New takeover code

Hi,

Promotor  holding of listed Company is –55.18 % .two companies out of this promotor group holding 6.52 % each.Now these 2 companies are buying shares of the companies in which they are in promotor group.

e.g -- If  "abc is company"  and  "x " and  " y " are in promotor group . x and y both are  buying  shares of abc.

My query is :-

as per new takeover code.

1) what  disclosures are required to be made by x and y in individual capacity

2)what disclosures are required to be made by  "promotors group of abc company ".

3) is creeping acqsition applicable here ? what are the % , to AVOID open offer both from promotor group angle and individual angle (specify the maximum % to avoid the open offer )

Regards