General Updates

Ref: ISLL:CH:2026 Date: 22nd June, 2026 The President The Vice President, Corporate Relationship Department Listing Compliance Department, BSE Limited National Stock Exchange of India Limited, Phiroze Jeejeebhoy Towers, Exchange Plaza, 5th Floor 25th Floor, Dalal Street, Plot No. C/2, G-Block, Mumbai 400 001 Bandra Kurla Complex, Bandra (E), Mumbai 400 051 BSE Scrip Code: 532305 NSE Symbol: INDSWFTLAB Subject: Intimation under Regulation 8(2) of Securities Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Ref: Amendment to the ‘Code of Fair Disclosure, Internal Procedures and Conduct for Regulating, Monitoring and Reporting of Trading by Designated Persons and Immediate Relatives of Designated Persons, and Legitimate Purpose Policy’ Dear Sir/Ma’am, We wish to inform you that the the Board of Directors of the Company vide resolution passed by circulation on Monday, June 22, 2026, have approved amendment to the ‘Code of Fair Disclosure, Internal Procedures and Conduct for Regulating, Monitoring and Reporting of Trading by Designated Persons and Immediate Relatives of Designated Persons, and Legitimate Purpose Policy’ of the Company. Please find enclosed herewith a copy of the amended Code. Further, the amended Code is also being hosted on the website of the Company at https://www.indswiftgroup.com/investor-relations/disclosure-under-regulation-46/corporate-governance/ We request you to take the same on record. Thanking you, For IND-SWIFT LABORATORIES LTD. PARDEEP VERMA VP-CORPORATE AFFAIRS & COMPANY SECRETARY IND SWIFT LABORATORIES LIMITED CODE OF FAIR DISCLOSURE, INTERNAL PROCEDURES AND CONDUCT FOR REGULATING, MONITORING AND REPORTING OF TRADING BY DESIGNATED PERSONS AND IMMEDIATE RELATIVES OF DESIGNATED PERSONS, AND LEGITIMATE PURPOSE POLICY [Adopted by the Board on 22.06.2026] Page 1 of 31 Index Sr. No. Particulars Page No. 1. Object and Commencement 4 2. Definitions 4 3. Compliance Officer 7 4. Preservation of Unpublished Price Sensitive Information 8 5. Trading when in possession of Unpublished Price Sensitive 8 Information 6. Reporting requirements for transaction in Company’s Securities 13 7. Code of Fair Disclosure 14 8. Policy on determination of Legitimate purpose 14 9. Leak of Unpublished Price Sensitive Information 15 10. Contravention of the Code and Regulations 15 11. Reporting under Vigil Mechanism and Whistle Blower Policy 16 12. Amendments to the Code 16 13. Annexures 17 Page 2 of 31 FOREWORD On January 15, 2015 the Securities Exchange Board of India (“SEBI”) had notified the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time (“Regulations”) which replace the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 1992 with effect from May 15, 2015. The Regulations inter alia prohibits (i) communication of Unpublished Price Sensitive Information, (ii) procurement of price sensitive information and (iii) trading in securities when in possession of Unpublished Price Sensitive Information. The Regulations requires the Company to enact and adopt a code which lays down the internal procedures for regulating, monitoring and reporting of trading by Designated person(s) and their Immediate Relatives (“Code”). The Code is enclosed herewith. Page 3 of 31 1. Object and Commencement 1.1 This Code of internal procedures and conduct for regulating, monitoring and reporting of trading is enacted pursuant to the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, and as amended from time to time, under the overall supervision of the Board of Directors. 1.2 The object of this Code is to formulate (i) a code of conduct for fair disclosure and (ii) an internal code of conduct to regulate, monitor and report trading by the Designated Person(s) and their Immediate Relatives in terms of regulation 8 and 9 of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 read with Schedule A and B appended thereto, as amended from time to time. The Code shall also cover Policy on Determining Legitimate Purpose. However, the provision(s) of this Code may be made applicable, fully or partially, to any person whether an employee of the Company or otherwise, which the Compliance officer in consultation with the Managing Director(s) or Chief Financial Officer (CFO), may determine, inter-alia for the purpose of prevention misuse or unwarranted use of Unpublished Price sensitive Information. 2. Definitions 2.1 “Act” means the Securities and Exchange Board of India Act, 1992. 2.2 “Board” means the Board of Directors of the Company. 2.3 “Code” or “Code of Conduct” shall mean this Code of Fair Disclosure, Internal Procedures and Conduct for Regulating, Monitoring and Reporting of Trading by Designated Person(s) of the Company and policy on Legitimate purpose, as amended from time to time and formulated in terms of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time. 2.4 “Company” means Ind Swift Laboratories Limited. 2.5 "Compliance Officer" means Company Secretary or such other senior officer, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under these regulations designated so and reporting to the Board of Directors and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the preservation of Unpublished Price Sensitive Information, monitoring of trades and the implementation of the Code under the overall supervision of the Board of Directors of the Company. 2.6 “Connected Person” means: (i) any person who is or has during the 6 (six) months prior to the concerned act been associated with the Company, directly or indirectly, in any capacity 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 between himself and the Company whether temporary or permanent, that allows such person, directly or indirectly, access to Unpublished Price Sensitive Information or is reasonably expected to allow such access. Page 4 of 31 (ii) 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, (a) a relative of connected persons specified in clause (i); or (b) a holding company or associate company or subsidiary company; or (c) an intermediary as specified in Section 12 of the Act or an employee or director thereof; or (d) an investment company, trustee company, asset management company or an employee or director thereof; or (e) an official of a stock exchange or of clearing house or corporation; or (f) 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 (g) a member of the Board of directors or an employee, of a public financial institution as defined in section 2 (72) of the Companies Act, 2013; or (h) an official or an employee of a self-regulatory organization recognised or authorized by the Board; or (i) a banker of the Company; or (j) a concern, firm, trust, Hindu undivided family, company or association of persons wherein a director of the Company or his/her relative or banker of the Company, has more than ten per cent, of the holding or interest; (k) a firm or its partner or its employee in which a connected person specified in sub-clause (i) of clause (d) is also a partner; or (l) a person sharing household or residence with a connected person specified in sub-clause (i) of clause (d) 2.7 “Designated Person(s)” means a) Promoter(s) and me [Showing first 8,000 characters — download PDF for full document]