Revision in policy for procedure of inquiry or suspected in case of leak of UPSI

12th August, 2026 Corporate Relationship Department, Bombay Stock Exchange Limited Phiroze Jeejeebhoy Towers Dalal Street, Mumbai- 400 001 Scrip Code: 508969 (SULABEN), ISIN: INE673M01029 Subject: General Announcement for Review of Policy for Procedure of Inquiry In Case of Leak of Unpublished Price Sensitive Information or Suspected Leak of Unpublished Price Sensitive Information (“UPSI”) Dear Sir/ Madam, Please find enclosed herewith Amended Policy for Procedure of Inquiry In Case of Leak of Unpublished Price Sensitive Information or Suspected Leak of Unpublished Price Sensitive Information (“UPSI”) This is for your information and records. Thanking You, For Sulabh Engineers and Services Limited Tauheed Ahmad (Company Secretary and Compliance Officer) (Membership No: - ACS- 74592) Add: Regd. Off.:206, 2nd Floor, Apollo Complex Premises Cooperative Society Ltd., R.K. Singh Marg, ParsiPanchyat Road, Andheri (East), Mumbai, Maharashtra-400069/ Tel.: +91 22-67707822 Corp. Off.: Cabin No. 365 & 366 Padam Tower- II 3rd Floor, 14/113, Civil Lines Kanpur-208001/ Tel.:+91 8353917112 SULABH ENGINEERS AND SERVICES LIMITED POLICY FOR PROCEDURE OF INQUIRY IN CASE OF LEAK OF UNPUBLISHED PRICE SENSITIVE INFORMATION OR SUSPECTED LEAK OF UNPUBLISHED PRICE SENSTIVE INFORMATION (“UPSI”) Framed pursuant to Regulation 9A(5) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time. Background The Committee constituted by SEBI to review the Insider Trading Regulation noted the recent cases of leak of UPSI related to listed entities on Instant Messaging apps. Such information originates from within the company and affects the listed company in terms of its market price as well as loss of reputation and investors’ / financers’ confidence in the company. Leakage of UPSI from a company is a matter of serious concern not only for the regulator but for the company as well, and listed companies should take responsibility to find out sources responsible for the leakage and plug loopholes in the internal control systems to prohibit reoccurrence of such leakage of UPSI. Regulation 9A(5) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time mandates every listed company to formulate a written policy and procedures for inquiry in case of leak of unpublished price sensitive information or suspected leak of unpublished price sensitive information and initiate appropriate action on becoming aware of leak of unpublished price sensitive information or if the Compliance Officer is having suspicion that the UPSI is leaked from a particular connected persons or fiduciaries they the companies Officer is required to inform the Board promptly of such leaks, suspected, inquiries and results of such inquiries. In this regard, Board of Directors of Sulabh Engineers and Services Limited has laid down this policy for procedure of inquiry in case of leak or suspected leak of Unpublished Price Sensitive Information (‘the policy’), for adoption. Objective  To strengthen the internal control system to prevent leak of UPSI.  To restrict and prohibit the practice of sharing of UPSI, with an un-authorized person, which originates from within the company and which affects the market price of the Company as well as loss of reputation and investors’/ financers’ confidence in the Company.  To have a uniform code to curb the un-ethical practices of sharing UPSI by Insiders, Employee & Designated Persons with any person, firm, Company or Body Corporate.  To constitute a committee who shall be empowered to make inquiry, call for documents or evidences in case of leak of UPSI or suspected leak of UPSI and inform the same to the Securities and Exchange Board of India (“SEBI”) or any other competent authority promptly.  To take disciplinary actions, if deemed fit against any Insider, Employee & Designated Persons, Fiduciaries and other persons who appears to have found guilty of violating this policy, apart from any action that SEBI may initiate/take against the Insider, Employee & Designated Persons. 1) Scope To lay down procedures for inquiry in case of leak of unpublished price sensitive information or suspected leak of unpublished price sensitive information and inform the Board promptly of such leaks, inquiries and results of such inquiries. 2) Applicability This Policy shall apply to all Directors, Promoters, Promoter Group, Designated Persons, Insiders, Connected Persons, Relatives of Connected Persons, Fiduciaries, Immediate Relatives wherever specifically applicable under the Regulations, and any other person having possession of or access to UPSI. 3) Definitions a) “Audit committee” means the committee formed under Section 177 of the Companies Act, 2013 and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended thereof from time to time. b) “Board of Director” means the Board of Directors of Sulabh Engineers and Services Limited. c) “compliance officer” means any senior officer, designated so and reporting to the board of directors or head of the organization in case board is not there, 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. d) “Connected Person” shall have the meaning assigned under Regulation 2(1)(d) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time. e) Designated Persons: the board of directors or such other analogous authority shall in consultation with the compliance officer specify the designated persons to be covered by the code of conduct on the basis of their role and function in the organization and the access that such role and function would provide to unpublished price sensitive information in addition to seniority and professional designation and shall include :  Employees of such listed company, intermediary or fiduciary designated on the basis of their functional role or access to unpublished price sensitive information in the organization by their board of directors or analogous body;  Employees of material subsidiaries of such listed companies designated on the basis of their functional role or access to unpublished price sensitive information in the organization by their board of directors;  All promoters of listed companies and promoters who are individuals or investment companies for intermediaries or fiduciaries;  Chief Executive Officer and employees upto two levels below Chief Executive Officer of such listed company, intermediary, fiduciary and its material subsidiaries irrespective of their functional role in the company or ability to have access to unpublished price sensitive information;  Any support staff of listed company, intermediary or fiduciary such as IT staff or Secretarial staff who have access to unpublished price sensitive information. f) “Fiduciaries” Under Regulation 9(2) fiduciaries is collectively referred as “Professional firms such as auditors, accountancy firms, law firms, analysts, insolvency professional entities, consultants, banks etc., assisting or advising listed companies.” g) “insider” means any person who is:  a connected person; or  in possession of or having access to unpublished price sensitive information; h) “Leak of UPSI” : shall mean communication of information which is / shall be UPSI by any Insider, Employee & Designated Persons or any other known or unknown person to any person other than a person(s) authorized by the [Showing first 8,000 characters — download PDF for full document]