On March 24, 2025, the Board of Securities and Exchange Board of India (SEBI) decided to constitute a High Level Committee (HLC) to undertake a comprehensive review of the provisions relating to conflict of interest, disclosures pertaining to property, investments, liabilities, and related matters in respect of Members and Officials of the Board.
The HLC consisted of the following members:
1. Shri Pratyush Sinha, IAS (Retd.), Former Chief Vigilance Commissioner - Chairman of the HLC
2. Shri Injeti Srinivas, IAS (Retd.), Former Secretary, Ministry of Corporate Affairs & Former Chairman, IFSCA - Vice Chairman of the HLC
3. Shri Uday Kotak, Founder & Director, Kotak Mahindra Bank
4. Shri G Mahalingam, Former Executive Director, RBI and Former Whole Time Member, SEBI
5. Shri Sarit Jafa, IA&AS (Retd.), Former Deputy Comptroller and Auditor General
6. Prof. R Narayanaswamy, Former Professor, IIM, Bangalore
The HLC's Terms of Reference were to:
1. Review existing policies and frameworks governing conflict of interest, disclosures, and related matters, and identify any gaps or ambiguities.
2. Recommend a robust framework for preventing, mitigating, and managing conflict of interest including a recusal policy, disclosure requirements covering public disclosures, provisions pertaining to restriction on investments, maintenance of digital records, and a framework for monitoring.
3. Recommend a mechanism for members of the public to raise concerns pertaining to conflict of interest, disclosures including process to examine complaints.
4. Consider any other related matter as appropriate.
The HLC submitted its report to the SEBI Chairman on November 10, 2025, at SEBI Bhavan, Mumbai. For further information, contact the Communications Division, SEBI Bhavan, Bandra Kurla Complex, Bandra (E), Mumbai - 400 051. Tel: +91-22-26449000. Email: press@sebi.gov.in. Website: www.sebi.gov.in. The Press Release number is PR No.71/2025.
Key Entities Referenced
Securities and Exchange Board of India (SEBI): Indian regulatory body for the securities market in India; responsible for overseeing the HLC's work and receiving its report.
High Level Committee (HLC): Committee constituted to review provisions relating to conflict of interest, disclosures, and related matters for members and officials of SEBI.
Ministry of Corporate Affairs: Government ministry where one of the members of the HLC was formerly the Secretary.
PR No.71/2025
High Level Committee on “Conflict of Interest, Disclosures and related matters in
respect of Members and Officials of SEBI” submits its report
The Board at its meeting held on March 24, 2025 had decided to constitute a High Level
Committee (HLC) to undertake a comprehensive review of the provisions relating to conflict
of interest, disclosures pertaining to property, investments, liabilities etc., and related
matters in respect of Members and Officials of the Board.
Accordingly, the HLC was constituted with the following members -
1. Shri Pratyush Sinha, IAS (Retd.), Former Chief Vigilance Commissioner - Chairman
of the HLC
2. Shri Injeti Srinivas, IAS (Retd.), Former Secretary, Ministry of Corporate Affairs &
Former Chairman, IFSCA - Vice Chairman of the HLC
3. Shri Uday Kotak, Founder & Director, Kotak Mahindra Bank
4. Shri G Mahalingam, Former Executive Director, RBI and Former Whole Time
Member, SEBI
5. Shri Sarit Jafa, IA&AS (Retd.), Former Deputy Comptroller and Auditor General
6. Prof. R Narayanaswamy, Former Professor, IIM, Bangalore
The HLC was set up with the following Terms of Reference:
1. Review the existing policies and frameworks governing conflict of interest,
disclosures & related matters and identify any gaps or ambiguities
Page 1 of 22. Recommend a robust framework for preventing, mitigating and managing conflict of
interest including a recusal policy, disclosure requirements covering public
disclosures, provisions pertaining to restriction on investments, maintenance of
digital records and framework for monitoring, etc.
3. Recommend a mechanism for members of the public to raise concerns pertaining
to conflict of interest, disclosures including process to examine complaints
4. Any other related matter as considered appropriate
The HLC submitted its report to the SEBI Chairman on November 10, 2025 at SEBI
Bhavan, Mumbai.
Mumbai
November 10, 2025
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