Designation:
Date:
Place:
Page 24 of 38
FORM C (Indicative format)15
SEBI (Prohibition of Insider Trading) Regulations, 2015
Regulation 7(3) – Transactions by Other connected persons as identified by the company
Details of trading in securities by other connected persons as identified by the company
Name, Connect Securities held prior to Securities Securities held post Date of Date of Mode of Exchang
PAN, ion with acquisition/disposal acquired/Disposed acquisition/disposal allotment intimation acquisiti e on
CIN/DIN, company advice/ to on/dispo which the
& address acquisition company sal (on trade was
with of shares/ market/ executed
contact disposal of public/
nos. of shares rights/
other specify Preferent
connecte Type of No. and Type of No. Val Transac Type of No. From To ial offer /
d persons securities % of securitie ue tion securities and % off
as (For e.g. sharehol s (For Type (For e.g. – of market/
identified – Shares, ding e.g. (Purcha Shares, share Inter-
by the Warrants, – se/Sale/ Warrants, holding se
company Convertible Shares, Pledge/ Convertible transfer,
Debentures, Warrants, Revocat Debentures, ESOPs
Rights Convertib ion / Rights etc. )
entitlement, le Invocati entitlement,
etc.) Debentur on/ etc.)
es, Others-
Rights please
entitleme specify)
nt, etc.)
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Note: (i) “Securities” shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015.
(ii) Value of transaction excludes taxes/brokerage/any other charges
15 Erstwhile title of the Form’D’ of the Circular SEBI/HO/ISD/CIR/P/2021/19 dated February 09, 2021 has been changed to Form ‘C’.
Page 25 of 38
Details of trading in derivatives on the securities of the company by other connected persons
as identified by the company
Trading in derivatives (Specify type of contract, Futures or Options etc.) Exchange on
which the
trade was
Type of Contract Buy Sell executed
Contract specifications
Notional Value Number of units Notional Value Number of units
(contracts * lot size)
(contracts * lot
size)
16 17 18 19 20 21 22
Note: In case of Options, notional value shall be calculated based on premium plus strike price of options.
Name:
Signature:
Place:
Page 26 of 38
Annexure 2 - Report by (Name of the listed company/ Intermediary/Fiduciary) for
violations related to Code of Conduct under SEBI (Prohibition of Insider Trading)
Regulations, 2015
[For listed companies: Schedule B read with Regulation 9 (1) of SEBI (Prohibition of
Insider Trading) Regulations, 2015
For Intermediaries/ Fiduciaries: Schedule C read with Regulation 9(1) and 9(2) of SEBI
(Prohibition of Insider Trading) Regulations, 2015]
Sr.
Particulars Details
No.
1 Name of the listed company/ Intermediary/Fiduciary
2 Please tick appropriate checkbox
Reporting in capacity of:
☐ Listed Company
☐ Intermediary
☐ Fiduciary
3 A. Details of Designated Person (DP)
i.Name of the DP
ii.PAN of the DP
iii.Designation of DP
iv.Functional Role of DP
v. Whether DP is Promoter or belongs to Promoter Group
B. If Reporting is for immediate relative of DP
i. Name of the immediate relative of DP
ii. PAN of the immediate relative of DP
C. Details of transaction(s)
i. Name of the scrip
ii. No of shares traded and value (₹) (Date- wise)
D. In case value of trade(s) is more than ₹10 lacs in a calendar quarter
i. Date of intimation of trade(s) by concerned
DP/director/promoter/promoter group to Company
under Regulation 7 of SEBI (PIT) Regulations, 2015
ii. Date of intimation of trade(s) by Company to stock
exchanges under regulation 7 of SEBI (PIT)
Regulations, 2015
4 Details of violations observed under Code of Conduct
5 Action taken by Listed company/ Intermediary/ Fiduciary
6 Reasons recorded in writing for taking action stated above
Page 27 of 38
7 Details of the previous instances of violations, if any, since last
financial year
8 If any amount collected for Code of Conduct violation(s)
i. Mode of transfer to SEBI - IPEF (Net Banking/
NEFT/RTGS/ Debit Cards/ UPI)16
ii. Details of transfer
Particulars Details
Name of the transferor
Bank Name, branch and
Account number
Transaction reference Number
Transaction date
Transaction Amount (in ₹)
9 Any other relevant information
Yours faithfully,
Date and Place Name and Signature of Compliance Officer
PAN:
Email ID:
16 Circular no. SEBI/HO/GSD/TAD/P/CIR/2023/149 dated September 4, 2023
Page 28 of 38
Annexure 3 - Steps/process required to be taken for implementation of System
Driven Disclosures
1. The various formats and timelines for sharing of data shall be standardized, as
agreed upon by the depositories and exchanges.
