SOYASUP: Closed Period Gets Violated by an Insider

September 29, 2026 (MLN): SOYASUP's second-largest shareholder, Mr. Danish Elahi sold 5 million shares in nine days; one tranche landing squarely inside a company-declared Closed Period. Interestingly, under Section 130 of the Securities Act, 2015, Mr. Elahi  is an “Insider” on two counts: by relation, and by possession.

On September 22, Mr. Elahi sold 2.5 million shares via PSX's Negotiated Deal Market at PKR 36.75. Two days later, on September 24, he sold another 2.5 million shares, via the same channel, and at the same price.  However, on September 23, the Company declared a Closed Period extending up to September 30, for a Board Meeting to be held for consideration of Annual Accounts.

This was not the first sale. Twelve days earlier, it was reported that Mr. Elahi had bought shares at the IPO price on September 9 and sold a chunk of that position six days after listing, at an 11% gain, through the same negotiated deals market channel. That story centered on a labeling gap. Danish Elahi is not classified as a "sponsor" under PSX rules, so the lock-in that restricts sponsors from rapid post-listing selling never applied to him. The latest filings show that gap being used again, and this time, the law in play is considerably heavier than a PSX regulation.

Total sold since listing: 5,173,378 shares (~PKR 190mn) across three trades, all at the identical PKR 36.75.

What the law actually says

Section 130 of the Securities Act, 2015 (full text) defines who counts as an insider, and Mr. Elahi meets that definition on two separate, and independent, grounds.

First, and most directly: Sub-Clause (e) states that " any person holding a share, directly or indirectly, which enables him to appoint director on the board, or ten per cent or more shares of an issuer of listed securities" is an insider. Mr. Elahi holds roughly 19–20% of SOYASUP in his own name, nearly double the regulatory threshold. This alone makes him a statutory insider, regardless of any other relationship to the company.

Secondly, Sub-Clause (a) names " any sponsor, executive officer or director of an issuer of listed securities" as an insider, and Sub-Clause (i) extends that status to the "spouse... of a person referred to in clauses (a) to (h)." Mrs. Safinah Danish is a Non-Executive Director of the Company and spouse of Mr. Danish Elahi. That makes Mr. Elahi an insider on the second count.

Two separate and independent provisions of the same law point to the same conclusion: by statute, not by inference, Mr. Danish Elahi is an insider.

Insider trading itself is defined broadly under the Act: any deal, directly or indirectly, involving listed securities, executed by an insider on the basis of information not yet made public. The penalties are not administrative. For an individual, the Act prescribes imprisonment of up to three years, or a fine of up to PKR 200 million, or three times the gain made or loss avoided, whichever amount is higher. For a company, the fine rises to PKR 300 million, or three times the gain or loss, whichever is higher.

What this piece is, and is not, saying

To be precise, insider trading requires proof that a trade was made on the basis of undisclosed, price-sensitive information, and nothing in the public filings proves what Danish Elahi knew about SOYASUP's unreleased financials at the moment he sold. That determination belongs to SECP, with access to records this newsroom does not have.

What the public record does show, and without ambiguity, is that a person who qualified under the Securities Act as an insider, on two separate counts, transacted in a listed Company’s shares during the Closed Period announced to consider Annual Accounts. The timing is not simply a regulatory technicality; it is precisely the scenario Section 130 was envisioned to deter.

This is now squarely SECP's question to answer

Twelve days ago, this was a story about sponsors versus substantial shareholders, and a lock-in period that did not apply. Today, it is not simply about a labeling loophole. It is a 19% shareholder, and a director's spouse, trading two and a half million shares within a Closed Period announced at the exchange for consideration of annual accounts by the Board of Directors.

SECP has both the power and the obligation, under Section 159(1) of the Act, to investigate this  noncompliance and settle the matter under Section 159 of the Securities Act. The Pakistan Stock Exchange also has an obligation to prosecute the matter for better governance and investor confidence.

SECP as a regulator, and PSX as a frontline supervisor, cannot afford to leave such regulatory noncompliances unexamined.

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