Updates

Date: 03 November 2026 To, To, National Stock Exchange of India Limited BSE Limited Exchange Plaza, C-1, Block G, Phiroze Jeejeebhoy Towers Bandra Kurla Complex, Dalal Street, Bandra (E), Mumbai – 400 051 India Mumbai – 400 001 India Symbol: BLSPOLY S crip Code: 545011 Subject: Intimation pursuant to Regulations 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“SEBI PIT Regulations”) Dear Sir/Madam, Pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended (“SEBI PIT Regulation”), please find enclosed herewith the “Policy on Code of Practices & Procedures for Fair disclosures of UPSI”(“Code”) approved and adopted by the Board of Directors of the Company under Regulation 8(1) of the SEBI PIT Regulations. In compliance with the aforesaid regulations, the aforesaid Code is also available on the Company's website at Policies section at viz. https://blspolymers.com/ We request you to kindly take the same on record. Thanking You, Yours Sincerely, For BLS Polymers Limited Neha Kumar Sunit Company Secretary and Compliance Officer Membership No.: A28210 Place: Mumbai Enc: -As above POLICY ON CODE OF PRACTICES & PROCEDURES FOR FAIR DIS CLOSURE OF UP SI BLS POLYMERS LTD. POLICY ON CODE OF PRACTICES & PROCEDURES FOR FAIR DISCLOSURE OF UPSI TABLE OF CONTENTS Contents Page No. 1. CHAPTER – I PRELIMINARY……………………………………...04 - 07 2. CHAPTER – II PRINCIPLES AND OBLIGATIONS AND 2.1. The Principles and Obligation………………………………...07 - 07 3. CHAPTER – III PRACTICES AND PROCEDURES……………...07 - 12 3.1. 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……………………………….07 - 08 3.2. Uniform and universal dissemination of UPSI to avoid selective disclosure ………………………………………08 - 08 3.3. Designation of a senior officer as a Chief Investor Relations Officer to deal with dissemination of information and disclosure of UPSI……………………………08 - 08 3.4. Prompt dissemination of UPSI that gets disclosed selectively, inadvertently, or otherwise to make such information generally available………………………….08 - 08 3.5. Appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities…………………….08 - 09 3.6. Ensuring that information shared with analysts and research personnel is not UPSI…………………………….09 - 09 3.7. Developing 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……………………….09 - 10 2 | Page BLS POLYMERS LTD. POLICY ON CODE OF PRACTICES & PROCEDURES FOR FAIR DISCLOSURE OF UPSI 3.8. Handling of all UPSI on a need-to-know basis………………10 - 10 3.9. Policy for determination of “Legitimate Purposes"………....10 - 11 3.10. Structured Digital Database…………………………………..11 - 11 3.11. Disclosure of the Code on Public Domain…………………....11 - 11 3.12. Chief Investor Relations Officer……………………………...11 - 11 3.14. Scope and Limitation………………………………………….12 - 12 3 | Page BLS POLYMERS LTD. POLICY ON CODE OF PRACTICES & PROCEDURES FOR FAIR DISCLOSURE OF UPSI CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UPSI [Pursuant to Regulation 8 of SEBI (Prohibition of Insider Trading) Regulations, 2015] CHAPTER – I PRELIMINARY 1.1. Introduction This Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information is framed as per Model Code prescribed under Schedule A of the SEBI (Prohibition of Insider Trading) Regulations, 2015 1.2. Definitions a) “Act” means the Securities and Exchange Board of India Act, 1992 (15 of 1992); b) “Board” or “Board of Directors” means the board of directors of BLS Polymers Limited. c) “Company” means BLS Polymers Limited. d) “Compliance Officer” means any senior officer, designated so and reporting to the Board of Directors or head of the organization, in case Board is not there, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under the Regulations 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 codes specified in the Regulations under the overall supervision of the Board of Directors of the Company or the head of an organization, as the case may be; The term “financially literate” shall mean a person who has the ability to read and understand basic financial statements i.e. balance sheet, profit and loss account, and statement of cash flows. e) “Connected Person” means any person who is or has during the six months prior to the concerned act, been associated with a company, directly or indirectly, in any 4 | Page BLS POLYMERS LTD. POLICY ON CODE OF PRACTICES & PROCEDURES FOR FAIR DISCLOSURE OF UPSI 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. f) “Deemed to be a Connected Person”: means the persons falling within the following categories shall be deemed to be connected persons unless the contrary is established: i. An immediate relative of Connected Persons specified in clause (2.e); or ii. A holding company or associate company or subsidiary company; or iii. An intermediary as specified in Section 12 of the Act or an employee or director thereof; or iv. An investment company, trustee company, asset management company or an employee or director thereof; or v. An official of a stock exchange or of clearing house or corporation; or vi. 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 vii. 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 (“Companies Act, 2013”); or viii. An official and/or employee of a self-regulatory organization recognized or authorized by the Board; ix. A banker of the Company; or x. A concern, firm, trust, Hindu undivided family, company or association of persons wherein a director of the Company or his immediate relative or banker of the Company, has more than ten per cent, of the holding or interest. g) “Designated Persons” will mean and include: i. All the Directors of the Company; ii. Promoters and members of Promoter Group; iii. All employees of the Company coming under the Grade 1, 2 and 3 (as per the policy of the Company) and its material subsidiaries. iv. Key Managerial Personnel (as defined in accordance with the Companies Act, 2013 and applicable accounting standards) of the Company; v. All employees of the ‘Finance’, ‘Accounts’, ‘Audit’, ‘Taxation’, ‘Legal and Secretarial’, ‘Corporate Communication’ functions of Corporate Finance, Information Technology, irrespective of their grade; 5 | Page BLS POLYMERS LTD. POLICY ON CODE OF PRACTICES & PROCEDURES FOR FAIR DISCLOSURE OF UPSI vi. employees of such other functions of the Company who are in possession or likely to be in possession of Unpublished Price Sensitive Information; vii. Directors, Chief Executives and employees up to 2 (two) levels below the Managing Director, including the head of Accounts and Finance (by whatever name called) of the Company and material subsidiaries of the Company; viii. Personal assistants, if any, o [Showing first 8,000 characters — download PDF for full document]