Amended Code of Conduct for Insider Trading and Fair Disclosure of Unpublished Price Sensitive Information

FIOND.A Honda India Power Products Limited Head Office & Works: Plot No. 5, Sector-41, (Kasna) Greater Naida Industrial Development Area, Distt. Gautam Budh Nagar (U.P.) Pin-201310 Ref: HIPP/SE/2026-27/43 Tel. : +91-120-2590 100 Fax : +91-120-2590 350 November 05, 2026 Website: www.hondaindiapower.com CIN: L40103DL2004PLC203950 E-mail: ho.mgt@hspp.com Corporate Relationship Department BSE Limited Phiroze Jeejeebhoy Towers, 25th Floor , Dalal Street ' Fort , Mumbai -400001 Listing Department National Stock Exchange oflndia Limited 5th Floor, Exchange Plaza, Bandra Kurla Complex, Bandra (E), Mumbai-400051 Scrip Code: NSE HONDAPOWER BSE 522064 Sub: Code of Conduct for Insider Trading and Fair Disclosure of Unpublished Price Sensitive Information Dear Sir/Madam, Pursuant to Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 ("PIT Regulations"), read with SEBI Master Circular No. HO/4 3/15/l 2(3 )2025-ISD-POD2/I/l l 734/2026 dated May 15, 2026, as amended, we wish to inform you that the Board of Directors of the Company, at its meeting held on November 05, 2026, has approved the amended Code of Conduct for Insider Trading and Fair Disclosure of Unpublished Price Sensitive Information, framed under Regulations 8 and 9 of the PIT Regulations. A copy of the amended Code is enclosed herewith. The above-mentioned Code shall also be available on Company's website at ww,v.honclaincliapowcr.com Kindly take the same on record. Thanking you. Yours truly, For Honda India Limited Sunita Ganjoo Company Secreta -- 1cc Officer Encl: as above Honda India Power Products Limited (Formerly Honda Siel Power Products Limited) Regd. Office: 409, DLF Tower B, Jasola Commercial Complex, New Delhi -110025 H:OND.A HONDA INDIA POWER PRODUCTS LIMITED CODE OF CONDUCT FOR INSIDER TRADING AND FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION Adopted on : May 18, 2015 Revised on : November 05, 2026 February 10, 2025 & :H:ON'D.A. PREAMBLE 1. The Securities and Exchange Board of India (“SEBI”), for protection of investors and to regulate the securities market, had formulated the SEBI (Prohibition of Insider Trading) Regulations, 2015 under the powers conferred on it under the SEBI Act, 1992. These Regulations came into force w.e.f. 15 May, 2015 (as amended from time to time) and the same are applicable to all companies whose shares are listed on Indian Stock Exchanges. 2. Regulation 9 requires the Board of Directors of every listed company and market intermediary to formulate a code of conduct to regulate, monitor and report trading by its employees and other ‘connected persons’ towards achieving compliance with the Regulations, adopting minimum standards as set out in Schedule B of the Regulations, without diluting the provisions of the Regulations in any manner. 3. The SEBI Regulations prohibit an Insider from Trading in the Securities of a Company listed on any stock exchange on the basis of unpublished price sensitive information. 4. In the above context, Honda India Power Products Limited (“HIPP”/ “Company”) has formulated this Code of Conduct for Prohibition of Insider Trading and fair disclosure of unpublished price information (“Code”). 1. DEFINITION 1.1. “Act” means the Securities and Exchange Board of India Act, 1992. 1.2. “Board” means the Securities and Exchange Board of India. 1.3. “Board of Director” means the Board of Directors of the Company. 1.4. “The Code” means this Code of Conduct formulated for Regulating, Monitoring and Reporting by Insiders under SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time. 1.5. “Company” means Honda India Power Products Limited (HIPP). 1.6. “Compliance Officer” means the Company Secretary, capable of appreciating requirements for legal & regulatory compliance under these 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 these Regulations under the overall supervision of the Board of Directors of the Company. 1.7. “Connected Person” means: i. any person who is or has been, during the six months prior to the concerned act, associated with a Company, in any capacity, directly or indirectly, 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, whether temporary or permanent, with the Company, that allows such a person, directly or :H:ON'D.A. indirectly, access to unpublished price sensitive information or is reasonably expected to allow such access. ii. 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. A relative of Connected Persons specified in clause (i); or b. A Holding Company or Associate Company or Subsidiary Company; or c. An intermediary as specified in Section 12 of the Act or an Employee or Director thereof; or d. An Investment Company, Trustee Company, Asset Management Company or an Employee or Director thereof; or e. An Official of a Stock Exchange or of Clearing House or Corporation; or f. 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 g. 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; or h. An Official or an Employee of a self-regulatory organization recognized or authorized by the Board; or i. A Banker of the Company; or j. 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 (10%), of the holding or interest. k. a firm or its partner or its employee in which a connected person specified in sub- clause (i) of clause (d) is also a partner; or l. a person sharing household or residence with a connected person specified in sub- clause (i) of clause (d); NOTE: It is intended that a connected person is one who has a connection with the Company that is expected to put him in possession of unpublished price sensitive information. Relatives and other categories of persons specified above are also presumed to be connected persons but such a presumption is a deeming legal fiction and is rebuttable. This definition is also intended to bring into its ambit persons who may seemingly not occupy any position in a company but are in regular touch with the Company and its officers and are involved in the know of the Company’s operations. It is intended to bring within its ambit those who would have access to or could access unpublished price sensitive information about any company or class of companies by virtue of any connection that would put them in possession of unpublished price sensitive information. 1.8. “Designated Persons(s)/Employee(s)” shall include: i. Every Promoter; ii. Director including Whole Time Director and Employee upto one (1) level below the Board of Directors; iii. Company and its Material Subsidiary(ies), if any; iv. Every Employee is designated as CEO and KMP; v. Every Employee is designated as Assistant General Manager and above; vi. Every Employee in the Finance & Accounts Department, Secretarial & Legal Department, IT irrespective of their role, designation etc; vii. Any other Employee/person as may be determined by the Board of Directors/Compliance Officer from time to time in consultation with the Management of the Company considering the objectives of the Code; and viii. Immediate Relatives of all the above P [Showing first 8,000 characters — download PDF for full document]