SOYASUP’s second‑largest shareholder, Danish Elahi, sold five million shares over a nine‑day period, with one transaction falling inside a company‑declared closed period. Under Section 130 of the Securities Act, 2015, Elahi is considered an insider on two independent grounds: he holds roughly 19–20 % of the company, and he is the spouse of a non‑executive director.
On 22 September, Elahi sold 2.5 million shares on the Pakistan Stock Exchange’s Negotiated Deal Market at PKR 36.75. Two days later, on 24 September, he sold another 2.5 million shares at the same price. The company had declared a closed period from 23 September to 30 September for a board meeting to consider annual accounts.
The sales follow an earlier transaction on 15 September, when Elahi sold 173,378 shares at the same price, shortly after acquiring them at the IPO price of PKR 33. That earlier sale exploited a labeling gap, as Elahi is not classified as a sponsor under PSX rules and thus was not subject to the sponsor lock‑in.
Section 130 of the Securities Act defines an insider as any person holding ten percent or more of an issuer’s listed securities, or any sponsor, executive officer, director, or their spouse. Elahi meets both criteria, making him a statutory insider.
Insider trading, defined as dealing in listed securities based on non‑public price‑sensitive information, carries severe penalties: up to three years’ imprisonment, a fine of up to PKR 200 million, or three times the gain or loss avoided, whichever is higher.
While the public record does not prove that Elahi traded on undisclosed information, the fact that an insider transacted during a closed period announced for annual accounts falls squarely within the scenario Section 130 was designed to deter.
The Securities and Exchange Commission of Pakistan (SECP) and the Pakistan Stock Exchange (PSX) are expected to investigate the non‑compliance and take appropriate action to uphold market integrity.

