Updates

SWARAJ ENGINES LIMITED Works: Plot No. 2, lndl. Focal Point, Phase-IX, S.A.S. Nagar Distt. S.A.S. Nagar (Mohali) (Near Chandigarh) Tel.: 0172-2234941-47, 2234950 02/SP/EXCH 12th October, 2026 BSE Limited National Stock Exchange of India Limited Listing Department Capital Market-Listing, Exchange Plaza, P.J. Towers, 1st Floor, Bandra Kurla Complex, Dalal Street, Fort, Bandra (E), Mumbai – 400 001 Mumbai- 400051 Email: corp.relations@bseindia.com Email: cmlist@nse.co.in Ref: Scrip Code: 500407 Scrip Name: SWARAJENG Sub: Amendment to the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information Dear Sir, We hereby inform you that, in compliance with Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, the Company has amended the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Code of Fair Disclosure”), effective from today i.e. 12th October, 2026. A copy of the Code of Fair Disclosure is enclosed. The same will also be available on the Company’s website at: https://swarajenterprise.com/policies Kindly take the above information on your record. With regards, For Swaraj Engines Limited (RAJESH K. KAPILA) Company Secretary M.No.: ACS-9936 Encl: As above Regd. Office : Industrial Area, Phase IV, S.A.S. Nagar, Mohali, Near Chandigarh-160 055 Tel. : 91-172-2271620-27, Fax : 91-172-2271307 & 2272731 Website : www.swarajenterprise.com CIN - L50210PB1985PLC006473 SWARAJ ENGINES LIMITED (Revised on 12-10-2026) CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION 1. This Code shall come into force from 15th day of May, 2015 with such other applicable amendments as specified by SEBI from time to time. 2. Definitions: For the purpose of this code the following terms shall have the meanings assigned to them hereunder: i. “Act” means the Securities and Exchange Board of India Act, 1992 (15 of 1992); ii. “Code” or “this Code” shall mean this Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information; iii. “Company” or “the Company” or “SEL” means Swaraj Engines Limited; iv. “Generally Available Information” means information that is accessible to the public on a non-discriminatory basis, such as information published on the website of the stock exchanges. “Generally Available” with respect to information shall be construed accordingly; v. “Insider Trading Regulations” means the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 as amended from time to time; vi. “Listing Regulations” means the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended from time to time; vii “Mainstream Media” shall include print or electronic mode of the following: (a) Newspapers registered with the Registrar of Newspapers for India; (b) News channels permitted by Ministry of Information and Broadcasting under Government of India; (c) Content published by the publisher of news and current affairs content as defined under the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021; and (d) Newspapers or news channels or news and current affairs content similarly registered or permitted or regulated, as the case may be, in jurisdictions outside India. viii. “Unpublished Price Sensitive Information” or “UPSI” means any information, relating to the Company or its Securities, directly or indirectly, that is not generally available which upon becoming generally available, is likely to materially affect the price of the Securities of the Company and shall, ordinarily including but not restricted to, information relating to the following: (i) financial results; (ii) dividends; (iii) change in capital structure; (iv) mergers, de-mergers, acquisitions, delistings, disposals and expansion of business, award or termination of order/contracts not in the normal course of business and such other transactions; (v) changes in key managerial personnel, other than due to superannuation or end of term, and resignation of a Statutory Auditor or Secretarial Auditor; (vi) change in rating(s), other than ESG rating(s); (vii) fund raising proposed to be undertaken; (viii) agreements, by whatever name called, which may impact the management or control of the company; (ix) fraud or defaults by the company, its promoter, director, key managerial personnel, or subsidiary or arrest of key managerial personnel, promoter or director of the company, whether occurred within India or abroad; (x) resolution plan/ restructuring or one-time settlement in relation to loans/borrowings from banks/financial institutions; (xi) admission of winding-up petition filed by any party /creditors and admission of application by the Tribunal filed by the corporate applicant or financial creditors for initiation of corporate insolvency resolution process against the company as a corporate debtor, approval of resolution plan or rejection thereof under the Insolvency and Bankruptcy Code, 2016; (xii) initiation of forensic audit, by whatever name called, by the company or any other entity for detecting mis-statement in financials, misappropriation/ siphoning or diversion of funds and receipt of final forensic audit report; (xiii) action(s) initiated or orders passed within India or abroad, by any regulatory, statutory, enforcement authority or judicial body against the company or its directors, key managerial personnel, promoter or subsidiary, in relation to the company; (xiv) outcome of any litigation(s) or dispute(s) which may have an impact on the company; (xv) giving of guarantees or indemnity or becoming a surety, by whatever named called, for any third party, by the company not in the normal course of business; (xvi) granting, withdrawal, surrender, cancellation or suspension of key licenses or regulatory approvals. Explanation 1 - For the purpose of sub-clause (ix): a. ‘Fraud’ shall have the same meaning as referred to in Regulation 2(1)(c) of Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade Practices relating to Securities Market) Regulations, 2003. b. ‘Default’ shall have the same meaning as referred to in Clause 6 of paragraph A of Part A of Schedule III of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations,2015. Explanation 2 - For identification of events enumerated in this clause as unpublished price sensitive information, the guidelines for materiality referred at paragraph A of Part A of Schedule III of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 as may be specified by the Board from time to time and materiality as referred at paragraph B of Part A of Schedule III of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 shall be applicable. ix. Other terms not specifically defined here shall have the same meaning as assigned under the ‘Code of Conduct for Prevention of Insider Trading in Securities of Swaraj Engines Limited’ and ‘the Insider Trading Regulations’. The provisions of this Code have to be read along with the Insider Trading Regulations and if there is any inconsistency / contradiction between the two, the provisions of the Insider Trading Regulations shall prevail. 3. Purpose of the Code This Code has been formulated to ensure prompt, timely and adequate disclosure of UPSI. 4. Principles of Fair Disclosure The Company shall ensure: i. Prompt public disclosure of UPSI that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available. ii. Uniform and universal dissemination of UPSI to avoid selective disclosure. iii. Prompt dissemination of UPSI that gets disclosed selectively, inadvertently or othe [Showing first 8,000 characters — download PDF for full document]