Revision in Code of Conduct under Prohibition of Insider Trading Regulations, 2015.

K E Y N O T E Ref # Key26 /Stock Exchange Let/Sk(25) August 13, 2026 The Manager The Manager BSE Limited, National Stock Exchange of India Ltd. Listing Department, Listing Department, Phiroze Jeejeebhoy Towers, Exchange Plaza, C-1, Block – G, Dalal Street, Bandra Kurla Complex, Bandra (East), Mumbai – 400 001 Mumbai – 400 051 Scrip Code: 512597 Symbol: KEYFINSERV Dear Sir/Madam, Sub: Intimation of Revision in the Policy We wish to inform you that the Board of Directors of the Company, at their Meeting held on today i.e August 13, 2026 has updated the following policy as mentioned below: Sr.No Policy’s Name 1. Code of Practices for Prohibition of Insider Trading Practices The aforesaid updated policies can also be accessed at the website of the Company at www.keynoteindia.net You are requested to take the above on record. Yours faithfully, For Keynote Financial Services Limited Simran Kashela Company Secretary & Compliance Officer Keynote Financial Services Limited The Ruby, 9th Floor, Senapati Bapat Marg, Dadar (West), Mumbai 400028 Tel : 91 22 6826 6000 Fax : 91 22 6826 6088 Email : info@keynoteindia.net Website www.keynoteindia.net CIN – L67120MH1993PLC072407 K E Y N O T E Keynote Financial Services Limited Code of Conduct for Prohibition of Insider Trading I. BACKGROUND AND OBJECTIVE Keynote Financial Services Limited (“Company”) is a public company whose Equity Shares are listed on BSE Limited (“BSE”) and National Stock Exchange of India Limited (“NSE”) and subject to the rules and regulations issued by the Securities and Exchange Board of India (“SEBI”). The Board (as defined below) of the Company had originally approved the Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons (“Code”) at its meeting held on May 28, 2015, in order to comply with the SEBI (Prohibition of Insider Trading) Regulations, 2015 (as amended from time to time) (“SEBI Regulations”). The Code was subsequently amended by the Board at its meetings held on February 11, 2022, and May 29, 2025 in order to comply with the applicable regulatory requirements. This Code shall be applicable to Designated Persons and Immediate Relatives of Designated Persons as defined in this Code. The SEBI Regulations prohibits an Insider from Trading (as defined below) in the Securities of a company listed on any stock exchange when in possession of any UPSI (as defined below). II. CODE OF CONDUCT 1. Definitions 1) “Act” shall mean the SEBI Act, 1992 (15 of 1992). 2) “Audit Committee’” shall mean committee of the Board of the Company constituted pursuant to the provisions of Section 177 of the Companies Act, 2013 read with Regulation 18 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. (“SEBI LODR”) 3) “Board” shall mean the board of Directors of the Company. 4) “Compliance Officer” means the Company Secretary of the Company, or such other senior officer designated as such and reporting to the Board, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under the SEBI Regulations and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the preservation of UPSI, monitoring of Trades and implementation of the codes specified under the SEBI Regulations under the overall supervision of the Board. 5) “Connected Person” means. i.. A Director of the Company ii. A Key Managerial Personnel of the Company; K E Y N O T E iii. An Officer of the Company; iv. Any person who is or has been in a contractual, fiduciary or employment relationship at any time in the six-month period prior to the date of determining whether that person, as a result of such relationship, was, directly or indirectly, allowed access to UPSI or reasonably expected to be allowed access to UPSI; v. Any person who is or has been in frequent communication with an Officer of the Company at any time in the six-month period prior to the date of determining whether that person, as a result of such frequent communication, was, directly or indirectly, allowed access to UPSI or reasonably expected to be allowed access to UPSI; vi. An employee of the Company who has access to UPSI or is reasonably expected to have access to UPSI; and vii. Any person who has a professional or business relationship with the Company, whether temporary or permanent, and that relationship directly or indirectly, allows access to UPSI or is reasonably expected to allow access to UPSI; Without prejudice to the generality of the foregoing, the persons enumerated below shall be deemed to be Connected Persons unless the contrary is established - 1. A relative of connected persons as specified above in (i) to (vii) 2. A holding company, associate company or subsidiary company. 3A banker of the Company; and 4 A concern, firm, trust, Hindu undivided family, company or association of persons wherein a Director of the Company or his Relative or banker of the Company, has more than ten percent of holding or interest. 5. a firm or its partner or its employee in which a connected person as specified in (i) to (vii) is also a partner; 6 a person sharing household or residence with a connected person as specified in (i) to (vii) 7 all those persons/entities as enumerated in the Regulations from time to time 6). “Contra trade” means a Trade or transaction which involves buying or selling Securities of the Company and within six months trading or transacting in an opposite transaction involving sell or buy following the prior transaction. 7). “Designated Person" shall consist of: i. Promoters of the Company. ii. Directors and Key Managerial Personnel of the Company and its material subsidiaries. iii. All employees of the Company and its subsidiaries, irrespective of K E Y N O T E their designation, shall be treated as Designated Persons, except administrative staff (such as office boys) and other support staff who, by virtue of their roles, do not have access to Unpublished Price Sensitive Information (UPSI) vi. Any other person may be designated by the Boar3 from time to time 8) “Director” shall have the meaning assigned to it under the Companies Act, 2013. 9) “Generally available information” means information that is accessible to the public on a non discriminatory basis and shall not include unverified event or information reported in print or electronic media. For example, information which is published on the website of stock exchange(s) where the Securities of the Company are listed or published by way of a press release by the Company, would ordinarily be considered generally available. 10) “Immediate Relative” means a spouse of a person, and includes parent, sibling, and child of such person or of the spouse, if they are either dependent financially on such person, or consults such person in taking decisions relating to Trading in Securities. 11) “Insider” means any person who is: i. a Connected Person or ii.. in possession of or having access to UPSI. 12) “Key Managerial Personnel” shall have the meaning assigned to it under the Companies Act, 2013. 13) “Leak of UPSI” shall refer to such act / circumstance(s) by virtue of which an UPSI is made available or becomes available, by any means or mode to any person, association, body, firm, agency, society, entity or to a group thereof, whether registered or otherwise before becoming its generally available and which shall also include any purported attempt thereof. Explanation: It covers the instances where the UPSI has been shared by a person to any person, association, body, firm, agency, society, entity or to a group thereof except in compliance with applicable law. 14) “Legitimate purpose” shall include sharing of UPSI 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, provided that s [Showing first 8,000 characters — download PDF for full document]