On March 24, 2025, the Securities and Exchange Board of India (SEBI) Board decided to constitute a High Level Committee (HLC) to comprehensively review provisions relating to conflict of interest, disclosures pertaining to property, investments, liabilities, and related matters for Members and Officials of the Board. The HLC was composed of the following members: Shri Pratyush Sinha (Chairman), Shri Injeti Srinivas (Vice Chairman), Shri Uday Kotak, Shri G Mahalingam, Shri Sarit Jafa, and Prof. R Narayanaswamy.
The HLC's Terms of Reference included: reviewing existing policies and frameworks governing conflict of interest and disclosures; recommending a robust framework for preventing, mitigating, and managing conflict of interest; recommending a mechanism for members of the public to raise concerns related to conflict of interest; and addressing any other related matter.
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. Telephone: +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): The primary regulator for securities markets in India, responsible for overseeing the High Level Committee and receiving its report.
High Level Committee (HLC): Committee constituted by SEBI to undertake a comprehensive review of provisions relating to conflict of interest, disclosures, and related matters in respect of Members and Officials of the Board.
Ministry of Corporate Affairs: Government ministry associated with a member of the HLC.
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
Page 2 of 2