Markets regulator Sebi has said code of conduct under the insider trading norms is applicable on promoters, and not just on persons designated by the board of a company.

The clarifications have been given as part of an informal guidance sought by Apollo Tricoat Tubesas Ltd regarding certain aspects of Prohibition of Insider Trading (PIT) regulations.

"The PIT regulations identify promoters as designated persons. Hence a person identified as a promoter is required to comply with the code of conduct requirements as required by other designated persons," the regulator said in the four-page interpretive letter made public on Tuesday.

Besides, the markets watchdog said that any trade by promoters during closure of trading window would be considered tantamount to violation of provisions under the inisder trading rules.

The PIT rules make it mandatory for every listed public company to lay down a code of conduct for prevention of insider trading in the securities of the firm and these framework need to be be observed by its designated persons.

According to Sebi, the company's board of directors in consultation with the compliance officer specify the designated persons, to be covered by the code of conduct, on the basis of their role and functions in the firm and "the access that such role and function would provide to unpublished price sensitive information in addition to seniority and professional designation" and shall include all the promoters.

Noting that this position is based on the information furnished, Sebi said, "different facts or conditions might lead to a different interpretation".

"This letter does not express a decision of the board on the question referred," the regulator added.