Updates

Premier ARC Date: September 17, 2026 To, To, National Stock Exchange of India Limited (“NSE”) BSE Limited (“BSE”) Listing Department Listing Department Exchange Plaza, C-1 Block G, Corporate Relationship Department Bandra Kurla Complex, Bandra (E), Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai – 400051 Mumbai - 400 001 NSE Scrip Symbol: ARCIL BSE Scrip Code: 544921 ISIN: INE148G01016 ISIN: INE148G01016 Subject: 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Trading) Regulations, 2015, please find enclosed herewith the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information framed under Regulation 8(1) of SEBI PIT Regulations which is a part of Insider Trading Code of the Company (“Insider Trading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://www.arcil.co.in/about- us/corporate-governance You are requested to take the aforesaid information on your record. Thanking You, For Asset Reconstruction Company (India) Limited Ameet Ashok Kela Company Secretary and Compliance O(cid:431)icer Membership No.: F7934 Encl: As above Asset Reconstruction Company (India) Limited The Ruby, 10th Floor, 29, Senapati Bapat Marg, Dadar (West), Mumbai 400 028. India Tel: (+91 - 22) 6658 1300 Fax: (+91 22) 6658 1313/14 Website: www.arcil.co.in Corporate Identification Number: U65999MH2002PLC134884 Arcil – Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information Background ASSET RECONSTRUCTION COMPANY (INDIA) LIMITED Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (Amended in Board Meeting held on August 21, 2026) Company Secretarial Group Page 1 of 13 Arcil – Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information Background Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information Background 1. Background The Securities and Exchange Board of India [“SEBI’’] has promulgated the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended (hereinafter referred to as “PIT Regulations”). As per Regulation 8(1) read with Schedule A of the PIT Regulations, every listed company has to frame a Code of Conduct for Fair Disclosure of Unpublished Price Sensitive Information. The PIT Regulations require the company to disseminate Unpublished Price Sensitive Information [“UPSI”] universally, and not selectively. This Code lays down principles, procedures and practices to be followed by the company pertaining to uniform and fair disclosure of its UPSI. 2. Objective The objective of this Code is to devise practices and procedures that would aid in fair disclosure of UPSI in a uniform manner through normal channels for making disclosures of such information so as to ensure that there is no information asymmetry in the securities market. The Code aims to achieve this objective by ensuring that disclosures are made at the same time and of the same information. The Code aims to lay down the practices and procedures for being followed by every person associated with the Company, who is in possession of UPSI of the Company or has access to the UPSI of the Company, without prejudice to the duty each such person owes towards maintenance of confidentiality. The ultimate responsibility for ensuring effective compliance of the requirements of this Code lies with the Board of Directors. 3. Applicability The Code shall apply to every disclosure of UPSI arising from time to time until it becomes Generally Available Information (‘’GAI’’). The exceptions as given in the PIT Regulations shall be applicable for the purpose of this Code as well. 4. Definitions a. “Company” means Asset Reconstruction Company (India) Limited. b. “Chief Investor Relations Officer (‘’CIRO’’)” means the Compliance Officer of the Company who has been assigned with the specific responsibility to deal with dissemination of information and disclosure of UPSI in a fair and unbiased manner. CIRO shall be responsible for determining whether permitted disclosures of any UPSI have been made and whether such disclosures have been made for legitimate purposes as prescribed in this Code. Page 2 of 13 Arcil – Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information Background Board vide its meeting held on June 14, 2025 vide has Compliance Officer as the CIRO for the purpose of enabling compliance under this Code. c. “Compliance Officer” means any senior officer designated so and reporting to the Board, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under the Insider Trading Regulations, and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules of preservation of Unpublished Price Sensitive Information, monitoring of trades and the implementation of the codes specified under the Insider Trading Regulations under the overall supervision of the Board. d. “Disclosures to Public” means acting as governance bodies and making disclosures about the Company and on behalf of the Company, through press reports or media or interviews or announcements etc. e. “Disclosures to Third Parties” means making disclosures to persons or entities in the course of the routine performance of duties. f. “Generally Available Information (‘GAI’)” means information that is accessible to the public on a non-discriminatory basis and shall not include unverified event or information reported in print or electronic media. Information published on the website of a stock exchange, would ordinarily be considered generally available. “Generally Available Information" is defined it is intended that anyone in possession of or having access to unpublished price sensitive information should be considered as an "insider" regardless of the manner in which one came into possession of or had access to such information. Various circumstances are provided to enable such a person to demonstrate that he has not indulged in insider trading. Therefore, this definition is intended to bring within its reach any person who is in receipt of or has access to unpublished price sensitive information. The onus of showing that a certain person was in possession of or had access to unpublished price sensitive information at the time of trading would, therefore, be on the person leveling the charge after which the person who has traded when in possession of or having access to unpublished price sensitive information may demonstrate that he was not in such possession or that he has not traded or he could not access or that his trading when in possession of such information was squarely covered by the exonerating circumstances. g. “Insider” means any person as defined under Regulation 2[1(g)] of PIT Regulations. h. “Need to Know basis” means that the person or entity in possession of UPSI should be disclosed only to those Persons who need the information to discharge Page 3 of 13 Arcil – Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information Background their duty and whose possession of such information will not give rise to a conflict of interest or appearance of misuse of the information. i. “Permitted Insider” means the Chairman, Chief Executive Officer & Managing Director and Key Managerial Persons of the Company. j. “Permitted Employee” means any other Employee of the Company who may have access to or be in possession of UPSI but who shall be specifically permitted in writing to make permitted disclosures to third parties only; for Legitimate Purposes. However, no Permitted employee shall suo-moto m [Showing first 8,000 characters — download PDF for full document]