General Updates

September 30, 2026 ECL/SE/2026-27/04 Na(cid:23)onal Stock Exchange of India Limited BSE Limited Exchange Plaza, Plot No. C/1, G Block, Phiroze Jeejeebhoy Towers, Bandra-Kurla Complex, 25th floor, Dalal Street, Fort, Bandra (E), Mumbai – 400051 Mumbai – 400001 Symbol: ELEVATE Scrip Code: 544945 Dear Sir/Madam, Subject: Intimation under Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Pursuant to the Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended (“SEBI PIT Regulations”), please find enclosed herewith the “Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information and determination of Legitimate Purposes” framed under Regulation 8(1) of SEBI PIT Regulations. The said Code has also been uploaded on the website of the Company at www.elevatecampuses.com Kindly take the above information on your record. Yours faithfully, For Elevate Campuses Limited (formerly known as Good Host Spaces Limited) Jenny Shah Company Secretary & Compliance Officer Elevate Campuses Limited (Formerly known as Good Host Spaces Limited) CIN – U74994MH2005PLC339336 Registered Office: Naman Midtown, Unit No 902 - 906, 9th Floor, Tower B, Lower Parel, Mumbai - 400013 Tel: +91 -22-68201600 l Email: companysecretary@elevatecampuses.com l Website: www.elevatecampuses.com ELEVATE CAMPUSES LIMITED (formerly known as Good Host Spaces Limited) CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION AND DETERMINATION OF LEGITIMATE PURPOSES Version control Original approved by the Board at its meeting held on September 25, 2025 Revised and Approved by the Board at its meeting held on September 17, 2026 CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION AND DETERMINATION OF LEGITIMATE PURPOSES I. PREAMBLE In pursuance to the Regulation 8(1) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time (“Insider Trading Regulations”), it is required that the board of directors of every listed company shall formulate a code of practices and procedures for fair disclosure of unpublished price sensitive information. This document (“Code”) embodies the code of practices and procedures for fair and prompt disclosure of unpublished price sensitive information (“UPSI”) (as defined under the Insider Trading Regulations) to be followed by the Company, its subsidiaries and associates, effective from the commencement of listing and trading of the equity shares of the Company on the stock exchange(s), i.e. BSE Limited or the National Stock Exchange of India Limited, in accordance with applicable laws. For the avoidance of doubt, the provisions of this Code shall be applicable to the Company in accordance with the timelines and stages prescribed under the Insider Trading Regulations, including when the Company is considered as ‘proposed to be listed’, at which point the relevant provisions shall become applicable with immediate effect. All terms used but not defined herein shall have the meaning ascribed to such term under the Insider Trading Regulations. In case of any discrepancy between the Insider Trading Regulations and the terms defined herein, the meaning as ascribed under the Insider Trading Regulations, shall prevail. II. UNPUBLISHED PRICE SENSITIVE INFORMATION i. Elevate Campuses Limited (formerly known as Good Host Spaces Limited) (“Company”) shall promptly disclose unpublished price sensitive information that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available. ii. The UPSI shall be uniform and universally disseminated and due care will be taken to avoid selective disclosure. iii. Material events will be disseminated as mandated by the stock exchanges in Regulation 30 of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended from time to time. iv. In case if the UPSI that gets disclosed selectively, inadvertently or otherwise, prompt steps shall be taken to make such information generally available. Accordingly, the board of directors of Company (“Board”) adopted the Policy at its meeting held on September 25, 2025, which can be amended from time to time. III. DEFINITIONS i. “Insider” shall mean any person who is: (a) a connected person; or (b) in possession of or having access to Unpublished Price Sensitive Information;. ii. "Code" or "this Code" shall mean this Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information; iii. “need-to-know basis” shall mean that UPSI should only be disclosed to, or procured by, such persons who need to share or access the UPSI in furtherance of legitimate purposes, performance of duties or discharge of legal obligations, and whose possession of such UPSI will not give rise to a conflict of interest or amount to the misuse of such UPSI. iv. “Promoters” shall mean Genius Bidco Holdings Pte. Ltd. and Genius Rajkot Investment Holdings Pte. Ltd. v. “Unpublished Price Sensitive Information” shall have the meaning assigned to it under the Insider Trading Regulations. Other terms not specifically defined here shall have the same meaning as assigned under the ‘Code of Conduct to regulate, monitor and report trading by Designated Persons and their Immediate Relatives of Elevate Campuses Limited' and ‘Insider Trading Regulations’. IV. DESIGNATION AND ROLE OF CHIEF INVESTOR RELATIONS OFFICER i. The Chief Financial Officer of the Company shall be the Chief Investor Relations Officer (“CIRO”) for the purpose of the Code. The CIRO shall be responsible for dissemination of information and disclosure of UPSI and also responding to the queries on news reports and requests for verification of market rumours by regulatory authorities. ii. In the temporary absence of the CIRO for any reason whatsoever, the executive director/whole-time director/managing director/chief executive officer of the Company shall nominate any other official of the Company to be responsible for dissemination of information and disclosure of UPSI. V. GENERAL OBLIGATIONS FOR PRESERVATION AND DISCLOSURE OF UPSI i. All UPSI shall be handled on a need-to-know basis and in accordance with the provisions of the Insider Trading Regulations and any other applicable codes, policies and procedures of the Company. ii. It is clarified that information to be termed UPSI should be specific and intended to be generally made available at a point of time to ensure it does not lead to creation of a false market in securities. For the purpose of disclosure, the CIRO may consult such officials within the Company to ensure the correctness and credibility of the UPSI. The CIRO shall authorise disclosure or dissemination of UPSI (1) by way of intimation to the stock exchanges, such that further disclosure can be made from the stock exchange websites; (2) on the official website to ensure official confirmation and documentation; and (3) in any other manner as may be decided by the CIRO to facilitate uniform and universal dissemination of UPSI. iii. All communications of UPSI with the stock exchange shall be approved by the CIRO and communicated through appropriate personnel under his direction. iv. The CIRO shall also be responsible for overseeing the contents of UPSI to be posted on the website of Company for the purposes of this Code and shall give appropriate directions for the publication of the same. No other person shall be authorised to post any UPSI in the absence of any directions from the CIRO. v. Information disclosure/ dissemination should normally be approved in advance by the CIRO. If the information is accidentally disclosed without prior approval, the person responsible must inform the CIRO [Showing first 8,000 characters — download PDF for full document]