Amendments to the PIT Policies

November 04, 2026 Ref: NIVABUPA/EQ/2026-27/54 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 Mumbai – 400 001 Symbol: NIVABUPA Scrip Code: 544286 Sub: Amendment and Consolidation of the a) Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (‘UPSI’); and b) the Policy for Inquiry in Case of Leak or Suspected Leak of UPSI, collectively named as ‘Policy’. Ref: Regulation 8(2) of SEBI (Prohibition of Insider trading) Regulations, 2015 (‘SEBI PIT Regulations’) Dear Sir/Madam, We hereby inform you that the Board of Directors of the Company, at its meeting held today i.e. on Wednesday, November 04, 2026, inter alia, has approved amendments to the, a) Code of Practices and Procedures for Fair Disclosure of UPSI; and b) the Policy for Inquiry in Case of Leak or Suspected Leak of UPSI, formulated under the SEBI PIT Regulations. The Board also approved the consequent consolidation into a single comprehensive Policy. The updated and consolidated Policy is enclosed herewith as Annexure-I and will also be made available on the website of the Company at www.nivabupa.com. The meeting of the Board commenced at 02:30 P.M. (IST) and concluded at 03:10 P.M. (IST). Kindly take the same on records. Thanking you, Yours Sincerely, For Niva Bupa Health Insurance Company Limited Aparna Sharma Company Secretary and Compliance Officer Niva Bupa Health Insurance Company Limited IRDAI Registration No. 145 | CIN: L66000DL2008PLC182918 Registered Office: C-98, First Floor, Lajpat Nagar, Part 1, Delhi-110024 Corporate Office: 3rd Floor, Capital Cyber scape, Golf Course Extension Road, Sector-59, Gurugram-122101, Haryana. Website: www.nivabupa.com | Email id: investor@nivabupa.com I Tel: +91-124-6354900 NIVA BUPA HEALTH INSURANCE COMPANY LIMITED (“the Company”) Policy Name Part A - Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information; And Part B - Policy for Inquiry in case of leak or suspected leak of Unpublished Price Sensitive Information Approved By Audit Committee & Board of Directors Issued & Owned By Company Secretary Version History Version Approval date V.01 May 10, 2024 V.02 May 07, 2025 V.03 November 04, 2026 Prior to this, the Company maintained two separate policies governing Unpublished Price Sensitive Information ("UPSI"). To streamline operational compliance and regulatory alignment under the SEBI (Prohibition of Insider Trading) Regulations, 2015, these policies have been integrated into a comprehensive single policy divided into Part A (Fair Disclosure Code) and Part B (Policy for Inquiry in Case of Leak or Suspected Leak of UPSI). Background & Purpose Part – A Regulation 8(1) read with Schedule A of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations 2015 (“SEBI PIT Regulations”) requires the Company to formulate a Code of practices and procedures for fair disclosure of unpublished price sensitive information (“Code”), forms as Part A of this document. This Code sets out the principles and practices the Company shall follow to ensure uniform, transparent, and timely disclosure of Unpublished Price Sensitive Information (“UPSI”) to prevent selective disclosure. The Code incorporates the principles laid down in Schedule A of the SEBI PIT Regulations and reinforces the Company’s commitment to transparent and fair disclosure practices. The Company shall maintain adequate and effective internal controls and institutional mechanisms to ensure compliance with SEBI PIT Regulations, including identification of UPSI, restriction of access on a need-to-know basis, and periodic review of compliance controls by the Compliance Officer. The internal controls shall include the controls specified under Regulation 9A(2), including identification of employees having access to UPSI as Designated Persons, identification and protection of UPSI, restrictions on its communication or procurement, maintenance of lists of persons with whom UPSI is shared, service of confidentiality notices or execution of confidentiality agreements, and periodic review of the effectiveness of such controls. Part -B Regulation 9A (5) of the SEBI PIT Regulations requires Board of Directors of a listed company to formulate written Policy and procedures (“Policy”), for inquiry in case of leak or suspected leak of unpublished price sensitive information and to initiate appropriate inquiries upon becoming aware of such leak or suspected leak Part B of this document has been formulated in accordance with the said requirement. The purpose of Part B is to lay down a structured mechanism for investigating, inquiring into, and taking appropriate disciplinary action against any actual or suspected leak of UPSI, thereby safeguarding confidentiality and ensuring regulatory compliance. Definitions and Interpretations Words and expressions used but not defined in this Code and Policy shall have the same meaning assigned to them in the SEBI (Prohibition of Insider Trading) Regulations, 2015, the Securities and Exchange Board of India Act, 1992, the Securities Contracts (Regulation) Act, 1956, the Depositories Act, 1996 or the Companies Act, 2013 and the rules and regulations made thereunder, as the case may be or in any amendment thereto. Inquiry Committee There shall be a Committee called the Inquiry Committee ("Committee") comprising of: - Chief Financial Officer; - Chief Compliance Officer - Chief Risk Officer; - Chief Human Resource Officer; or - Any other person nominated by Managing Director & CEO. A member who is the subject of the inquiry, is connected with the matter, has reported the matter, or may reasonably be perceived to have a conflict of interest shall recuse from the inquiry. The Inquiry Committee may co-opt an alternate member or direct that the inquiry be conducted by an independent external professional. The quorum shall be three members. Decisions shall be taken by majority and the reasons for material decisions shall be recorded. The Company Secretary & Compliance Officer of the Company shall act as Secretary to the Committee. The Committee shall also decide the suitable actions under Clause 12 of Code of Conduct to regulate, monitor and report trading by its Designated Persons and immediate relatives of designated persons. This Committee shall report the matter of breach or violation under this Code to the Audit Committee/ Board, in accordance with this Policy. Further, such Committee will also concern itself with any leak / suspected leak of unpublished price sensitive information and inquiries as laid out in the Policy on procedures to be conducted while conducting an inquiry in the event of leak or suspected leak of unpublished price sensitive information. Part A - Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Code”) Designation and Role of Chief Investor Relations Officer (“CIRO”) The Company Secretary & Compliance Officer of the Company shall act as the Chief Investor Relations Officer (“CIRO”) for the purpose of this Code or in absence of CIRO, such other Official as may be nominated by the Board. The CIRO may be contacted by e-mail at investor@nivabupa.com. The CIRO shall be responsible for ensuring dissemination of information and disclosure of UPSI at appropriate times, so as to avoid selective disclosure. Disclosures under the Code 1. The CIRO shall ensure:  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.  uniform and universal dissemination of UPSI to avoid selective disclosure; and  prompt dissemination of UPSI that gets disclosed inadvertently or selectively or otherwise to ensure that the information is made generally available. 2. It is clarifie [Showing first 8,000 characters — download PDF for full document]