Updates

VARMORA GRANITO LIMITED (Formerly known as Varmora Granito Private Limited) Registered Office: 8-A, National Highway, Dhuva, Taluka Wankaner, Morbi, Gujarat – 363641, India Tel.: +91-22-28389790/91/92 | Fax: +91-22-28389794 Email: cs@varmora.com | CIN: U26914GJ2003PLC043194 Date: September 29, 2026 To, To, National Stock Exchange of India Limited (“NSE”) BSE Limited (“BSE”) Listing Department Listing Department Exchange Plaza, C-1 Block G, Bandra Kurla Complex Corporate Relationship Department Bandra [E], Mumbai – 400051 Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai - 400 001 NSE Scrip Symbol: VARMORA BSE Scrip Code: 544942 ISIN: INE0M5301040 ISIN: INE0M5301040 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 Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, please find attached herewith the “Code of Conduct and Procedures for Fair Disclosure of Unpublished Price Sensitive Information” framed under Regulation 8 (1) of the SEBI PIT Regulations. This is for your information and records. Thanking You, For Varmora Granito Limited Bhavesh Vallabhdas Varmora Managing Director DIN: 02718600 Encl: Code of Conduct and Procedures for Fair Disclosure of Unpublished Price Sensitive Information VARMORA GRANITO LIMITED CODE OF CONDUCT AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION 1. BACKGROUND The Securities and Exchange Board of India (SEBI), in its endeavour to put in place a framework for prohibition of insider trading in securities, has notified the SEBI (Prohibition of Insider Trading) Regulations, 2015 (Regulations). These Regulations are applicable to all companies whose securities are listed on stock exchanges. In terms of Regulation (8) (1) of the Regulations, the Board of Directors of these companies are required to formulate and publish on its official website, a code of conduct and procedures for fair disclosure of unpublished price sensitive information (the “Code”) that it would follow in order to adhere to each of the principles set out in Schedule A to the Regulations. The code is aligned with the principles of responsible business conduct as per the National Guidelines on Responsible Business Conduct (NGRBC) and SEBI’s Business Responsibility and Sustainability Reporting (BRSR) framework. 2. OBJECTIVE The Company endeavours to preserve the confidentiality of unpublished price sensitive information and to prevent the misuse of such information. Accordingly, this Code has been formulated with a view to maintain uniformity, transparency and fairness in dealing with all stakeholders and to ensure timely, fair and adequate disclosure of unpublished price sensitive information to the investor community by the Company to enable them to take informed investment decisions with regard to the Company’s securities. 3. DEFINITIONS "Unpublished Price Sensitive Information (UPSI)" means any information, relating to the Company or its securities, directly or indirectly, that is not generally available and which upon becoming generally available, is likely to materially affect the price of the securities and shall, ordinarily include but not restricted to, information relating to financial results, dividends, change in capital structure, mergers, de-mergers, acquisitions, delistings, disposals and expansion of business and changes in key managerial personnel. "Generally available information" means information that is accessible to the public on a non- discriminatory basis. “Legitimate Purpose” shall include 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 the Regulations. Any person in receipt of UPSI pursuant to a Legitimate Purpose shall be considered as an “Insider” for the purpose of this Code and such persons shall maintain confidentiality of such UPSI in compliance with this Code, the Varmora Code of Conduct to Regulate, Monitor and Report Trading by Insiders and the SEBI (Prohibition of Insider Trading) Regulations, 2015. All other terms not defined in this Code shall have the meaning in accordance with the Varmora Code of Conduct to Regulate, Monitor and Report Trading by Insiders and the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time. 4. CODE The Company will adhere to the following so as to ensure fair disclosure of events and occurrence that could impact price discovery in the market for its securities: 1. The Company will make prompt disclosure to the stock exchange of any UPSI that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available. The Company may, in appropriate circumstances, also simultaneously disclose the UPSI in such manner as it deems fit including on the Company’s website, print or electronic media or social media. 2. The Company will make uniform and universal dissemination of UPSI to avoid selective / speculative disclosure which could have an adverse impact on the market and the price discovery process. 3. The Head – Investor Relations of the Company shall act as the Chief Investor Relations officer (CIRO) to deal with dissemination of information and disclosure of UPSI. The CIRO shall coordinate with the Compliance Officer to ensure that all regulatory filings and investor communications are aligned with SEBI guidelines. 4. The Company will make prompt dissemination of UPSI that gets disclosed selectively, inadvertently or otherwise to make such information generally available. 5. The Company will provide appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities. 6. Research and analysis should be done on the basis of generally available information. The Company will ensure that information, if any, shared with analysts and research personnel during meetings/discussions/conferences, is not UPSI. 7. As a means of following best practices in respect of meetings with analysts and other investor relations conferences and to ensure official confirmation and documentation of disclosures made, the Company shall: a. Make transcripts or records of proceedings of meetings with analysts and other investor relations conference available on the official website of the Company, where the Company considers necessary; b. Endeavour that at least 2 company representatives be present at meetings with analysts, brokers, institutional investors and research personnel; c. In appropriate circumstances, consider posting of relevant information on its website or issuing a press release or disseminating information in any other mode it deems appropriate in relation to meeting with analysts. 8. All UPSI shall be handled within the Company strictly on a need to-know basis i.e. all UPSI may be disclosed only where such disclosure is (i) for a “legitimate purpose”, as defined in this Code; (ii) in discharge of legal obligations or (iii) to those within the Company who need the UPSI to discharge their duty and whose possession of such information will not give rise to a conflict of interest or appearance of misuse of such information. Such disclosure shall be made only after appropriate entry(ies)have been made by the concerned employee disclosing the information in the Structured Digital Database module. 5. DETERMINATION OF LEGITIMATE PURPOSE FOR SHARING OF UPSI The sharing of UPSI shall be considered as for a legitimate purpose, if it is in the ordinary course of business by an Insider with partners, collaborators, lenders, custome [Showing first 8,000 characters — download PDF for full document]