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Whether trading on the basis of UPSI is prohibited even for persons not falling under the definition of ‘Designated Persons’ under the PIT Regulations?

 Regulation 2(1) (g) of SEBI (PIT) Regulations, 2015 defines ‘insider’ as any person who is:
i) a connected person; or

ii) in possession of or having access to unpublished price sensitive information.

Therefore, even if a person is not classified as a designated person, having access to UPSI
would make such a person an ‘insider’. As per Regulation 4(1) of SEBI (PIT) Regulations,
2015, an insider is prohibited to trade while in possession of UPSI.

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