Updates

July 17, 2026 BSE Limited National Stock Exchange of India Limited Corporate Relationship Department The Listing Department, 25th Floor, Phiroze Jeejeebhoy Towers, Exchange Plaza, Dalal Street, Fort, Bandra- Kurla Complex, Bandra (East), Mumbai - 400 001. Mumbai - 400 051. BSE Scrip Code: 524000 NSE Symbol: POONAWALLA Subject: Intimation under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (“SEBI PIT Regulations”). Dear Sir / Madam, In pursuance to the provisions of Regulation 8(2) of the SEBI PIT Regulations, please find enclosed herewith a copy of the amended – “Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information” (“Code”), as approved by the Board of Directors of the Company at its meeting held on July 17, 2026. We request you to take the amended Code on record. In compliance with the SEBI Listing Regulations, the above information is also being hosted on the Company’s website at https://poonawallafincorp.com/investor-governance Thanking You, Yours faithfully, For Poonawalla Fincorp Limited Shabnum Zaman Company Secretary ACS-13918 Encl: As above Classification | INTERNAL POONAWALLA FINCORP LIMITED CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION FRAMED UNDER REGULATION 8 (1) OF SECURITIES AND EXCHANGE BOARD OF INDIA (PROHIBITION OF INSIDER TRADING) REGULATIONS, 2015 Contents 1. INTRODUCTION: 2 2. APPLICABILITY: 2 3. DEFINITIONS: 2 4. SHARING OF UPSI FOR LEGITIMATE PURPOSE: 4 5. FUNCTIONS OF THE CHIEF INVESTOR RELATIONS OFFICER: 5 6. PRINCIPAL OF FAIR DISCLOSURE ADOPTED BY PFL: 5 7. THIRD PARTY DEALINGS: 5 8. RUMOURS: VERIFICATION OF MARKET RUMOURS AND RESPONSE TO QUERIES. 5 9. NEED TO KNOW HANDLING OF UPSI: 5 10. AUTHORITY TO MAKE ALTERATIONS/AMENDMENTS: 5 11. GENERAL: 5 ANNEXURE- A 6 July 17, 2026 1. INTRODUCTION: This document forms the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information adopted by Poonawalla Fincorp Limited (hereinafter referred to as “PFL”/ “Company”). This code is consistent with the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“Regulations”). As per Regulation 8 read with Schedule A of the Regulations, every listed company has to frame a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (hereinafter referred to as the “Code”) to adhere to each of the principles set out in Schedule A of the Regulations. The Regulations intends to require companies to disseminate ‘Unpublished Price Sensitive Information’ (hereinafter referred to as “UPSI”) universally and not selectively. This Code is intended to lay down procedures and practices to be followed by the Company pertaining to universal disclosure of UPSI in light of principles laid down under the Regulations. The Company intends to follow best practices, duly compliant with the Applicable Law (as defined hereinafter), in the matter of disclosure of UPSI. Accordingly, the following Code was originally adopted by the board of directors of Poonawalla Fincorp Limited (“Board of Directors” or “Board”), at its meeting held on May 08, 2015, and has been reviewed and revised by the Board from time to time. 2. APPLICABILITY: This Code shall apply in relation to uniform disclosure by the Company of UPSI. The exceptions as given in Applicable Law shall be applicable for the purpose of this Code as well. 3. DEFINITIONS: 3.1 “Applicable Law” means the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, or any statute, law, listing agreement, regulation, ordinance, rule, judgment, order, decree, bye-law, clearance, directive, guideline, policy, requirement, notifications and clarifications, circulars or other governmental instruction and/or mandatory standards and or guidance notes as may be applicable in the matter of Trading by an Insider, and as may be amended, restated or substituted from time to time. 3.2 “Company” means Poonawalla Fincorp Limited; 3.3 “Connected Persons” means any person who: a. is or has been, during the six months prior to the concerned act, associated with a 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 a person, directly or indirectly, access to unpublished price sensitive information or is reasonably expected to allow such access; b. Without prejudice to the generality of the foregoing, 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 (a) above; or ii. a holding company or associate company or subsidiary company; or iii. an intermediary1 as specified in section 12 of the Securities Exchange Board of India Act, 1992 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 institution2 as defined in section 2 (72) of the Companies Act, 2013; or viii. an official or an employee of a self-regulatory organization3 recognised 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 a company or his relative or banker of the company, has more than ten per cent. of the holding or interest. xi. a firm or its partner or its employee in which a connected person specified in sub-clause (a) of clause (3.3) is also a partner; or xii. a person sharing household or residence with a connected person specified in sub-clause (a) of clause (3.3) “Chief Investor Relations Officer (CIRO)” means the Chief Financial Officer or such senior officer of the Company designated by the Board of Directors, for the purposes of Schedule A of the Regulation, to deal with dissemination of information and disclosure of UPSI in a fair and unbiased manner. 1As per Section 12 of the Securities and Exchange Board of India Act, 1992 “Intermediary” are persons such as stockbrokers, sub- broker, investment advisers, merchant banker, underwriter, portfolio manager, share transfer agent, registrar to an issue, depositories, custodians of securities, foreign institutional investors, credit rating agencies, asset management companies, venture capital funds, mutual funds and such other intermediaries who may be associated with securities market in any manner. 2As per Section 2(72) of Companies Act, 2013, “Public Financial Institutions” means: (i) the Life Insurance Corporation of India, established under section 3 of the Life Insurance Corporation Act, 1956 (31 of 1956); (ii) the Infrastructure Development Finance Company Limited, referred to in clause (vi) of sub-section (1) of section 4A of the Companies Act, 1956 (1 of 1956) so repealed under section 465 of this Act; (iii) specified company referred to in the Unit Trust of India (Transfer of Undertaking and Repeal) Act, 2002 (58 of 2002); (iv) institutions notified by the Central Government under sub-section (2) of section 4A of the Companies Act, 1956 (1 of 1956) so repealed under section 465 of this Act; (v) such other institution as may be notified by the Central Government in cons [Showing first 8,000 characters — download PDF for full document]