Updates

Date: 05th November, 2026 To To Listing Department Listing Department BSE Limited National Stock Exchange of India Limited Phiroze Jeejeebhoy Towers Exchange Plaza, C-1, Block G Dalal Street Bandra Kurla Complex Mumbai – 400 001 Bandra (E), Mumbai – 400 051 Script Code: 544957 (BSE) Company Code: GERMAN (NSE) Sub: Reporting of violation related to Code of Conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015 Dear Sir/ Madam, This is with reference to the Company’s Code of Conduct for Prevention of Insider Trading to regulate, monitor and report trading by Designated Persons and other Connected Persons as per the requirements of the SEBI (Prohibition of Insider Trading) Regulations, 2015. Please find enclosed herewith the report related to the violation of Company’s Code of Conduct for Prevention of Insider Trading by a Designated Person, in the format prescribed by SEBI vide its Circular HO/43/15/12(3)2025-ISD-POD2/I/11734/2026 dated May 15, 2026 as Annexure -A. Kindly take the above information on record. Thanking you, Yours faithfully, For, German Green Steel and Power Limited Abira Mansuri Company Secretary & Compliance Officer Membership No.: A42410 Annexure -A Report by German Green Steel and Power Limited for violations related to Code of Conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015 Particulars Details Name of the listed company / Intermediary / G Fiduciary German Green Steel and Power Ltd ☒ Listed Company Please tick appropriate checkbox – Reporting 2 ☐ Intermediary in capacity of: ☐ Fiduciary 3A(i) Name of the Designated Person (DP) Mr. Mushirulhaq Inamulhaq Iraki 3A(ii) PAN of the DP AMMPI9288E 3A(iii) Designation of DP Designated Person / Promoter Group 3A(iv) Functional Role of DP Promoter Group Whether DP is Promoter or belongs to 3A(v) Yes (Member of Promoter Group) Promoter Group Details where reporting is for immediate 3B Yes relative of DP 3B(i) Name of the immediate relative of DP Mrs. Sanya Zafar 3B(ii) PAN of the immediate relative of DP AEPPZ3202A Name of the Company: German Green Steel and Power Ltd 3C(i) Name of the scrip BSE Scrip Code: 544957 NSE Symbol: GERMAN On October 15, 2026, Mrs. Sanya Zafar, spouse of Mr. Mushirulhaq Inamulhaq Iraki, purchased 7,500 equity shares of the Company for an aggregate consideration of ₹9,57,075/-. Subsequently, on October 29, 2026, she 3C(ii) No. of shares traded and value (date-wise) purchased an additional 3,000 equity shares for an aggregate consideration of ₹3,06,660/-. Accordingly, she purchased a total of 10,500 equity shares for an aggregate consideration of ₹12,63,735/-. In case value of trade(s) is more than Rs. 10 lacs in a calendar quarter Date of intimation of trade(s) by concerned DP / Director / Promoter / Promoter Group to 3D(i) Not applicable Company under Regulation 7 of the SEBI (PIT) Regulations, 2015 Not Applicable, as the Company is not required to make manual filings of disclosures Date of intimation of trade(s) by Company to under Regulation 7(2)(a) and (b) of the PIT 3D(ii) stock exchanges under Regulation 7 of the Regulations, pursuant to SEBI Circular No. SEBI (PIT) Regulations, 2015 SEBI/HO/ISD/ISD/CIR/P/2021/617 dated August 13, 2021. Trading (Purchase) by Designated Person Details of violations observed under Code of Relative (Spouse) during trading window Conduct closure period. The Company has issued a written warning to Mr. Mushirulhaq Inamulhaq Iraki and Mrs. Sanya Zafar not to repeat any such actions in the future and to ensure strict compliance with the SEBI (Prohibition of Insider Trading) Action taken by Listed Company / Intermediary / 5 Regulations, 2015 and the Company’s Code of Fiduciary Conduct. Further, it is proposed to transfer an amount equivalent to 2% of the aggregate transaction value, i.e. approximately ₹25,200/-, to the Prime Minister's National Relief Fund (PMNRF). The Compliance Officer sought explanations from Mr. Mushirulhaq Inamulhaq Iraki and Mrs. Sanya Zafar, who admitted the violation and clarified that the transactions were inadvertent and not intended to violate the Company's Code of Conduct or the SEBI (Prohibition of Insider Trading) Regulations, 2015 ("SEBI PIT Regulations"). They further confirmed that they were not in possession of or had access to any unpublished price-sensitive information (UPSI) at the time of the transactions and expressed regret for the Reasons recorded in writing for taking action inadvertent violation. stated above Considering that the Company is newly listed and this is the first such instance, warning letters have been issued to both individuals, advising them to ensure strict compliance in future. The Company maintains a zero-tolerance approach towards violations of the Code of Conduct and SEBI PIT Regulations. Further, it is proposed to transfer an amount equivalent to 2% of the aggregate transaction value, i.e. approximately ₹25,200/-, to the SEBI Invertor Protection and education Fund (SEBI IPEF). Details of previous instances of violations, if any, 7 Nil since last financial year i) Mode of transfer to SEBI – IPEF (Net Banking / NEFT / RTGS / Debit Cards / UPI): If any amount collected for Code of Conduct 8 Transaction ID: 261105291794997 violation(s) (ii) Details of transfer / payment: Not Applicable The Audit Committee at its meeting held on 9 Any other relevant information November 05, 2026, took note of the same. Thanking you, Yours faithfully, For, German Green Steel and Power Limited Abira Mansuri Company Secretary & Compliance Officer Membership No.: A42410