Updates

Date: September 17, 2026 To, To National Stock Exchange of India Limited BSE Limited (“BSE”) (“NSE”) Listing Department Listing Department Corporate Relationship Department Exchange Plaza, C-1 Block G, Bandra Kurla Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Complex Bandra [E], Mumbai – 400051 Mumbai - 400 001 NSE Scrip Symbol: LCCPROJECT BSE Scrip Code: 544918 ISIN: INE1FPN01026 ISIN: INE1FPN01026 Sub.: Intimation under Regulation 8 (2) of the Securities Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015. Dear Sir/ Madam Pursuant to Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, please find enclosed herewith the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information framed under Regulation 8(1) of SEBI PIT Regulations which is a part of Insider Trading Code of the Company (“Insider Trading Code”). A copy of the aforesaid code is enclosed herewith. This intimation is also available on the Company’s website at https://lccprojects.com/. You are requested to take the aforesaid information on your record. Thanking You, For LCC Projects Limited Gayatri Desai Company Secretary and Compliance O(cid:431)icer Mem. No. A60858 Encl.: A/a PROHIBITION ON INSIDER TRADING LCC PROJECTS LTD. CIN: U45500GJ2017PLC100301 Registered & Corporate Office: LCC Corporate House, B/S GTPL House, Sindhu Bhavan Road, Bodakdev, Ahmedabad-380054, Gujarat, India Telephone No. +91 79 4848 4453 E-mail: cs@lccprojects.com Website: www.lccprojects.com LCC PROJECTS LIMITED PROHIBITION ON INSIDER TRADING 1. PREAMBLE The Board of Directors of LCC Projects Limited (“the Company”) has adopted this “Prohibition of Insider Trading Policy” (the “Policy”) to comply with the SEBI (Prohibition of Insider Trading) Regulations, 2015 (“SEBI PIT Regulations”) as amended from time to time. This policy shall be applicable to all Insiders (as defined herein) of the Company including Designated Persons and immediate relatives of Designated Persons as defined in this policy. The SEBI Regulations prohibit the communication of UPSI to any person except in compliance with applicable law. Further, procuring any person to Trade in the securities of any company when in possession UPSI is also prohibited under the SEBI Regulations and the securities laws. Violations of the SEBI Regulations and the securities laws subject Insiders to severe penalties including disgorgement proceedings, fines and imprisonment as per the applicable law. The SEBI Regulations provides that every listed company shall frame (a) Code of Conduct, to regulate, monitor and report trading by its designated persons and immediate relatives of designated persons. (b) Code of Practices and Procedures, for fair disclosure of unpublished price sensitive information, towards achieving compliance with the Regulations. 2. DEFINITIONS 2.1 ‘Act’ means the Securities and Exchange Board of India Act, 1992 2.2 ‘Audit Committee’ means Committee of the Board of the Company constituted pursuant to Section 177 of the Companies Act, 2013 read with Regulation 18 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 2.3 ‘Board’ means the Board of Directors of LCC Projects Limited. 2.4 ‘Company’ means LCC Projects Limited. 2.5 ‘Compliance Officer’ means the person as enumerated in Reg 2(c) of SEBI PIT Regulations, as amended from time to time. At present, the Company Secretary is the Compliance Officer for the purpose of the said Regulation. 2.6 Connected Persons means all the persons as enumerated in Reg 2(d) of SEBI PIT Regulations, as amended from time to time. 2.7 ‘Contra Trade’ means a trade or transaction which involves buying or selling any number of shares of the Company and within 6 months trading or transacting in an opposite transaction involving sell or buy following the prior transaction. 2.8 ‘Dealing in Securities’ means an act of subscribing to, buying, selling or agreeing to subscribe to, buy, sell or deal in the Securities of the Company either as principal or agent. 2.9 ‘Designated Person’ means - i. Every Promoter, Directors and Key Managerial Personnels of the Company and its material subsidiary Companies. ii. Senior Manager/Manager/ Project Manager/Head of the Department working in Finance, Accounts, Secretarial, Taxation, Purchase, Store, Technical, Legal and IT Departments, HR and Admin, Techno Commercial, CMD cell department at the Corporate Office and its material subsidiaries. iii. Such other employees of the Company including that of material Subsidiary/Associate companies, temporary/ad-hoc employees designated by the Board of Directors from time to time to whom the trading restrictions shall be applicable. iv. Immediate Relatives of persons specified in (i) to (iii) above in case any of the designated persons leaves the services of the Company, due to superannuation/resignation/ termination etc., he/she shall continue to be considered as such for a further period of six months subsequent to the date of his/her leaving the Company as envisaged under SEBI (Prohibition of Insider Trading) Regulations, 2015. 2.10 ‘Director’ means a member of the Board of Directors of the Company. 2.11 ‘Employee’ means every employee of the Company including the Directors in the employment of the Company. 2.12 ‘Generally available information’ means information that is accessible to the public on a non- discriminatory basis. 2.13 ‘Immediate Relative’ means a spouse of a person, and includes parent, sibling, and child of that person or of the spouse, if they are either dependent financially on such person, or consult such person in taking decisions relating to Trading in securities. 2.14 ‘Insider’ means any person who is: i. A Connected Person or ii. In possession of or having access to UPSI. 2.15 ‘Insider trading’ means when insiders use unpublished price sensitive information to arrive at securities trading (including buying as well as selling) decisions. 2.16 ‘Key Managerial Personnel’ means person as defined in Section 2(51) of the Companies Act, 2013. 2.17 ‘Leak of UPSI’ shall refer to such act/circumstance(s) by virtue of which an UPSI is made available or becomes available, by any means or mode to any person, association, body, firm, agency, society, entity or to a group thereof, whether registered or otherwise before its official publication or announcement or formal circulation in public domain and which shall also include any purported attempt thereof. Explanation: It covers the instances where the UPSI has been shared by a person to any person, association, body, firm, agency, society, entity or to a group thereof except in compliance with applicable law. 2.18 ‘Legitimate purpose’ includes sharing of unpublished price sensitive information in the ordinary course of business by an insider with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals or other advisors or consultants, provided that such sharing has not been carried out to evade or circumvent the prohibitions of these regulations. 2.19 ‘Officer of the Company’ means any person as defined in clause 59 of Section 2 of the Companies Act, 2013 i.e. "officer" includes any director, managing director or key managerial personnel or any person in accordance with whose directions or instructions the Board of Directors or any one or more of the directors is or are accustomed to act, 2.20 ‘Promoter and Promoter Group’ shall have the meaning assigned to it under the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 or any modification thereof. 2.21 relative shall mean the following: (i) Spouse of the person; (ii) Parent of the person and parent of its spouse; (iii) Sibling of the person and sibling of its spouse; (iv) Child of the person and child of its spouse; (v) Spouse of the person listed at sub-clause (iii); and (vi) Spouse of the person li [Showing first 8,000 characters — download PDF for full document]