2. Listed company shall provide the information including PAN number of
Promoter(s) including member(s) of the promoter group, designated person(s)
and director(s) (hereinafter collectively referred to as entities) as per PIT
Regulations to the designated depository (selected in terms of SEBI circular ref.
no. SEBI/HO/CFD/DCR1/CIR/P/2018/85 dated May 28, 2018) in the format and
manner prescribed by the Depositories. For PAN exempt entities, the Investor’s
Demat account number(s) shall be specified by the listed company.
3. The designated depository shall share the information received from the listed
company with other depository.
4. In case of any subsequent update in the details of the entities, the listed
company shall update the information with the designated depository on the
same day. The designated depository shall share the incremental changes with
the other depository on the day of receipt from the listed company.
5. Based on the PAN of First holder/Demat account number(s), the depositories
shall tag such Demat accounts in their depository systems at ISIN level.
6. The designated depository shall also share with the stock exchange(s),
company-wise details of entities. In case of PAN exempt entity, respective
depository shall share the Demat account number(s) details with the stock
exchange(s). Any update (additions or deletions) in this information by listed
company shall be updated by the designated depositories with the stock
exchange(s) on a daily basis. The information shall be shared via system
interface established between the depositories and stock exchange(s).
7. The depositories shall provide the following data pertaining to the tagged
Demat account(s) separately to the stock exchanges on daily basis:
Page 29 of 38
 Details of transactions for pledge/revocation/invocation of shares and
other encumbrances such as Non-Disposal Undertakings (NDUs) etc.
of the entities.
 Details of off market transactions of the entities.
 Details of transmission of shares of the entities.
 Details of corporate actions such as ESOPs, Bonus, Rights, etc. of
the entities
 Additionally, details of market transfers in case of PAN Exempt
entities.
8. Based on the PAN information provided by the depositories, on daily basis, the
stock exchanges will identify the transactions carried out on their trading system
by the entities in the equities and equity derivative instruments (wherever
applicable) of the listed company/permitted to trade on the stock exchange(s),
and listed debt securities of equity listed companies.
9. Such identified trades shall be shared by the stock exchange with all other stock
exchanges where the company is listed, on daily basis.
10. Each stock exchange shall consolidate the information of the transactions
identified by them as well as received from other stock exchanges and the
depositories. On consolidation of the transactions, if the disclosure is triggered
under Regulation 7(2) of PIT Regulations, the stock exchange(s) shall
disseminate the same on their websites. The transaction(s) carried out on T
day shall be disseminated on T+2 day basis.
11. In case of any discrepancy, the issue shall be resolved by listed company, stock
exchanges and depositories in coordination with one another.
Page 30 of 38
Annexure – 4
Trading Window closure period under Clause 4 of Schedule B read with
Regulation 9 of PIT Regulations – Framework for restricting trading by
Designated Persons (“DPs”) and their immediate relatives, by freezing PAN at
security level
Process for implementation of the system:
1. The Designated Depository (“DD”) appointed by the listed company pursuant
to the SEBI Circular No. SEBI/HO/CFD/DCR1/CIR/P/2018/85 dated May 28,
2018 shall enable access to the respective listed company on the portal/
platform.
