General Updates

WESTLIFE FOODWORLD LTD. Regd. Off.: 1001, Tower-3, 10th Floor • One International Center Senapati Bapat Marg • Prabhadevi • Mumbai 400 013 Tel : 022-4913 5000 Fax : 022-4913 5001 CIN No. : L65990MH1982PLC028593 Website: www.westlife.co.in | E-mail id :shatadru@mcdonaldsindia.com Date: 30th July, 2026 To To The BSE Ltd (‘the BSE’) The National Stock Exchange of India Ltd Phiroze Jeejeebhoy Towers (‘the NSE’) Dalal Street Exchange Plaza Mumbai 400 001 Bandra Kurla Complex, Bandra (East) Mumbai – 400051 Sub : Compliance with Regulations 8 (2) of the SEBI (PIT) Regulations, 2015; Code of Fair Disclosure and Code of Conduct for prevention of Insider Trading Re : Westlife Foodworld Limited (the Company): BSE Scrip Code - 505533 and NSE Scrip Code – WESTLIFE. Dear Sir/Madam, In compliance with Regulation 8 (2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, please find attached, the amended Code of Fair Disclosure and Code of Conduct of Insider Trading for the Company and its Subsidiary i.e. Hardcastle Restaurants Private Limited, adopted by Board of Directors of the Company in the Board Meeting held on 30th July, 2026. The amended policy would be available on the Company’s website on www.westlife.co.in You are requested to take the same on record. Thanking you, Yours faithfully, For Westlife Foodworld Ltd. Dr Shatadru Sengupta Company Secretary Encl : as above CODE OF FAIR DISCLOSURE CODE OF CONDUCT PREVENTION OF INSIDER TRADING WESTLIFE FOODWORLD LIMITED [Formerly known as Westlife Development Limited] AND ITS SUBSIDIARIES INCLUDING HARDCASTLE RESTAURANTS PRIVATE LIMITED TOPIC INDEX SR. NO. TOPIC PAGE NO. 1. INTRODUCTION 3 2. INITIAL DISCLOSURE 3 3. CONTINUAL DISCLOSURE 4 4. CODE OF FAIR DISCLOSURE AND CONDUC 4 5. DEFINITIONS 5 - 8 6. POLICIES 8 7. COMPLIANCE OFFICER 9 8. DUTIES OF THE COMPLIANCE OFFICER 9 - 10 9. RESPONSIBILITIES OF DESIGNATED PERSONS 10 - 13 10. TRADING WINDOW 13 – 14 11. TRADING PLAN 15 12. COMPLIANCE WITH RESPECT OF INFORMATION, TRADE, 16 - 18 TRADING WINDOW, WITH REGULATION 9 READ WITH SCHEDULE B OF THE REGULATIONS 13. OTHER REPORTING REQUIREMENTS 18 - 19 14. PRE-CLEARANCE OF TRADES 19 15. OTHER TRADING RESTRICTIONS 19 - 20 16. PENALTY FOR CONTRAVENTION OF THE CODE OF 20 CONDUCT 17. PRINCIPLES OF FAIR DISCLOSURE 20 - 21 18. INTERPRETATION 21 19. ANNEXURES 22 - 35 CODE OF FAIR DISCLOSURE AND CODE OF CONDUCT FOR WESTLIFE FOODWORLD LIMITED AND ITS SUBSIDIARIES INCLUDING HARDCASTLE RESTAURANTS PRIVATE LIMITED [Under the SEBI (Prohibition of Insider Trading) (Amendment) Regulations, 2018] INTRODUCTION: “Insider trading” means dealing in securities of a company by its directors, employees or other insiders based on unpublished price sensitive information. Such dealings by insiders erode the investors’ confidence in the integrity of the management and is unhealthy for the capital markets. The Securities and Exchange Board of India (SEBI), in its endeavour to protect the interests of investors in general, had formulated the SEBI (Insider Trading) Regulations, 1992 under the powers conferred on it under the SEBI Act, 1992. These regulations came into force with effect from 19th November 1992 and the same were made applicable to all companies whose shares were listed on Indian stock exchanges. After a detailed overhauling exercise carried out by SEBI, these regulations came to be replaced by the “Securities & Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015” and further amended by the “Securities & Exchange Board of India (Prohibition of Insider Trading) (Amendment) Regulations, 2018” (hereinafter referred to as “the Regulations” or “the regulations”). The Regulations undergo amendments from time to time. Regulation 3 of the Regulation prohibits communication or procurement of unpublished price sensitive information (UPSI), making a policy for determination of “legitimate purpose” and maintenance of digital database by the board of directors and Regulation 4 prohibits insiders from trading in listed or to-be-listed securities when in possession of UPSI. Initial Disclosure Pursuant to Regulation 7(1), initial disclosures of holdings of securities of the Company are to be made by each existing and also subsequent promoter, key managerial personnel and director of every listed company. Continual Disclosure Pursuant to Regulation 7(2), every promoter, designated person and director of every company shall disclose to the company the number of such securities, acquired or disposed of above a threshold limit of traded value in a calendar quarter, within two trading days of such transaction. Regulation 7(3) empowers any listed company to require at its discretion any other connected person or class of connected persons to make disclosures of holdings and trading in securities of the company in such form and at such frequency as may be determined by the company in order to monitor compliance with these regulations. The forms for making the initial and continuing disclosures are as prescribed by SEBI from time to time and may be referred separately. Under Regulations 8 and 9, the Company is required to frame a Code of Fair Disclosure and a Code of Conduct, and these codes are set out herein. CODE OF FAIR DISCLOSURE AND CODE OF CONDUCT (Pursuant to Regulations 8 and 9 of the SEBI (Prohibition of Insider Trading) (Amendment) Regulations, 2018) This document embodies the Codes of Fair Disclosure and Conduct to ensure timely and adequate disclosure of Unpublished Price Sensitive Information (as defined hereinafter) for prevention of insider trading (collectively ‘the Code’) to be adopted by the Company (as defined herein) and followed by their directors, officers and other employees. The Code is based on the principle that directors, officers, and employees of the Company owe a fiduciary duty to, among others, the shareholders of the Company to place the interest of the shareholders above their own and conduct their personal Securities transactions in a manner that does not create any conflict of interest situation. The Code is also intended to serve as a guiding charter for all concerned persons associated with the functioning of listed companies and their dealings in securities of such companies. Further, the Code also seeks to ensure timely and adequate disclosure of Unpublished Price Sensitive Information to the investor community by the Company to enable them to take informed investment decisions with regard to the Company’s Securities. DEFINITIONS: As used in this Code: Board means the Board of Directors of the Company. Code means this Code of Fair Disclosure and the Code of Conduct, as applicable, including modifications made thereto from time-to-time. Company or the Company means Westlife Foodworld Limited and its subsidiaries including Hardcastle Restaurants Private Limited. Compliance Officer means any senior officer, designated so and reporting to the board of directors, who is financially literate and is capable of appreciating requirements for legal and 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 listed company or the head of an organization, as the case may be. At present, the Company Secretary of Westlife Foodworld Limited is the Compliance Officer: Explanation- for the purpose of this Regulation, “financially literate” means 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 flow. Connected person shall have the meaning given to it under Regulation 2 (1) (d) of the Regulations. Dealing in Securities means an act of subscribing to, buying, selling or agreeing to [Showing first 8,000 characters — download PDF for full document]