With reference to Company''s Code of Conduct to regulate, monitor and report trading by designated persons and their immediate relatives ("Insider Trading Code") read with SEBI PIT Regulations, ....

Date: August 07, 2026 To, To, The Manager The Manager Lis(cid:415)ng Department Lis(cid:415)ng Department BSE Limited (“BSE”), Na(cid:415)onal Stock Exchange of India Limited (“NSE”), Phiroze Jeejeebhoy Towers, “Exchange Plaza”, C-1, G Block, Dalal Street, Fort, Bandra Kurla Complex, Bandra (East), Mumbai - 400 001 Mumbai - 400 051 BSE Scrip Code: 544799 NSE Symbol: TURTLEMINT Dear Sir/ Ma’am, Subject: Repor(cid:415)ng of viola(cid:415)ons under SEBI (Prohibi(cid:415)on of Insider Trading) Regula(cid:415)ons, 2015 With reference to Company’s code of conduct to regulate, monitor and report trading by designated persons and their immediate rela(cid:415)ves (“Insider Trading Code”) read with SEBI (Prohibi(cid:415)on of Insider Trading) Regula(cid:415)ons, 2015, please find enclosed herewith the report related to the viola(cid:415)on of Company’s Insider Trading Code by certain designated persons in the format prescribed by SEBI vide its Circular SEBI/HO/ISD/ISD/CIR/P/2020/135 dated July 23, 2020. Request you to take the same on records. Thanking You, Yours Faithfully, For Turtlemint Fintech Solu(cid:415)ons Limited (Formerly known as Turtlemint Fintech Solu(cid:415)ons Private Limited and Fintech Blue Solu(cid:415)ons Private Limited) Prashant Saini Company Secretary & Compliance Officer Membership No. A23769 Encl: As above Annexure Report by Turtlemint Fintech Solu(cid:415)ons Limited for viola(cid:415)ons related to Code of Conduct under SEBI (Prohibi(cid:415)on of Insider Trading) Regula(cid:415)ons, 2015 (Schedule B read with Regula(cid:415)on 9(1) of SEBI (Prohibi(cid:415)on of Insider Trading) Regula(cid:415)ons, 2015) 1. Mr. Aaditya Kulkarni SR No. Par(cid:415)culars Details 1. Name of the listed company Turtlemint Fintech Solu(cid:415)ons Limited 2. Repor(cid:415)ng in the capacity of Listed Company 3. A. Details of Designated Person (DP) i. Name of the DP Aaditya Kulkarni ii. PAN of the DP IURPK3099E iii. Designa(cid:415)on of DP Senior So(cid:332)ware Engineer iv. Func(cid:415)onal Role of DP Technology v. Whether DP is Promoter or belongs to No Promoter Group B. If Repor(cid:415)ng is for immediate rela(cid:415)ve of DP i. Name of the immediate rela(cid:415)ve of DP Not Applicable ii. PAN of the immediate rela(cid:415)ve of DP Not Applicable C. Details of transac(cid:415)on(s) i. Name of the scrip BSE: 544799 NSE: TURTLEMINT ii. No of shares traded and value (₹) (Date- Date of Transac(cid:415)on – 08/07/2026 wise) No. of Shares bought – 50 Average Price – 129.50 Total considera(cid:415)on – Rs. 6475/- D. In case value of trade(s) is more than ₹10 lacs in a calendar quarter i. Date of in(cid:415)ma(cid:415)on of trade(s) by concerned Not Applicable DP/director/promoter/promoter group to Company under Regula(cid:415)on 7 of SEBI (PIT) Regula(cid:415)ons, 2015 ii. Date of in(cid:415)ma(cid:415)on of trade(s) by Company Not Applicable to stock exchanges under regula(cid:415)on 7 of SEBI (PIT) Regula(cid:415)ons, 2015 4 Details of viola(cid:415)ons observed under Code of Trading during the trading Conduct window closure period 5 Ac(cid:415)on taken by Listed company  In(cid:415)ma(cid:415)on of closure of trading window was circulated to all Designated Persons, via email on June 26, 2026 followed by reminder emails on June 28, 2026 and June 29, 2026 respec(cid:415)vely.  Show cause no(cid:415)ce has been issued by the Company via email on July 14, 2026 and a response has also been received by the Company on July 14, 2026.  The ma(cid:425)er was placed at the Audit Commi(cid:425)ee on July 17, 2026 and the Commi(cid:425)ee directed to issue warning le(cid:425)er to the said designated person.  Warning le(cid:425)er was issued to the designated person on July 30, 2026. 