2. Upon login, DD shall auto-populate PAN and name of the DPs and their
immediate relatives, and their demat account number / DP ID and client ID (only
in case of PAN exempt cases) as per the last updated or available information
under system-driven disclosure uploaded by the listed company with DD in
terms of para 4.3.4. mentioned in this Master Circular. Listed company to
provide details of Immediate Relatives of respective DPs as per format
prescribed by DD.
3. The listed company shall confirm to the DD, details with respect to listed ISIN
of equity share of the company, Name, PAN, and confirm the demat account
number viz. DP ID and client ID (in case of PAN exempted cases) of DPs and
their immediate relatives. In the event any updation is required to the
aforementioned details, the listed company shall take necessary steps as per
para 10 below.
4. DD shall provide a facility to the listed company to specify the ‘Trading Window
Closure Period’ i.e. ‘Commencement Date’ and ‘End Date’ on portal/platform.
4.1. With respect to financial results, the listed company shall specify the
1st day (T- day) immediately after the end of every quarter for which
results are to be announced as ‘Trading Window Closure
Page 31 of 38
commencement date’ and the date on which 48 hours ends post
disclosure of financial results as ‘Trading Window Closure End date’
in the portal/platform.
5. The listed company shall provide the aforesaid details atleast two trading days
prior to the commencement of trading window closure date (T-2 days). For
example, for financial results for the quarter ending September 30, 20XX, the
listed company shall confirm the details by September 29, 20XX.
6. DD shall provide the details received from the listed company (i.e.
commencement date and end date of the trading window closure period, Name
and PAN of DPs and their immediate relatives, ISIN, etc.) to the Stock
Exchanges and other depository atleast one trading day prior to the
commencement of trading window closure commencement date (T-1 day). For
example, for financial results for the quarter ending September 30, 20XX, the
DD shall provide the details by September 30, 20XX. Further, during the trading
window closure period, DD shall also provide the aforesaid details and changes
therein, if any, to the stock exchanges and other depository on a daily basis.
7. The demat accounts shall be identified by the depositories based on the PAN
of the DPs and their immediate relatives, as sole / joint holder.
8. Based on demat accounts identified as per para 7 above and instruction given
by listed company as per paras 3 and 4 above, the off-market transactions and
creation of pledge including all types of encumbrances, shall be restricted by
the depositories with reason code as “Trading Window Closure Period”.
9. On the basis of data received from the depositories, the stock exchanges shall
restrict the on-market transactions of DPs and their immediate relatives in
equity shares and equity derivatives contracts of the listed company from T day
i.e. commencement date of trading window closure period. As per the example
mentioned above, commencement date of trading window closure period shall
be October 01, 20XX, for the quarter ending September 30, 20XX.
Page 32 of 38
10. In case of any addition/deletion/updation pertaining to the details of DPs and
their immediate relatives, the listed company has to follow the procedure
specified in terms para 4.3.4. mentioned in this Master Circular and shall be
required to separately provide the details as mentioned at paras 3 and 4 above.
Such instances shall be effected within two trading days of receipt of intimation
from the listed company. For example, assuming the trading window closure
period is October 01 - 15, 20XX and if the listed company adds any DP and its
immediate relatives on October 10, 20XX, then the change i.e. freeze shall be
effected on or before October 12, 20XX.
11. There shall be provision in the system to specify the details of DPs and their
immediate relatives to be exempted by listed company from Trading Window
restriction in terms of Clause 4 (3) of Schedule B read with Regulation 9 of PIT
Regulations. In such cases, the restriction shall be removed within two trading
days from the date of receipt of request from the listed company. As per the
example given at para 10 above, if the listed company provides exemption to
any DP and its immediate relatives on October 11, 20XX, then the change i.e.
de-freeze shall be effected on or before October 13, 20XX. The restrictions
shall be re-introduced automatically post lapse of the exemption period or
completion of the transaction by the DP and its immediate relatives.
12. The freezing/de-freezing of PAN at the security level on account of changes
due to addition or deletion shall be effected post market hours.
13. Pay-in and pay-out obligations in respect of transactions, if any, taken place
prior to freezing the PAN of DPs and their immediate relatives at the security
level, may be permitted to be settled, squared off or closed out, as the case
may be.
