Updates

October 03, 2026 The Lis(cid:415)ng Department The Lis(cid:415)ng Department BSE Limited Na(cid:415)onal Stock Exchange of India Limited Phiroze Jeejeebhoy Towers Exchange Plaza, Dalal Street, Fort Bandra Kurla Complex, Mumbai – 400 001 Bandra (East), Mumbai – 400 051 Code: 544917 Symbol: KARAMTARA Sub: In(cid:415)ma(cid:415)on pursuant to Regula(cid:415)ons 8(2) of the Securi(cid:415)es and Exchange Board of India (Prohibi(cid:415)on of Insider Trading) Regula(cid:415)ons, 2015 (“SEBI PIT Regula(cid:415)ons”) Dear Sir/Madam, Pursuant to Regula(cid:415)on 8(2) of the SEBI (Prohibi(cid:415)on of Insider Trading) Regula(cid:415)ons, 2015, as amended (“SEBI PIT Regula(cid:415)ons”), please find enclosed herewith the “Code of Prac(cid:415)ces and Procedures for Fair Disclosure of Unpublished Price Sensi(cid:415)ve Informa(cid:415)on” (“Code”) approved and adopted by the Board of Directors of the Company under Regula(cid:415)on 8(1) of the SEBI PIT Regula(cid:415)ons. The above in(cid:415)ma(cid:415)on is also available on the website of the Company at www.karamtara.com and on the website of BSE Limited and Na(cid:415)onal Stock Exchange of India Limited. You are requested to kindly take the above informa(cid:415)on on record. Thanking you, For Karamtara Engineering Limited (Formerly known as Karamtara Engineering Pvt. Ltd.) Manoj Kumar Srivastava Vice President - Legal Company Secretary & Compliance Officer FCS-7460 KARAMTARA ENGINEERING LIMITED CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION 1. Purpose and Scope This Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Policy”) of Karamtara Engineering Limited ("Company” or “KEL”) has been adopted pursuant to the provisions of regulations 3(2A) and 8(1) read with Schedule A of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”), as amended from time to time, and has been approved by the board of directors of the Company (“Board”). This Policy seeks to put in place a framework to: (a) preserve confidentiality of Unpublished Price Sensitive Information (“UPSI”) (as defined below) and to prevent its misuse; and (b) facilitate fair disclosure of all UPSI (as defined below) on a non-discriminatory basis in order to enable fair price discovery of the securities of the Company. 2. Terms & Definitions “UPSI” means any information, relating to the Company or its securities, direct or indirect, that is not generally available, which upon becoming generally available, is likely to materially affect the market price of the securities of the Company, and UPSI shall ordinarily include, but not be restricted to, information relating to the following: (i) financial results; (ii) dividends; (iii) changes in capital structure; (iv) mergers/demergers/acquisition/delisting/disposal/business expansion and such other transactions; (v) changes in key managerial personnel; and (vi) any such information which is appropriately labeled as unpublished price sensitive information by the CIRO. “Chief Investor Relation Officer” or “CIRO” means the company secretary who has been designated by the Board from time to time to deal with dissemination and disclosure of UPSI. “Insider Trading Code” means the code of conduct of the Company formulated pursuant to Regulation 9 of the PIT Regulations, for the purpose of regulating, monitoring and reporting trading by the Company’s designated persons and immediate relatives of designated persons, and for ensuring compliance with the PIT Regulations. 3. Prevention of Leakage of UPSI The employees and/or directors of the Company and its subsidiaries shall: (a) not discuss or disclose UPSI in public places where such UPSI may be overheard, or participate in, host or link to any internet chat rooms, online social networking sites, newsgroups, discussions, articles, presentations, or bulletin boards which discuss matters that may be classified as UPSI; (b) not carry, read or discard UPSI in an exposed manner in public places; (c) not discuss or share UPSI with any other persons, except as required in furtherance of legitimate purposes or performance of duties or discharge of legal obligations and in such case shared only in a manner meeting the requirements outlined below; and (d) ensure, to the extent possible, that UPSI that is authorized to be shared is shared either by an email (addressed directly to the insider) or hard copy (with an acknowledgement from the recipient) or any other secure electronic mode (capable of identifying the recipient). 4. Sharing of UPSI for Legitimate Purpose(s) 4.1 UPSI can be shared only on a ‘need-to-know basis’ and for furtherance of legitimate purposes, or performance of duties, or discharge of legal obligations, and after taking consent of the CIRO and confirming that the personal details of the recipient of the UPSI has been entered in the SDD (as defined below). The term “legitimate purpose” shall include sharing of UPSI in the ordinary course of business in order to perform duty, if required, by an insider with promoters and their affiliates, partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals or other advisors or consultants etc. or sharing of UPSI for any other purpose as may be prescribed under any applicable law for the time being in force, as may be amended from time to time, provided that such sharing has not been carried out to evade or circumvent the prohibitions under the PIT Regulations. 4.2 In the following cases, which are illustrative in nature, sharing of UPSI would be considered a legitimate purpose: (a) Sharing of UPSI in the ordinary course of business with existing or proposed 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 under the PIT Regulations; (b) Sharing of UPSI pursuant to any investigation, inquiry or request for information by statutory or governmental authorities or any other administrative or judicial body or arbitral tribunal; (c) Sharing of UPSI during any proceedings before any statutory or governmental authorities or any other administrative or judicial body or arbitral tribunal; (d) Sharing of UPSI for compliance with applicable laws, regulations and rules; (e) Sharing of UPSI out of business requirements including for the purposes of promoting the business and strategies of business; (f) Sharing of UPSI with persons engaged or involved in the processes leading to disclosure of events set out in the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015; and (g) Sharing of UPSI for any other purpose as may be prescribed under the PIT Regulations, as amended from time to time. 4.3 In addition to the above, the Company acknowledges and accepts that the Company, its subsidiaries and other associate companies (collectively, “Company Group”) benefit from the oversight and strategic advice provided by the KEL Shareholder (as defined in the Articles of Association of the Company) and/ or its Affiliates (as defined in the Articles of Association of the Company) and that the KEL Shareholder and/ or its Affiliates may also require certain information from the Company Group in furtherance of legitimate purposes, performance of duties and/or discharge of legal obligations. The Company shall furnish to the KEL Shareholder and/ or its Affiliates the following information on a need to know basis from time to time, in accordance with the PIT Regulations: (a) information that may be necessary in connection with any financial or other support that may be required from the KEL Shareholder and/or its Affiliates; (b) information that may be required for entering into [Showing first 8,000 characters — download PDF for full document]