Adoption of Revised Whistle Blower Policy

Date: August 14, 2026 The Manager, Listing & Compliance, BSE Limited Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai – 400 001 Ref: Scrip Code – 544635 Subject: Intimation of Adoption of Revised Whistle Blower Policy pursuant to Regulation 22 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 Dear Sir/Madam, Pursuant to Regulation 22 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, we hereby inform you that the Board of Directors of the Company, at its meeting held on August 14, 2026, has approved and adopted the revised Whistle Blower Policy of the Company. The revised Whistle Blower Policy has been reviewed and updated in line with the applicable provisions of the Companies Act, 2013 and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to time. The revised policy aims to strengthen the vigil mechanism of the Company by providing an effective framework for reporting genuine concerns, ensuring adequate safeguards against victimisation of whistle blowers and facilitating fair and transparent investigation of reported concerns. The revised Whistle Blower Policy has also been placed on the website of the Company at www.luxurytimeindia.com for the information of the stakeholders. You are requested to kindly take the above information on record. Thanking you, Yours faithfully, For Luxury Time Limited Anjali Company Secretary & Compliance Officer Membership No. A69704 WHISTLE BLOWER POLICY (VIGIL MECHANISM) A. Introduction Luxury Time Limited (hereinafter referred to as the “Company”) is a public limited company whose equity shares are listed on the SME Platform of BSE Limited. The Company is committed to conducting its business with the highest standards of integrity, transparency, accountability and ethical behaviour and believes that good corporate governance is fundamental to its long-term success and sustainable growth. The Company encourages its Directors, employees and other stakeholders to report genuine concerns relating to any actual or suspected unethical conduct, fraud, financial irregularities, violation of applicable laws, the Company's Code of Conduct or other internal policies, misuse of the Company's assets or any other misconduct, without fear of retaliation or victimisation. Accordingly, the Company has established this Whistle Blower Policy (Vigil Mechanism) to provide an effective and confidential mechanism for reporting such genuine concerns and to ensure that every Protected Disclosure made in good faith is examined and addressed in a fair, impartial and timely manner. This Policy has been framed in accordance with the provisions of Section 177(9) and Section 177(10) of the Companies Act, 2013 read with Rule 7 of the Companies (Meetings of Board and its Powers) Rules, 2014 and, to the extent applicable, the provisions of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, and other applicable laws, rules and regulations, as amended from time to time. B. Objectives of the Policy The objectives of this Policy are to: a. To establish an effective Vigil Mechanism for reporting genuine concerns relating to unethical behaviour, fraud, misconduct or violation of applicable laws, the Company's Code of Conduct or other Company policies; b. To encourage Directors, employees and other eligible stakeholders to report genuine concerns in good faith without fear of retaliation, discrimination, harassment or victimisation; c. To provide adequate safeguards to whistle blowers against victimisation and ensure that no adverse action is taken against any person making a Protected Disclosure in good faith; d. To ensure that all Protected Disclosures are reviewed and investigated in a fair, objective, impartial and confidential manner; e. To provide direct access to the Chairperson of the Audit Committee in appropriate or exceptional cases in accordance with applicable law; f. To promote a culture of integrity, transparency, accountability and ethical conduct throughout the Company; g. To strengthen the Company's internal control and corporate governance framework by facilitating the early detection, reporting and prevention of fraud, unethical conduct and other misconduct; and h. To ensure compliance with the applicable provisions of the Companies Act, 2013, the rules made thereunder, SEBI Regulations and other applicable laws. C. Definitions For the purpose of this Policy, unless the context otherwise requires, the following terms shall have the meanings assigned to them below: a. “Act” means the Companies Act, 2013 and the rules made thereunder, as amended from time to time. b. “Audit Committee” means the Audit Committee constituted by the Board of Directors of the Company in accordance with Section 177 of the Companies Act, 2013 and other applicable provisions of law, as amended from time to time. c. “Board” or “Board of Directors” means the Board of Directors of Luxury Time Limited. d. “Code of Conduct” means the Code of Conduct adopted by the Company for its Directors, Key Managerial Personnel and Employees, as amended from time to time. e. “Company” means Luxury Time Limited. f. “Company Secretary & Compliance Officer” means the Company Secretary appointed by the Board of Directors, who also acts as the Compliance Officer of the Company in accordance with the applicable provisions of the Companies Act, 2013 and the SEBI Regulations. g. “Director” means a Director appointed to the Board of the Company. h. “Employee” means every employee of the Company, whether permanent, temporary, contractual, trainee or on probation, including the Directors in the employment of the Company. i. “Investigator(s)” means any person(s), internal or external, authorised by the Audit Committee to investigate a Protected Disclosure under this Policy. j. “Protected Disclosure” means any communication made in good faith by a Whistle Blower that discloses or demonstrates information concerning any actual or suspected unethical conduct, fraud, financial irregularity, violation of applicable laws, the Company's Code of Conduct, Company policies or any other improper or unlawful activity. k. “SEBI” means the Securities and Exchange Board of India. l. “SEBI LODR Regulations” means the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to time. m. “Subject” means a person against or in relation to whom a Protected Disclosure has been made or against whom evidence is gathered during the course of an investigation. n. “Whistle Blower” means any Director, Employee or other stakeholder of the Company, including vendors, suppliers, consultants, service providers, auditors, legal advisors or any other person associated with the Company, who makes a Protected Disclosure under this Policy in good faith. All other words and expressions used but not defined in this Policy, shall have the same meaning as defined in the Companies Act, 2013, SEBI (LODR) Regulations, 2015 or any other applicable law or regulation to the extent applicable to the Company. D. Guiding principles of the Vigil mechanism The Vigil Mechanism of the Company shall be guided by the following principles to ensure its effective implementation and to promote a culture of integrity, transparency and accountability: a. Every Protected Disclosure made in good faith shall be received, reviewed and dealt with in a fair, impartial and timely manner. b. The identity of the Whistle Blower and all information relating to the Protected Disclosure shall be kept strictly confidential, to the extent permitted under applicable law and as may be necessary for conducting a fair investigation. c. No Director, employee or any other person making a Protected Disclosure in good faith shall be subjected to victimisation, retaliation, harassment, discrimination or any other unfair treatment on a [Showing first 8,000 characters — download PDF for full document]