14. The formats and timelines for sharing of data shall be standardized, as agreed
upon by the depositories and the stock exchanges. Further, operational
guidelines for listed companies shall be issued by the depositories.
Page 33 of 38
15. In case of any discrepancy, the issue shall be resolved by the depositories, in
coordination with the stock exchanges and the listed company.
Page 34 of 38
Annexure – 5
Process Flow Chart
Designated Depository to
provide access tolisted
companyon a portal
/platform
Portalwill auto-populate
details of Designated
Persons andtheir
immediate relatives
(PAN and Name)
obtained for the purpose
of system driven
disclosure
Designated depository
Listed company to Listedcompany shall shall provide relevant
update/confirm select or de-select PAN data to stock exchanges FromT day i.e. July 01, 20XX,
a) PAN of DPs andtheir of DPs and their and other depository by depositories and stock exchanges
immediate relativesto immediate relatives at next trading day i.e. T-1 will freeze the PAN of DPsand their
be frozen b) ISIN and least 2 trading days prior day (eg. June 30, 20XX) immediate relatives at ISIN level, till
c) “Start and End date” to trading window and on daily basis for the end of trading window closure
of trading window closure start date i.e. T-2 any updation in DPs period
closure period days and their immediate
relatives during trading
window closure period
Any addition/exemption of/to DPs
and their immediate relatives during
trading window closure period, such
Eg. Financial results for the changes will be effected by 2 trading
quarter ending June 30, days of intimation by the company
20XX, the listed company
has to confirm the details by
June 29, 20XX
Eg. Assuming trading window closure
period is July 01 -15, 20XX. If
company adds/provides exemption to
any DP and their immediate relatives
on July 08, 20XX, the change i.e.
freeze or de-freeze shall be effected by
July 10, 20XX
Page 35 of 38
Annexure 6
Report by Depositories for implementation of framework for restricting trading
by Designated Persons and their immediate relatives by Freezing PAN at
security level.
Sr.No Particulars Count
1 Total number of listed companies which have
appointed Depository (NSDL/CDSL) as designated
depository (DD)
2 Total number of listed companies on which
implementation of framework for restricting trading by
Designated Persons (“DPs”) and their immediate
relatives, by Freezing PAN at security level, is
applicable
3 Total Number of unique and valid PANs of KMPs/DPs
and their immediate relatives provided by issuers/
listed companies, to the DD for Trading Window
Closure restriction, at end of quarter.
4 Total number of demat accounts of DPs and their
immediate relatives, in which PAN-ISIN level freeze
was carried out for the quarter.
5 Total no of exemptions given to DPs and their
immediate relatives from Trading Window restriction
as per PIT Regulations.
Depositories shall be required to separately provide the details as mentioned above in the
quarterly report submitted to SEBI.
Page 36 of 38
APPENDIX: LIST OF CIRCULARS RESCINDED
Sl. Date of Reference No. Subject/ Title Rescission
No. Circular Status
1 02-Sep-10 SEBI/Cir/ISD/1/2010 Trading Rules and Shareholding in Complete
dematerialized mode
2 23-Mar-11 Cir/ISD/1/2011 Unauthenticated news circulated by Complete
SEBI Registered Market Intermediaries
through various modes of communication
3 24-Mar-11 Cir/ISD/2/2011 Addendum to Circular no. Cir/ISD/ Complete
1/2011 dated March 23, 2011
4 11-May-15 Cir/ISD/1/2015 Disclosures under SEBI (PIT) Complete
Regulations, 2015
5 16-Sep-15 Cir/ISD/2/2015 Revised Disclosures formats under SEBI Complete
(PIT) Regulations, 2015
6 19-July- 19 SEBI/HO/ISD/ISD/CIR/P/201 Standardizing reporting of violations Complete
9/82 related to Code of Conduct under SEBI
(PIT) Regulations, 2015
7 23-Jul-20 SEBI/HO/ISD/CIR/P/P/2020/ Allowing Offer for Sale (OFS) and Rights Complete
133 Entitlements (RE) transactions during
trading window closure period
8 23-Jul-20 SEBI/HO/ISD/CIR/P/P/2020/ Reporting to Stock Exchanges regarding Complete
135 violations of SEBI (PIT) Regulations,
2015 relating to Code of Conduct
9 09-Sep-20 SEBI/HO/ISD/CIR/P/P/2020/ Automation of Continual Disclosures Complete
168 under Regulation 7(2) of SEBI
(Prohibition of Insider Trading)
Regulations, 2015 - System driven
disclosures
10 09-Feb-21 SEBI/HO/ISD/CIR/P/P/2021/ Revised disclosure formats under Complete
19 Regulation 7 of SEBI (Prohibition of
Insider Trading) Regulations, 2015
11 01-Mar-21 SEBI/HO/ISD/ISD/CIR/P/202 Master Circular on Surveillance of Complete
1/22 Securities Market.
