Updates

Date: 23.09.2026 To, To, BSE Limited National Stock Exchange of India Limited Department of Corporate Services Exchange Plaza, 5th Floor, Pheroze Jeejeebhoy Towers, Dalal Plot No. C/1, G Block, Street, Bandra-Kurla Complex, Mumbai – 400051 Mumbai –400001 BSE Scrip Code: 544903 NSE Symbol: DEEPA Sub: Intimation under Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Dear Sir/ Madam, This is to inform you that, pursuant to Regulation 8(1) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”), Deepa Jewellers Limited (“Company”) has framed a Code of Practices and Procedure for Fair Disclosure of Unpublished Price Sensitive Information. In accordance with Regulation 8(2) of the SEBI PIT Regulations, the same is being submitted herewith. The policy has also been uploaded on the Company’s website at www.deepajewel.com This is for your information and records. Thanking You, For Deepa Jewellers Limited Vandana Modani Company Secretary and Compliance Officer M. No.: A53323 DEEPA JEWELLERS LIMITED (Formerly known as Deepa Jewellers Private Limited) Code of Practices and Procedures for Fair Disclosure of UPSI [Pursuant to Regulation 8 of SEBI (Prohibition of Insider Trading) Regulations, CIN: U74999TG2016PLC109435 Registered Office: Ground Floor & First Floor, Door No 3-6-343 & 344, Basheerbagh, Himayathnagar, Hyderabad, Telangana, India, 500029 1 | Page CHAPTER – I PRELIMINARY 1. Introduction The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“Regulations”) mandate every company, whose securities are listed on a stock exchange, to formulate and publish on its website a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information. In light of the above, the Company has formulated this Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensistive Indormation (“Code”) which inter-alia, seeks to ensure timely and adequate disclosure of unpublished price sensitive information (“UPSI”) to the investor community by the Company to enable them to take informed investment decisions with regard to the Securities of the Company. This Code is framed as per Model Code prescribed under Schedule A of the Regulations. 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 Deepa Jewellers Limited. c) “Company” means Deepa Jewellers Limited (Formerly known as Deepa Jewellers Private 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 these regulations and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the preservation of UPSI, monitoring of trades and the implementation of the codes specified in these regulations under the overall supervision of the Board of the Company or the head of the Company, as the case may be, in compliance with the provisions of the SEBI PIT Regulations; 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 been, during the six months prior to the concerned act, associated with the Company, in any capacity, directly or indirectly, 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, whether temporary or permanent, with the Company that allows such person, directly or indirectly, access to UPSI or is reasonably expected to allow such access. 2 | Page 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. A relative of Connected Persons specified in clause (i); or ii. a holding company or associate company or subsidiary company; or iii. an intermediary as specified in Section 12 of the Securities and Exchange Board Act, 1992, as amended, 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; or viii. an official or an employee of a self- regulatory organization recognized or authorized by SEBI; or 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 relative or banker of the Company, has more than ten per cent, of the holding or interest; or xi. a firm or its partner or its employee in which a connected person specified in sub-clause (i) of clause (d) is also a partner; or xii. a person sharing household or residence with a connected person specified in sub-clause (i) of clause (d). 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. 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. Directors, Chief Executives and employees up to 2 (two) levels below the Managing Director, 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 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; x. Immediate Relatives of persons specified in (i) to (viii) above. h) “Promoter” and “Promoter Group” shall have the meaning assigned to them under the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 or any modification thereof; 3 | Page i) “Insider” shall mean any person who is a Connected Person; or who is in possession of or having access to UPSI; 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” means the Securities & Exchange Board o [Showing first 8,000 characters — download PDF for full document]