Amendment to Code for Prohibition of Insider Trading and Fair Disclosure of Unpublished Price Sensitive Information (UPSI) of the Company under SEBI (Prohibition of Insider Trading), Regulations, 2015

July 24, 2026 BSE Limited National Stock Exchange of India Limited Phiroze Jeejeebhoy Towers, Exchange Plaza, Plot C/1, G Block, Dalal Street, Bandra – Kurla Complex, Fort, Mumbai – 400 001 Bandra – (East), Mumbai – 400 051 Scrip Code: 543367 Trading Symbol: PARAS Dear Sir/Madam, Subject: Amendment to Code for Prohibition of Insider Trading and Fair Disclosure of Unpublished Price Sensitive Information (UPSI) of the Company. Pursuant to the provisions of Regulations 8 and 9 read with Schedules A and B of the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended, we wish to inform you that the Board of Directors of the Company, at its meeting held on July 24, 2026, has approved amendments to Code for Prohibition of Insider Trading and Fair Disclosure of Unpublished Price Sensitive Information of the Company (“the PIT Code”). The amended policy has been formulated in accordance with the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time. A copy of the amended Policy is enclosed herewith. The same has also been uploaded on the Company’s website at the link https://parasdefence.com/investors You are requested to disseminate the above information on your respective websites. Thanking you, For Paras Defence and Space Technologies Limited Minal Bhate Company Secretary and Compliance Officer Membership No.: A20188 Encl.: As above CODE FOR PROHIBITION OF INSIDER TRADING AND FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION (UPSI) IN THE SECURITIES PARAS DEFENCE AND SPACE TECHNOLOGIES LIMITED comprising PART B: “Code of Conduct for Regulating, Monitoring and Reporting of Trading by Designated Persons and their Immediate Relatives” (framed under Regulation 9(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015) PART C: “Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI)” (framed under Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015) Document Control Document Title Code for Prohibition of Insider Trading and Fair Disclosure of UPSI in the Securities of Paras Defence and Space Technologies Limited Version 3.0 Effective Date 07th March, 2020 Amendment Date 24th July, 2026 Document Owner Secretarial and Compliance Document Approver Board of Directors CODE FOR PROHIBITION OF INSIDER TRADING AND FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION (UPSI) PART A- GENERAL PROVISIONS A1. PREAMBLE This Code, titled the “Code for Prohibition of Insider Trading and Fair Disclosure of UPSI in the Securities of Paras Defence and Space Technologies Limited” (the "Code") is formulated under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (the “SEBI PIT Regulation”), as amended from time to time. Pursuant to regulation 8(1) and 9(1) of the SEBI PIT Regulations, the Company hereby adopts this Code, comprising Part B (Code of Conduct for Regulating, Monitoring and Reporting of Trading by Designated Persons and their Immediate Relatives, framed under Regulation 9(1)) and Part C (Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information, framed under Regulation 8(1)), together with this Part A containing provisions of general application to both Part B and Part C. A2. APPLICABILITY & OBJECTIVE This Code shall be applicable to Connected Persons, Insiders, Designated Persons and their Immediate Relatives and includes any person in possession of or having intermittent access to UPSI. This Code aims to preserve the strict confidentiality of all inside corporate records, to enforce uniform, non-selective public disclosure of market-moving events, to prohibit unfair market abuse, short-swing trading, and illicit insider transactions and to regulate, monitor and report trading by Connected Persons, Insiders, Designated Persons and their Immediate Relatives to comply with SEBI PIT Regulations, as amended from time to time. A3. DEFINITIONS (i). “Act” means the Securities and Exchange Board of India Act, 1992. (ii). “Board” means the Board of Directors of the Company. (iii). “CODE” shall mean this Code, comprising Part B (Code of Conduct for Regulating, Monitoring and Reporting of Trading by Designated Persons and their Immediate Relatives, framed under Regulation 9(1) of the SEBI PIT Regulations) and Part C (Code of Practices and Procedures for Fair Disclosure of UPSI, framed under Regulation 8(1) of the SEBI PIT Regulations), read together with this Part A. (iv). “Company” or “PARAS” means Paras Defence and Space Technologies Limited. (v). “Compliance Officer” means any senior officer, designated so and reporting to the Board of Directors, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under the Insider Trading Regulations, and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules of preservation of Unpublished Price Sensitive Information, monitoring of trades and the implementation of the codes specified under the Insider Trading Regulations under the overall supervision of the Board. (vi). “Connected Person” means: Page 2 of 37 a) any person who is or has during the 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. b) 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 Relative of Connected Persons specified in clause (a) above; or ▪ a holding company or associate company or subsidiary company; or ▪ an intermediary as specified in Section 12 of the Securities and Exchange Board of India Act, 1992, as amended or an employee or director thereof; or ▪ an investment company, trustee company, asset management company or an employee or director thereof; or ▪ An official of a stock exchange or of clearing house or corporation; or ▪ 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 ▪ 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, as amended; or ▪ An official and/or employee of a self-regulatory organization recognized or authorized by the Board; ▪ A banker of the Company; or ▪ A concern, firm, trust, Hindu undivided family, company or association of persons wherein a director of the Company or his relative or banker of the Company, has more than ten per cent, of the holding or interest. ▪ a firm or its partner or its employee in which a connected person specified in clause (a) above. ▪ a person sharing household or residence with a connected person specified in clause (a) above. Provided that the onus of establishing that a Connected Person was not in possession of Unpublished Price Sensitive Information shall rest entirely on such Connected Person (vii). “Designated Person” shall mean and include the following categories of persons, specified by the Board of Directors in consultation with the Compliance Officer on the basis of their functional role and access to UPSI: a) the Promoters, Members of the Promoter group and all Directors of the Company (Executive, Non-Executive and Independent, whether Whole-Time or not); b) the Chief Executive Officer (CEO), Ma [Showing first 8,000 characters — download PDF for full document]