Updates

Ref: 03/SE/LC/2026-27 Date: October 23, 2026 To, To, National Stock Exchange of India Limited BSE Limited (“BSE”) (“NSE”) Listing Department Listing Department Corporate Relationship Department Exchange Plaza, C-1 Block G, Bandra Kurla Phiroze Jeejeebhoy Towers, Complex Bandra (East), Mumbai – 400051 Dalal Street, Fort, Mumbai - 400 001 NSE Scrip Symbol: SMT BSE Scrip Code: 545001 ISIN: INE356Y01018 ISIN: INE356Y01018 Subject: Intimation under Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Dear Sir/ Madam, Pursuant to Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“SEBI PIT Regulations”), please find attached herewith the “Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information” framed under Regulation 8 (1) of the SEBI PIT Regulations (“Code”). In compliance with the SEBI PIT Regulations, the aforesaid Code is also available on the Company's website at smtpl.com This is for your information and records. Thanking you, For Sahajanand Medical Technologies Limited Bhargav Dhirajlal Kotadia Managing Director & Chief Executive Officer DIN: 06575042 Encl: Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information SAHAJANAND MEDICAL TECHNOLOGIES LIMITED CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION Name Code for Fair Disclosure of UPSI Approval Date November 12, 2025 Version Version 1 Effective date of the Policy November 12, 2025 1. Introduction The Board of Directors (“Board”) of Sahajanand Medical Technologies Limited (“Company”) has formulated and adopted this Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Code”) in compliance with Regulation 8(1) read with Schedule A of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 as amended from time-to-time (“PIT Regulations”). 2. Objectives The objective of this Code is to: - lay down the practices and procedures for fair disclosure of Unpublished Price Sensitive Information (“UPSI”); - set out processes to preserve the confidentiality of UPSI and to prevent its misuse; - provide a framework to ensure timely and adequate disclosure of UPSI which could impact the price of the Company’s securities and to maintain uniformity, transparency and fairness in dealing with all its stakeholders in compliance with PIT Regulations. 3. Definitions & Interpretations All the words and expressions used herein and not defined shall have the same meaning as ascribed to them in the PIT Regulations, and the Code of Conduct for Prohibition of Insider Trading (“Insider Code”). 4. Chief Investor Relations Officer 4.1. Company Secretary & Compliance Officer or any senior person authorised by Managing Director (“MD”) & Chief Executive Officer (“CEO”) shall act as a Chief Investor Relations Officer (“CIRO”) for the purpose of this Code. 4.2 CIRO would be responsible for ensuring uniform and universal dissemination of information and disclosure of UPSI at an appropriate time, so as to avoid selective disclosure. 5. Principles of Fair Disclosure: 5.1 Prompt public disclosure of UPSI The Company shall endeavour to make prompt public disclosure of UPSI as soon as it has credible and concrete information by reporting it to the stock exchanges on which Securities of the Company are listed as well as by hosting the same on the official website of the Company, in order to make such information generally available. For the purposes of timely disclosures of UPSI and other material events, the Company will follow the timelines as stipulated in the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015. 5.2 Uniform and universal dissemination of UPSI (i) The UPSI shall be disseminated uniformly and universally to all stakeholders through Stock Exchanges and by posting the same on official website of the Company. (ii) The Company shall use its best endeavors to avoid selective disclosure of UPSI, however in the event there is an accidental or inadvertent disclosure of UPSI, it should be brought to the notice of the CIRO and the CIRO shall forthwith make the said information as Generally Available Information. 5.3 Response to regulatory authorities / market rumours The Company shall provide an appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities. In this regard, the general policy of the Company shall be not to respond to market rumour or speculations unless required by the regulatory authorities and necessary in line with the applicable regulatory framework. However, any rumours that have or is likely to have a substantial effect on the price of the Company’s securities shall be dealt with by the CIRO after necessary due-diligence, in accordance with the PIT Regulations. 5.4 Interactions with analysts, investors and research personnel (i) The Company shall ensure that information shared with analysts, research personnel and institutional investors is not UPSI. (ii) If any UPSI is shared with analysts, research personnel and institutional investors, the same should be simultaneously made public by way of disclosure to the stock exchanges as well as on the official website of the Company. (iii) The Company shall develop best practices to make transcripts or records of proceedings of meetings with analysts and other investor relations conferences on the official website to ensure official confirmation and documentation of disclosures made. 5.5 Handling of UPSI on a Need-to-Know basis (i) The Company shall put in a system to ensure handling all UPSI on a need-to-know basis. UPSI shall be made available to relevant persons / entities strictly on a need-to-know basis and in line with any other applicable codes, policies and procedures of the Company, including, specifically, this Code and the Insider Code. (ii) For sharing of UPSI within the Company or with external parties for genuine business purpose, appropriate wall-crossing procedure as stipulated in the Insider Code shall be followed. Further, all compliances in terms of the PIT Regulations will be duly observed. “Need-to-know” basis shall mean: a. only relevant information is shared with the recipient which will be used by the recipient for performance of his duty(s) or obligation under any contract or law, etc. and b. the person sharing the information is legally or contractually obligated to share the information to recipient. 6. Policy for Determination of Legitimate Purpose 6.1. Pursuant to Regulation 3(2A) of PIT Regulations, “Legitimate Purpose” shall include sharing of UPSI in the ordinary course of business by an insider with 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 of PIT Regulations. 6.2. The Company prohibits all Directors, Designated Persons, Employees and other Insiders from: (i) communicating, providing, or allowing access to any UPSI relating to the Company to any person including other insiders (ii) procuring or causing the communication of UPSI relating to the Company from any person including other insiders except where such communication is in furtherance of Legitimate Purpose (as defined hereinabove), performance of duties or discharge of legal obligations. 6.3. Any person in receipt of UPSI pursuant to a “Legitimate Purpose” shall be considered an “Insider” for purposes of PIT Regulations and the Insider Code and such persons shall be liable to maintain confidentiality of such UPSI in compliance with the PIT Regulations. 6.4. Insider may also be required to execute an agreement to contract [Showing first 8,000 characters — download PDF for full document]