A company announces its annual results, and the results are duly disseminated so that they become GENERALLY AVAILABLE information in the market. Ten days later, a designated person trades in the company's shares in the ordinary course. Under the SEBI (PI

The insider-trading prohibition turns on trading while in possession of UNPUBLISHED price-sensitive information. Once the results are made generally available (information accessible to the public on a non-discriminatory basis) and the company's trading window reopens, an ordinary trade in compliance with the code is NOT an act of insider trading - the UPSI character is removed by publication. Designated persons must still observe the code (pre-clearance, reporting, and the contra-trade restrictions) for their trades. The reason the results-then-trade sequence is lawful is that the information is no longer 'unpublished'. Publication and window-reopening are what legitimise the subsequent trade.