6 Reasons recorded in wri(cid:415)ng for taking ac(cid:415)on The Company has issued warning stated above le(cid:425)er considering the amount of trade is insignificant and this trade was made inadvertently without inten(cid:415)on of viola(cid:415)ng PIT regula(cid:415)ons 7 Details of the previous instances of viola(cid:415)ons, None if any, since last financial year 8 If any amount collected for Code of Conduct viola(cid:415)on(s) – Not Applicable i. Mode of transfer to SEBI - IPEF - (Online/Demand Dra(cid:332)) ii. Details of transfer/payment - In case of Online: Par(cid:415)culars Details Name of the transferor Bank name, branch and account number UTR/ transac(cid:415)on reference number Transac(cid:415)on date Transac(cid:415)on amount (in Rs.) In case of Demand Dra(cid:332) (DD): Par(cid:415)culars Details Bank name and branch DD number DD date DD amount (in Rs.) 9 Any other relevant informa(cid:415)on - 2. Mr. Yash Malviya SR No. Par(cid:415)culars Details 1. Name of the listed company Turtlemint Fintech Solu(cid:415)ons Limited 2. Repor(cid:415)ng in the capacity of Listed Company 3. A. Details of Designated Person (DP) i. Name of the DP Yash Malviya ii. PAN of the DP JBAPM0779J iii. Designa(cid:415)on of DP Tech Intern iv. Func(cid:415)onal Role of DP Tech v. Whether DP is Promoter or belongs to No Promoter Group B. If Repor(cid:415)ng is for immediate rela(cid:415)ve of DP i. Name of the immediate rela(cid:415)ve of DP Not Applicable ii. PAN of the immediate rela(cid:415)ve of DP Not Applicable C. Details of transac(cid:415)on(s) i. Name of the scrip BSE: 544799 NSE: TURTLEMINT ii. No of shares traded and value (₹) (Date- Date of Transac(cid:415)on – 01/07/2026 wise) No. of Shares bought – 2 Average Price – 143.49 Total considera(cid:415)on – Rs. 286.98/- D. In case value of trade(s) is more than ₹10 lacs in a calendar quarter i. Date of in(cid:415)ma(cid:415)on of trade(s) by concerned Not Applicable DP/director/promoter/promoter group to Company under Regula(cid:415)on 7 of SEBI (PIT) Regula(cid:415)ons, 2015 ii. Date of in(cid:415)ma(cid:415)on of trade(s) by Company Not Applicable to stock exchanges under regula(cid:415)on 7 of SEBI (PIT) Regula(cid:415)ons, 2015 4 Details of viola(cid:415)ons observed under Code of Trading during the trading Conduct window closure period 5 Ac(cid:415)on taken by Listed company  In(cid:415)ma(cid:415)on of closure of trading window was circulated to all Designated Persons, via email on June 26, 2026 followed by reminder emails on June 28, 2026 and June 29, 2026 respec(cid:415)vely.  Show cause no(cid:415)ce has been issued by the Company via email on July 14, 2026 and a response has also been received by the Company on July 24, 2026.  The ma(cid:425)er was placed at the Audit Commi(cid:425)ee on July 17, 2026 and the Commi(cid:425)ee directed to issue warning le(cid:425)er to the said connected person.  Warning le(cid:425)er was issued to the connected person on July 30, 2026. 6 Reasons recorded in wri(cid:415)ng for taking ac(cid:415)on The Company has issued warning stated above le(cid:425)er considering the amount of trade is insignificant and this trade was made inadvertently without inten(cid:415)on of viola(cid:415)ng PIT regula(cid:415)ons 7 Details of the previous instances of viola(cid:415)ons, None if any, since last financial year 8 If any amount collected for Code of Conduct viola(cid:415)on(s) – Not Applicable i. Mode of transfer to SEBI - IPEF - (Online/Demand Dra(cid:332)) ii. Details of transfer/payment - In case of Online: Par(cid:415)culars Details Name of the transferor Bank name, branch and account number UTR/ transac(cid:415)on reference number Transac(cid:415)on date Transac(cid:415)on amount (in Rs.) In case of Demand Dra(cid:332) (DD): Par(cid:415)culars Details Bank name and branch DD number DD date DD amount (in Rs.) 9 Any other relevant informa(cid:415)on - 3. Mr. Yash Rajput SR No. Par(cid:415)culars Details 1. Name of the listed company Turtlemint Fintech Solu(cid:415)ons Limited 2. Repor(cid:415)ng in the capacity of Listed Company 3. A. Details of Designated Person (DP) i. Name of the DP Yash Rajput ii. PAN of the DP EYUPR5571R iii. Designa(cid:415)on of DP Senior So(cid:332)ware Engineer [Showing first 8,000 characters — download PDF for full document]