Please refer the attached intimation.

August 10, 2026 Listing Compliance Department BSE Limited, Phiroze Jeejeebhoy Towers, Dalal Street, Fort Mumbai — 400 001. REF: SCRIP CODE: 500422 ISIN: INE019B01010 Dear Sir /Madam, Subject: Amendment to the Code of Conduct for Prevention of Insider Trading With reference to the captioned subject, the Board of Directors at its meeting held today, i.e. August 10, 2026, approved the amendment to the ‘Code of Conduct for Prevention of Insider Trading’ pursuant to provisions of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“SEBI PIT Regulations”) as amended from time to time. A copy of the amended Code of Conduct for Prevention of Insider Trading is enclosed as Annexure A, in compliance with Regulation 8(2) of the SEBI PIT Regulations. The meeting of the Board of Directors of the Company commenced at 03:30 p.m. and concluded at 04:45 p.m. Kindly take the same on your records. Thanking You, Yours Faithfully, For Transchem Limited Neeraja Karandikar Company Secretary ACS: 10130 Encl: a/a CIN: L66120MH1976PLC019327 Registered Office: 111, Maker Chambers IV, 11th Floor, Nariman Point, Mumbai - 400021 Tel.: +91 22 43347000 Fax: + 91 22 43347002 E-mail: secretary@transchem.net Website: www.transchem.net TRANSCHEM LIMITED Code of Conduct PREVENTION OF INSIDER TRADING Document Name Code of Conduct for Prevention of Insider Trading Original document Date May 11, 2019 Review Version & Date Version 3.0 dated August 10, 2026 CIN: L66120MH1976PLC019327 Registered Office: 111, Maker Chambers IV, 11th Floor, Nariman Point, Mumbai - 400021 Tel.: +91 22 43347000 Fax: + 91 22 43347002 E-mail: secretary@transchem.net Website: www.transchem.net ❖ Contents ❖ 1. INTRODUCTION AND APPLICABILITY 2. DEFINITIONS 3. CODE OF CONDUCT FOR PREVENTION OF INSIDER TRADING 1) Protocol and Trading Restrictions applicable to Connected Persons 2) Trades that may be permitted during the Trading Window Closure Period 3) The Process of bringing in Connected Persons on sensitive transactions 4) Additional Trading restrictions applicable to Designated Persons 5) Reporting Requirements applicable to Designated Persons 6) Penalty for Contravention of the Code 7) Compliance Officer 4. CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION 4.1 Policy for determination of legitimate purposes. 4.2 Policy for procedure of inquiry in case of leak of UPSI. 5. POWERS OF THE BOARD OF DIRECTORS 6. DISCLOSURE OF THE CODE 7. AMENDMENTS/MODIFICATIONS CIN: L66120MH1976PLC019327 Registered Office: 111, Maker Chambers IV, 11th Floor, Nariman Point, Mumbai - 400021 Tel.: +91 22 43347000 Fax: + 91 22 43347002 E-mail: secretary@transchem.net Website: www.transchem.net Introduction: Securities Exchange Board of India (SEBI) vide its SEBI (Prohibition of Insider Trading) Regulations, 2015 (Insider Trading Regulations) and the Ministry of Corporate Affairs through the Companies Act, 2013, has laid down provisions to prevent Insider Trading. Employees, including Directors and KMP, should be aware that if they possess inside information regarding the Company they work for, they must completely refrain from trading or advising anybody to trade in the Securities of that Company during the time such information remains unpublished, as this is classified as ‘Insider Trading’ and is a punishable offence. The penalty for violating this requirement includes ban from trading in the stock market, payment of market price of Securities which have been traded in violation of these requirements and criminal prosecution (i.e. imprisonment up to 10 years and/or fine up to Rs. 25 crores or three times the amount of profits made out of insider trading, whichever is higher.). (Ref: SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended up to date; SEBI Act, 1992 and Companies Act, 2013). About this Code of Conduct One of the rules prescribed by SEBI for preventing Insider Trading is that the Board of Directors of every listed company should formulate and adopt a Code of Conduct to regulate, monitor and report trading by its Connected Persons. The Code adopted by the Company should adhere as closely as possible to the Model Code specified in Schedule B of the Insider Trading Regulations without diluting it in any manner and companies must ensure compliance of the same. The Code of Conduct contained herein is framed in compliance with the aforesaid requirement of Insider Trading Regulations and provisions of the Companies Act, 2013. This Code of Conduct supersedes and replaces any previous Codes of Conduct on Prevention of Insider Trading, whether express or implied, in full. This Code of Conduct pertains solely to Prevention of Insider Trading and does not purport to be a general Code of Conduct for employees in respect of other matters. 1. INTRODUCTION AND APPLICABILITY a) This Code may be called the “Transchem’s Code of Conduct for Prevention of Insider Trading”. b) This Code is framed pursuant to the provisions of Regulation 9(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 and provisions of the Companies Act, 2013. c) The Code shall be applicable to Connected Persons and Designated Persons as defined below. 2. DEFINITIONS a) “Act” means the Securities and Exchange Board of India Act, 1992. b) “Board” means the Board of Directors of Transchem Limited. c) “Code” means the Transchem’s Code of Conduct for Prevention of Insider Trading. d) “Company” means Transchem Limited. CIN: L66120MH1976PLC019327 Registered Office: 111, Maker Chambers IV, 11th Floor, Nariman Point, Mumbai - 400021 Tel.: +91 22 43347000 Fax: + 91 22 43347002 E-mail: secretary@transchem.net Website: www.transchem.net e) “Compliance Officer” means the Company Secretary or such senior officer who may be appointed by the Board of Directors as the Compliance Officer as designated under Regulations. f) ‘Connected Person’ shall have the meaning as described under Regulation 2(d) of the Regulations as amended from time to time. g) “Designated Person” means a) Promoters of the Company; b) Directors of the Company; c) CFO of the Company and its Material Subsidiaries, if any; d) Employees upto two level below the Chief Executive officer of the Company and its material subsidiaries, if any; e) Key Managerial Personnel; f) All designated employees of the across the Group having/likely to gave access to UPSI; and g) Relatives of the above. Clarification to definition: For the avoidance of doubt, the expression “Designated Person” shall also include the Managing Director/Chief Executive Officer of the Company, promoters and members of the promoter group, and every support-function employee and connected consultant, intermediary, fiduciary or advisor who has or is reasonably expected to have access to unpublished price sensitive information, in each case as identified by the Board in consultation with the Compliance Officer; and the reference to “Relatives of the above” shall be read as “Immediate Relatives” as defined under Regulation 2(1)(f) of the Regulations. h) “Generally available information” shall have the meaning as described under Regulation 2(e) of the Regulations as amended from time to time. i) “Immediate Relative” shall have the meaning as described under Regulation 2(f) of the Regulations as amended from time to time. j) “Insider” means Connected Person or persons who is in possession of or having access to Unpublished Price Sensitive Information. k) “Insider Trading “means trade in Securities by any Insider; l) “Key Managerial Personnel (KMP)“shall be as defined under the provisions of the Companies Act, 2013 and the Rules made thereunder. m) “relative” shall have the meaning as described under Regulation 2(h)(b) of the Regulations as amended from time to time. n) “Securities” shall have the meaning assigned to it under the Securities Contracts (Regulation) Act, 1956 or any modification thereof. o) “Trading” means and includes subscribing, buying, [Showing first 8,000 characters — download PDF for full document]