Revision in Code of Conduct under SEBI PIT Regulations

Telephone: +91 22 6661 7272 | Email: info.india@blackbox.com BBOX/SD/SE/2026/73 August 12, 2026 Corporate Relationship Department Corporate Relationship Department Bombay Stock Exchange Limited The National Stock Exchange of India Limited P.J. Tower, Dalal Street, Exchange Plaza, Bandra Kurla Complex, Fort, Mumbai 400001 Bandra East, Mumbai 400051 Sub: Intimation about revision in Company’s ‘Code of Conduct for Prevention of Insider Trading and Fair disclosure of Unpublished Price Sensitive Information’ Ref.: Scrip code: BSE: 500463/NSE: BBOX Dear Sir/Madam, This is to inform you that pursuant to the SEBI (Prohibition of Insider Trading) Regulations, 2015, the Board of Directors of the Company at their Meeting held on August 12, 2026 have adopted revised "Code of Conduct for Prevention of Insider Trading and Fair disclosure of Unpublished Price Sensitive Information" ("Insider Trading Code"). The said revised Code is attached herewith for your information and record. Yours Faithfully, For Black Box Limited Aditya Goswami Company Secretary & Compliance Officer Encl.: A/a. BLACK BOX LIMITED Registered Office: 501, 5th Floor, Building No. 9, Airoli Knowledge Park, MIDC Industrial Area, Airoli, Navi Mumbai 400 708, India BLACKBOX.COM | CIN: L32200MH1986PLC040652 | Tel: +91 22 6661 7272 Black Box Limited CODES FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION INTERNAL PROCEDURES AND CONDUCT FOR REGULATING, MONITORING AND REPORTING OF TRADING BY INSIDERS REVISED CODE OF CONDUCT EFFECTIVE FROM AUGUST 12, 2026 CODE OF FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION Pursuant to Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, the Company has a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI), adopted with effect from 15th March 2015. Further, SEBI has vide notification dated 31 December 2018, amended SEBI (Prohibition of Insider Trading) Regulations, 2015 effective from 1st April 2019. Thus, as required under the said Regulations, a revised Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“UPSI”), (hereinafter referred to as the "Code") has been approved & adopted by the Board of Directors of the Company. The said Code shall supersede the earlier Code and shall be effective from January 01, 2023. DEFINITION: 1. Legitimate Purpose: The sharing of unpublished price sensitive information in the ordinary course of business by an insider with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals or other advisors or consultants will be considered as a “legitimate purpose”, provided that such sharing has not been carried out to evade or circumvent the restrictions/prohibitions imposed by SEBI (Prohibition of Insider Trading) Regulations, 2015 (“Regulations”).” 2. Other terms not specifically defined here shall have the same meaning as assigned under the said Regulations. CODE: 1. The Company shall ensure promptly disclosure of unpublished price sensitive information (“UPSI”) that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available to public; 2. The Company shall ensure uniform and universal dissemination of UPSI to avoid selective disclosure; 3. The Company Secretary shall act as the Chief Investor Relations Officer to deal with dissemination of information and disclosure of UPSI; 4. The Company shall ensure prompt dissemination of UPSI that gets disclosed selectively, inadvertently or otherwise, to make such information “generally available”; 5. The Company shall provide appropriate and fair response to queries on news reports and requests for verification of market rumors by regulatory authorities; 6. The Company shall ensure that information shared with analysts and research personnel is not UPSI; 7. The Company shall ensure that prior intimation of analysts meets and transcripts or records of proceedings of meetings with analysts (earnings call) and other investor relations conferences shall be published on the official website of the Company to ensure official confirmation and documentation of disclosures made thereof. 8. The Company shall handle all UPSI on a need-to-know basis. 9. The Company shall consider any person in receipt of UPSI due to a “legitimate purpose”, as an “insider”, for purposes of these regulations and the Company shall serve a notice on such person to maintain confidentiality of such UPSI in compliance with these regulations. 10. The Company shall maintain a structured digital database containing the names of such persons or entities with whom UPSI is shared in accordance with these regulations, along with their Permanent Account Number or any other identifier authorized by law, in case a Permanent Account Number is not available. Further, the Company shall ensure that adequate internal controls and checks are incorporated in such databases to ensure non- tampering of the database. 11. The Company shall establish an online IT portal which shall be used by the insiders for submission of application for obtaining pre-clearance and reporting of trades by the insiders in the securities of the Company. The said portal shall also assist in maintaining a digital database of such persons with whom UPSI is shared. 12. The Company has adopted appropriate policies/procedures for conducting an inquiry in case of a leak or suspected leak of UPSI as a part of the Code of Conduct to regulate, monitor and report trades of Designated Person(s). ********* CODE INTERNAL PROCEDURES AND CONDUCT FOR REGULATING, MONITORING AND REPORTING OF TRADING BY INSIDERS INTR ODUCTION Insider trading means trading in securities of a Company by insiders to the company having access to unpublished price sensitive information. Such trading is a civil as well as criminal wrong in violation of the fiduciary or contractual obligations of the insider. It is against the principles of efficient market of the securities of the company and erodes confidence of the investors in the company. The Securities and Exchange Board of India (SEBI), in its endeavor to regulate, develop the securities market and protect the interest of investors had formulated the SEBI (Prohibition of Insider Trading) Regulations, 1992 to provide a fair securities market by prohibiting insider trading. SEBI in its endeavor to keep pace with the dynamic securities market and in line with its experience in dealing with insider trading issues had constituted a High Level Committee under the Chairmanship of Justice N K Sodhi in 2013 to review the Regulations. Based on the recommendations of the Committee, SEBI has enacted SEBI (Prohibition of Insider Trading) Regulations, 2015 which replaces the SEBI (Prohibition of Insider Trading) Regulations, 1992. The 2015 Regulations revises the framework for prohibition on insider trading in securities. The 2015 Regulations shall come into force on May 15, 2015. The Regulations prescribes all listed companies to formulate and publish internal code of conduct to comply with the mandates under the Regulations which are at variance from the code of conduct prescribed under the 1992 Regulations. Black Box Limited (the “Company”) on an ongoing basis endeavors to apply best practices in relation to corporate governance requirements. As a part of its efforts, the Company undertakes to regulate, preserve and manage unpublished price sensitive information and its abuse. Per SEBI (Prohibition of Insider Trading) Regulations, 1992, the Company has formulated Code of Conduct for Prevention of Insider Trading. The Company is committed to transparency and fairness in dealing with all stakeholders and in ensuring adherence to all laws, regulations and Code of Conducts. Every director, officer, employee of the Company has a duty to safeguard the confidentiality of all su [Showing first 8,000 characters — download PDF for full document]