12 16-Jun-21 SEBI/HO/ISD/ISD/CIR/P/202 Automation of Continual disclosures Complete
1/578 under Regulation 7(2) of SEBI
(Prohibition of Insider Trading)
Regulations, 2015 - System driven
disclosures for inclusion of listed Debt
Securities.
13 13-Aug-21 SEBI/HO/ISD/ISD/CIR/P/202 Automation of Continual Disclosures Complete
1/617 under Regulation 7(2) of SEBI Prohibition
of Insider Trading) Regulations, 2015 -
System driven disclosures - Ease of
doing business.
14 05-Aug-22 SEBI/HO/ISD/ISD-SEC- Trading Window closure period under Complete
4/P/CIR/2022/107 Clause 4 of Schedule B read with
Regulation 9 of SEBI (Prohibition of
Insider Trading) Regulations, 2015 (“PIT
Regulations”) – Framework for restricting
trading by Designated Persons (“DPs”)
by freezing PAN at security level.
15 13-Sep-22 SEBI/HO/ISD/ISD-PoD- Master Circular on Surveillance of Complete
2/P/CIR/2022/118 Securities Market.
16 23-Mar-23 SEBI/HO/ISD/ISD-PoD- Master Circular on Surveillance of Complete
2/P/CIR/2023/039 Securities Market.
Page 37 of 38
Sl. Date of Reference No. Subject/ Title Rescission
No. Circular Status
17 19-July-23 SEBI/HO/ISD/ISD-PoD- Trading Window closure period under Complete
2/P/CIR/2023/124 Clause 4 of Schedule B read with
Regulation 9 of SEBI (Prohibition of
Insider Trading) Regulations, 2015 (“PIT
Regulations”)– Extending framework for
restricting trading by Designated Persons
(“DPs”) by freezing PAN at security level
to all listed companies in a phased
manner.
18 06-Jun-24 SEBI/HO/ISD/ISD-PoD- Framework of “Financial Disincentives Complete
1/P/CIR/2024/73 for Surveillance Related Lapses” at
Market Infrastructure Institutions.
19 09-Jul-24 SEBI/HO/ISD/ISD-PoD- Master Circular on Surveillance of Complete
2/P/CIR/2024/99 Securities Market.
20 23-Sep-24 SEBI/HO/ISD/ISD-PoD- Master Circular on Surveillance of Complete
2/P/CIR/2024/126 Securities Market.
21 30-Dec-24 SEBI/HO/ISD/ISD-PoD- Allowing subscription to the issue of Non- Complete
2/P/CIR/2024/180 Convertible Securities during
trading window closure period.
22 21-Apr-25 SEBI/HO/ISD/ISD-PoD- Trading Window closure period under Complete
2/P/CIR/2025/55 Clause 4 of Schedule B read with
Regulation 9 of Securities and
Exchange Board of India(Prohibition of
Insider Trading) Regulations, 2015
(“PIT Regulations”) –Extension of
automated implementation of trading
window closure to Immediate Relatives
of Designated Persons, on account of
declaration of financial results.
*****************
Page 38 of 38