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ANNU PROJECTS LIMITED Corporate Identification No.: U45201DL2003PLC120995 (Formerly Known as " Annu Projects Private Limited") Date: September 02, 2026 Sr. General Manager Sr. General Manager Listing Department Listing Department BSE Limited National Stock Exchange of India Limited Phiroze Jeejeebhoy Towers Dalal Street, Exchange Plaza, C-1, Block G Mumbai - 400001. Bandra -Kurla Complex, Bandra (East), Mumbai- 400051. Scrip Code: 544893 Scrip Symbol: ANNU ISIN: INE103001017 ISIN: INE103001017 Subject: Intimation under Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Dear Sir/Madam, Pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (‘SEBI PIT Regulations’), please find enclosed herewith the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information framed under Regulation 8(1) of SEBI PIT Regulations. This is for your information and record. Thanking You, For ANNU PROJECTS LIMITED Sanjay Kumar Sarraf Chairman & Managing Director DIN: 01174144 Encl.: as Above Regd. O(cid:431)ice: Tel.: 46063652, 46063658, 40114237, 40114238 Plot No.11, 1st Floor, LSC, Sector-B-1, Website: www.annuprojects.com Vasant Kunj, New Delhi-110070 E-mail: info@annuprojects.com / aicipl@gmail.com CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UPSI [Pursuant to Regulation 8 of SEBI (Prohibition of Insider Trading) Regulations, 2015] ANNU PROJECTS LIMITED CIN: U45201DL2003PLC120995 Registered Office: Annu Projects Limited Plot no 11, First Floor, Sector B, Pocket 1- LSC, Vasant Kunj, Opposite: Delhi Jal Board New Delhi – 110070 CHAPTER I PRELIMINARY 1. Introduction Regulation 8(1) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“SEBI PIT Regulations”) mandates a listed entity to formulate and publish on its website, a code of practices and procedures for fair disclosure of unpublished price sensitive information. In light of the aforesaid, this Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information is framed as per Model Code prescribed under Schedule A of the SEBI PIT Regulations and was adopted by the Board in its meeting held on May 22nd, 2025. 2. Definitions: a) “Act” means the Securities and Exchange Board of India Act, 1992 (15 of 1992) and the rules and regulations formed, circulars and guidelines issued thereunder; b) “Board” or “Board of Directors” means the board of directors of Annu Projects Limited. c) “Company” means Annu Projects Limited. d) “Compliance Officer” means any senior officer, designated so and reporting to the Board of Directors or head of the organization in case Board is not there, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under the regulations and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the preservation of unpublished price sensitive information, monitoring of trades and the implementation of the codes specified in the regulations under the overall supervision of the Board of Directors of the Company or the head of an organization, as the case may be; The term “financially literate” shall mean a person who has the ability to read and understand basic financial statements i.e. balance sheet, profit and loss account, and statement of cash flows. e) “Connected Person” means any person who is or has during the six months prior to the concerned act, been associated with a company, directly or indirectly, in any capacity including by reason of frequent communication with its officers or by being in any contractual, fiduciary or employment relationship or by being a director, officer or an employee of the company or holds any position including a professional or business relationship between himself and the company whether temporary or permanent, that allows such person, directly or indirectly, access to unpublished price sensitive information or is reasonably expected to allow such access. f) “Deemed to be a Connected Person”: means the persons falling within the following categories shall be deemed to be connected persons unless the contrary is established: i. An immediate relative of Connected Persons specified in clause (2.e); or ii. A holding company or associate company or subsidiary company; or iii. An intermediary as specified in Section 12 of the Act or an employee or director thereof; or iv. An investment company, trustee company, asset management company or an employee or director thereof; or v. An official of a stock exchange or of clearing house or corporation; or vi. A member of board of trustees of a mutual fund or a member of the board of directors of the asset management company of a mutual fund or is an employee thereof; or vii. A member of the Board of Directors or an employee, of a public financial institution as defined in section 2 (72) of the Companies Act, 2013, as amended (“Companies Act”) or viii. An official and/or employee of a self-regulatory organization recognized or authorized by the Board; ix. A banker of the Company; or x. A concern, firm, trust, Hindu undivided family, company or association of persons wherein a director of the Company or his immediate relative or banker of the Company, has more than ten per cent, of the holding or interest. g) “Designated Persons” will mean and include: i. All the Directors of the Company; ii. Promoters and members of Promoter Group; iii. All employees of the Company coming under the Grade 1, 2 and 3 (as per the policy of the Company) and its material subsidiaries on the basis of their functional role or access to Unpublished Price Sensitive Information; iv. Key Managerial Personnel (as defined in accordance with the Companies Act, 2013 and applicable accounting standards) of the Company; v. All employees of the ‘Finance’, ‘Accounts’, ‘Audit’, ‘Taxation’, ‘Legal and Secretarial’, ‘Corporate Communication’ functions of Corporate Finance, Information Technology, irrespective of their grade; vi. employees of such other functions of the Company who are in possession or likely to be in possession of Unpublished Price Sensitive Information; vii. Chief executive officer and employees up to 2 (two) levels below the Chief executive officer, including the head of Accounts and Finance (by whatever name called) of the Company and material subsidiaries of the Company; viii. Personal assistants, if any, of persons referred in (i) and from (iii) to (vii) above; ix. Any support staff of the Company such as IT staff or secretarial staff who have access to Unpublished Price Sensitive Information; x. Any other employees as may be designated/ notified by the Compliance Officer in consultation with the Board of Directors from time to time, who may be considered to be in possession of Unpublished Price Sensitive Information; xi. Immediate Relatives of persons specified in (i) to (viii) above. h) “Promoter group” shall have the meaning assigned to it under the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 or any modification thereof i) “Insider” means any person who is: (i) A connected person; or (ii) In possession of or having access to Unpublished Price Sensitive Information; or (iii) Any person who is in receipt of Unpublished Price Sensitive Information pursuant to a Legitimate Purpose; j) “Legitimate Purpose” shall include sharing of unpublished price sensitive information in the ordinary course of business by an Insider with partner(s), collaborator(s), lender(s), customer(s), supplier(s), merchant banker(s), legal adviser(s), auditors, insolvency professional(s) or other advisor(s), or consultant(s), provided that such sharing has not been carried out to evade or circumvent the prohibitions of the Regulations; k) “Regulations”/ “SEBI PIT Regulations” means [Showing first 8,000 characters — download PDF for full document]