Updates

United Spirits Limited Registered Office: UB Tower #24, Vittal Mallya Road, Bengaluru 560 001 Tel: +91 80 2221 0705 Fax: +91 80 2224 5253 www.diageoindia.com 28th October 2026 BSE Limited The National Stock Exchange of India Limited Listing Department Exchange Plaza, C-1 Block G, Phiroze Jeejeebhoy Towers, Bandra Kurla Complex, Dalal Street, Mumbai – 400 001 Bandra East, Mumbai – 400 051 Scrip Code: 532432 Scrip Code: UNITDSPR Dear Sirs, Sub: Intimation under Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“SEBI PIT Regulations”). In compliance with the requirements of Regulation 8(2) of SEBI PIT Regulations as amended from time to time, this is to inform you that the Board of Directors of the Company at its meeting held today, inter-alia has reviewed and amended “Code of Internal Procedures, and Conduct for Regulating, Monitoring and Reporting Trading by Insiders”. A copy of the same is enclosed herewith for your record. Amended Code of Internal Procedures, and Conduct for Regulating, Monitoring and Reporting Trading by Insiders is also being made available on the Company’s website at www.diageoindia.com. Thank you, For United Spirits Limited Pragya Kaul Company Secretary and Compliance Officer Encl: As above Corporate Identity Number: L01551KA1999PLC024991 contactus.india@diageo.com United Spirits Limited UNITED SPIRITS LIMITED CODE OF INTERNAL PROCEDURES, AND CONDUCT FOR REGULATING, MONITORING AND REPORTING TRADING BY INSIDERS Content: 1. Introduction 2 2. Definitions and Clarifications 2 3. Handling of UPSI 2 4. Trading in Securities 4 5. Disclosures 8 6. Compliance officer 9 7. Maintenance of SDD 9 8. Internal Control System 10 9. Review of Internal Control System 10 10. Penalties 10 11. Miscellaneous 10 12. Protection to informant 11 13. Applicability and effective date 11 Schedules 16 Annexures 20 Approved by The Board of Directors of United Spirits Limited Version approved on 28th October 2026 Version effective from 29th October 2026 Page 1 of 2 United Spirits Limited 1 INTRODUCTION Pursuant to the Securities & Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“Regulations”), the Board of Directors formulated and adopted the Code of Internal Procedures and Conduct for regulating, monitoring and reporting Trading by Insiders (hereinafter referred to as “the Code” or “Code ”) at its meeting held on 23rd July 2015 and thereafter amended the Code from time to time in compliance with the amendments to the Regulations. 2 DEFINITIONS, APPLICABILITY AND CLARIFICATIONS 2.1 Terms used in this Code (that have their first letter capitalized) have the meanings given in Schedule 1, unless the context otherwise requires. Terms that are not defined in this Code have the meanings given in the Regulations. 2.2 This Code applies to all promoters, members of promoter group, directors, Designated Persons and their Immediate Relatives who are in possession or access to UPSI as envisaged by the Regulations. This Code deals with: (a) the handling of Unpublished Price Sensitive Information (‘UPSI’) (see para 3 below); (b) trading in securities by Insiders (see para 4 below); and (c) disclosures required to be made by certain persons with respect to their holding of and trading in securities of the Company (see para 5 below). Temporary classification of an employee in the category of two levels below Chief Executive Officer merely due to exit/movement of his/her line manager or skip-level manager from the Company or within the Company, be excluded from being included as ‘Designated Persons’. 2.3 If any person requires clarifications regarding this Code or the Regulations, e.g., whether any information constitutes UPSI, whether a trade requires pre-clearance or triggers disclosures, shall seek immediate clarification from the Secretarial Department or the Compliance Officer appointed under this Code (see para 6 below). 3 HANDLING OF UNPUBLISHED PRICE SENSITIVE INFORMATION 3.1 All Unpublished Price Sensitive Information (hereinafter referred to as “UPSI) must be handled on a need-to-know basis only and no UPSI shall be communicated to any person except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations. Each Executive Committee (ExCom) Members shall ensure ‘Chinese Walls’ are used to manage and control the dissemination of UPSI by employees within Page 2 of 3 United Spirits Limited their departments, and with employees in other departments, so that all UPSI is disseminated or accessible on a need-to-know basis only. The members of ExCom shall ensure that no employee below such rank as they may decide based on the need to know such information, shall be provided access rights to information in any other department, without the approval of the department head of the concerned department in which access rights are granted. 3.2 Policy for determination of legitimate purposes Sharing of Unpublished Price Sensitive Information shall only be for legitimate purpose which shall include the following - sharing of unpublished price sensitive information in the ordinary course of business, by an insider with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, rating agencies, statutory authorities, regulatory bodies, industry associations or other advisors or consultants, parent or holding Company(ies), its affiliates and employees, including, without limitation, for the purpose of preparation of consolidated accounts on a group-wide basis, rendering services on a shared business services model and such other business activities as may be approved by the Board or Stakeholder Relationship & General Committee of the Board from time to time, provided that such sharing has not been carried out to evade or circumvent the prohibitions of these regulations. 3.3 Any person in receipt of UPSI pursuant to a “legitimate purpose” as per 3.2 above shall be considered an “insider” for purposes of these regulations and due notice shall be given by the insider sharing such information to such persons to maintain confidentiality of such UPSI in compliance with this code. 3.4 All employees in possession of UPSI should ensure that relevant files are kept secure and under lock and key. When transmitting or sharing UPSI through electronic media, such information should be clearly marked ‘Confidential’. 3.5 Process for Investigation in case of leak / suspected leak of Unpublished Price Sensitive Information i. The Committee shall comprise of the Chief Financial Officer, Chief Human Resources Page 3 of 4 United Spirits Limited Officer, General Counsel and Company Secretary and Compliance Officer (“CO”) (‘Members’). Any three members of the Committee shall form quorum. The members shall have the authority to initiate appropriate inquiries/investigations on becoming aware of leak of UPSI or suspected leak of UPSI and shall inform the Board promptly of such leaks, inquiries and findings of such inquiries together with the recommendation for remedial action and recommendation for disciplinary action, if any. While investigating or inquiring into the issues of leakage of information, the members shall have authority to engage external parties, consultants, experts and seek statements of employees and other stakeholders including cross examination, as may be necessary. ii. Speak up/ whistleblower policy of the Company shall also include such leakage of information and employees can make use of such policy to report instances of leak of UPSI. iii. If an inquiry has been initiated in case of leak of UPSI or suspected leak of UPSI. The CO along with anyone of the Members shall make a report of the findings of the inquiry and investigation and initiate actions to be taken pursuant to the recommendation(s) of the Members and also place the summary of the findings before the Audit Committee at the next A [Showing first 8,000 characters — download PDF for full document]