The intimation under Regulation 8 (2) of the SEBI (PIT) Regulations, 2015

ft SBI MUTUAL FUND SBI Funds Management Limited Aj oint venture between SBI &A MUNDI A PA R l NE R 0R l I H (CIN:U65990MH1992PLC065289) Ref. No.: FM/CS/2026/311 Date: July 21, 2026 National Stock Exchange of India Limited BSE Limited Exchange Plaza Plot No. C/1 Phiroze Jeejeebhoy Towers G Block Bandra – Kurla Complex Bandra Dalal Street East Mumbai – 400 051. Mumbai – 400 001. Scrip Symbol: SBIFUNDS Scrip Code: 544829 Sub: Intimation under Regulation 8 (2) of the Securities Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”) Dear Sir / Madam, This is to inform you that, pursuant to Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”), SBI Funds Management Limited (“the Company”) has framed a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information. In accordance with Regulation 8(2) of the PIT Regulations, a copy of the aforementioned Code is enclosed herewith. This intimation is also available on the Company’s website at https://sbifunds.com in compliance with Regulation 46 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI Listing Regulations”). You are requested to kindly take the same on record and disseminate it appropriately on your respective websites. Thanking you, For SBI Funds Management Limited Vinaya Datar Chief Compliance Officer, Company Secretary and Head Legal Membership No.: ACS 15527 Enclosed as above Trustee: SBI Mutual Fund Trustee Company Private Limited (CIN: U65991MH2003PTC138496) 9th Floor, Crescenzo, Plot C-38 & 39, G Block, Bandra Kurla Complex, Bandra (E), Mumbai -400 051. Tel.: +912261793000 Fax: +912267425687-91 Website: www.sbimf.com MUTUAL FUNDS I OFFSHORE FUNDS I PORTFOLIO MANAGEMENT SERVICES I ALTERNATIVE INVESTMENT FUNDS SBI FUNDS MANAGEMENT LIMITED CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION I. INTRODUCTION In accordance with Regulation 8 read with Schedule A of the Securities and Exchange Board of India (“SEBI”) (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”), as amended, the Board of SBI Funds Management Limited (“Company”), has adopted this ‘Code of practices and procedures for fair disclosure of Unpublished Price Sensitive Information’. II. OBJECTIVE The objective of the Code is to formulate a framework and policy for fair disclosure of events and occurrences that could impact price discovery in the market for the Company’s Securities, including the Unpublished Price Sensitive Information (“UPSI”), and to maintain the uniformity, transparency and fairness in dealings with all stakeholders and ensure adherence to applicable laws and regulations. III. DEFINITIONS (i). “Board” shall mean the board of directors of the Company. (ii). “Code” means this Code of practices and procedures for fair disclosure of UPSI. (iii). “Company” shall mean SBI Funds Management Limited. (iv). “Compliance Officer” means the duly appointed Compliance Officer of the Company or any senior officer, designated so and reporting to the Board, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under the PIT Regulations, and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules of preservation of UPSI, monitoring of trades and the implementation of the codes specified under the PIT Regulations under the overall supervision of the Board (v). “Stock Exchange” shall mean a recognised stock exchange on which the securities of the Company are listed. (vi). “Unpublished Price Sensitive Information” or “UPSI” shall have the meaning given to such term in the PIT Regulations. All terms used but not defined herein shall have the meaning ascribed to such term under the PIT Regulations and the Code of Conduct for Prevention of Insider Trading of the Company formulated under Regulation 9 of the PIT Regulations (“Insider Code”). In case of any discrepancy between the PIT Regulations and the terms defined herein, the meaning as ascribed under the PIT Regulations, shall prevail. IV. CHIEF INVESTOR RELATIONS OFFICER (CIRO) a) For the purposes of this Code, Compliance Officer shall act as the Chief Investor Relations Officer (“CIRO”). b) The CIRO would be responsible for: (a) 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; (b) Ensuring uniform and universal dissemination of information and disclosure of UPSI at an appropriate time, to avoid selective disclosure; (c) Ensuing appropriate and fair response to queries on news reports and requests for verification of market rumors by regulatory authorities; (d) Ensuring compliance with the Code and intimating instances of violations of the Code to the Audit Committee; (e) Overseeing and monitoring sharing of information of the Company (including UPSI) by employees and educating employees on disclosure policies and procedures; (f) Reviewing the disclosure process and controls and ensuring that same are operating effectively for compliance with the Code and the PIT Regulations; and (g) In discussion with the Board / senior management / Chief Financial Officer, making an assessment of (i) materiality of information; (ii) updates, if any, required to be provided in respect of past disclosures; and (iii) the timing and adequacy of the proposed disclosures. c) The CIRO shall strictly observe the timelines stipulated in terms of the SEBI (LODR) Regulations with respect to prior intimations / notices / notifications and disclosures to ensure prompt disclosure of any UPSI that gets disclosed selectively / inadvertently or otherwise to make such information generally available. V. PURPOSE AND SCOPE Prompt public disclosure of UPSI UPSI shall be disclosed to the Stock Exchanges by the CIRO and disseminated promptly on a continuous basis as soon as credible and concrete information comes into being in order to make such information generally available. For the purposes of timely disclosures of UPSI and other material events, the Company shall follow the timelines as stipulated in the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. Uniform and Universal dissemination of UPSI to avoid selective disclosure The UPSI shall be disseminated uniformly and universally to all stakeholders through Stock Exchanges and by posting the same on official website of the Company. The Company shall use its best endeavors to avoid selective disclosure of UPSI. However, if any information gets disclosed selectively or inadvertently or otherwise, it should be brought to the notice of the CIRO, and such information shall be made generally available through dissemination of the same to Stock Exchanges and/or by posting the same on the official website of the Company as soon as practicable. a) Procedures for responding to any queries on news reports and/or requests for verification of market rumors by regulatory authorities i. Appropriate, fair and prompt response shall be submitted to queries and/ or requests for verification of market rumors received from regulatory authorities or otherwise, in line with the applicable regulatory framework. ii. Such replies shall be signed by the CIRO or in absence of CIRO, by the CFO or any other person as identified by the CIRO for the time being. iii. In case the query/request has been received from any Stock Exchange, a copy of such reply shall be sent to other stock exchange(s) also where equity shares of the Company are listed, if any, by the Compliance Officer. iv. The CIRO shall oversee all public disclosures by the Company. He/ she shall be responsible for deciding whether a public announcement is necessary for verifying or denying rumors and then making the appropriate disclosures in [Showing first 8,000 characters — download PDF for full document]