Updates

Date: August 14, 2026 To, To, Listing Department Listing Department BSE Limited National Stock Exchange of India Limited Phirozee Jeejeeboy Towers, Exchange Plaza, Bandra Kurla Complex, Dalal Street, Fort, Mumbai – 400001. Bandra (East), Mumbai – 400051 Scrip Code: 544865 Symbol: LEAPIND Dear Sir/ Ma’am, Subject: Disclosure under Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulation, 2015 (“SEBI PIT Regulations”). Pursuant to Regulation 8(2) of the SEBI PIT Regulations, as amended, please find enclosed herewith the “Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information” as framed and adopted by the Board of Directors of the Company under Regulation 8(1) of the SEBI PIT Regulations. The copy of the said Code is also made available on the Company's website i.e., www.leapindia.net. You are requested to take the above information on your record. Thanking you. Yours faithfully, For LEAP India Limited Chirag Bagadia Company Secretary, Compliance Officer and Head Legal Membership No.: A21579 CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION In pursuance to the Regulation 8(1) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time (“Insider Trading Regulations”), it is required that the board of directors of every listed company shall formulate a code of practices and procedures for fair disclosure of unpublished price sensitive information. This document (“Code”) embodies the code of practices and procedures for fair disclosure of unpublished price sensitive information to be followed by the Company effective from the commencement of listing and trading of the equity shares of the Company on the stock exchange(s), i.e. BSE Limited or National Stock Exchange of India Limited, in accordance with applicable laws provided however that the relevant provision of the Insider Trading Regulations which are applicable to the companies ‘proposed to be listed’ shall become applicable with immediate effect. All terms used but not defined herein shall have the meaning ascribed to such term under the Insider Trading Regulations. In case of any discrepancy between the Insider Trading Regulations and the terms defined herein, the meaning as ascribed under the Insider Trading Regulations, shall prevail. Definitions “Compliance Officer” for the purpose of these Insider Trading Regulations means the Company Secretary of the Company. In absence of the Company Secretary, the board of the Company may authorize such other officer of the Company to discharge the duties of Compliance Officer under the Insider Trading Regulations. “Unpublished Price Sensitive Information”/ “UPSI” means any information, relating to the Company or its securities, directly or indirectly, that is not Generally Available Information which upon becoming Generally Available, is likely to materially affect the price of the Company’s securities and shall, ordinarily include but not be restricted to, information relating to the following: i. financial results / statements; ii. dividends; iii. change in capital structure; iv. mergers, demergers, acquisitions, delisting, disposals and expansion of business, award or termination of order/contracts not in the normal course of business and such other transactions; v. changes in Key Managerial Personnel other than due to superannuation or end of term, and resignation of a Statutory Auditor or Secretarial Auditor; vi. Change in rating(s), other than ESG rating(s); vii. fund raising proposed to be undertaken; viii. agreements, by whatever name called, which may impact the management or control of the company; ix. fraud or defaults by the company, its promoter, director, key managerial personnel, or subsidiary or arrest of key managerial personnel, promoter or director of the company, whether occurred within India or abroad; x. resolution plan/ restructuring or one-time settlement in relation to loans/borrowings from banks/financial institutions; xi. admission of winding-up petition filed by any party /creditors and admission of application by the Tribunal filed by the corporate applicant or financial creditors for initiation of corporate insolvency resolution process against the company as a corporate debtor, approval of resolution plan or rejection thereof under the Insolvency and Bankruptcy Code, 2016; xii. initiation of forensic audit, by whatever name called, by the company or any other entity for detecting mis-statement in financials, misappropriation/ siphoning or diversion of funds and receipt of final forensic audit report; xiii. action(s) initiated or orders passed within India or abroad, by any regulatory, statutory, enforcement authority or judicial body against the company or its directors, key managerial personnel, promoter or subsidiary, in relation to the company; xiv. outcome of any litigation(s) or dispute(s) which may have an impact on the company; xv. giving of guarantees or indemnity or becoming a surety, by whatever named called, for any third party, by the company not in the normal course of business; xvi. granting, withdrawal, surrender, cancellation or suspension of key licenses or regulatory approvals. xvii. Such other information, in the opinion of the Board, if disclosed is likely to materially affect the prices of the securities; and xviii. Such other information which is required by Insider Trading Regulations to be designated as UPSI. Unpublished Price Sensitive Information i. LEAP India Limited (“Company”) shall promptly disclose unpublished price sensitive information that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available. ii. The unpublished price sensitive information (“UPSI”) shall be uniform and universally disseminated and due care will be taken to avoid selective disclosure. iii. In case if the UPSI that gets disclosed selectively, inadvertently or otherwise, prompt steps shall be taken to make such information generally available. Designation and Role of Chief Investor Relations Officer i. The Chief Financial Officer of the Company or such other senior official nominated as such by the board of the Company from time to time shall be the Chief Investor Relations Officer (“CIRO”) for the purpose of the Code. The CIRO shall be responsible for dissemination of information and disclosure of UPSI and also responding to the queries on news reports and requests for verification of market rumours by regulatory authorities. ii. In the temporary absence of the CIRO for any reason whatsoever, the board of the Company shall nominate any other official of the Company to be responsible for dissemination of information and disclosure of UPSI. General obligations for preservation and disclosure of UPSI i. All UPSI shall be handled on a need-to-know basis and in accordance with the provisions of the Insider Trading Regulations including, where applicable, in accordance with the “Policy for Determination of Legitimate Purpose” provided in Annexure A of this Policy and any other applicable codes, policies and procedures of the Company. ii. The Company shall disseminate all credible and concrete UPSI on a continuous and in a timely manner to stock exchanges where its securities are listed in accordance with the requirements of applicable law and thereafter/ simultaneously to the press or other modes of public disclosures. iii. As a good corporate governance practice, the UPSI disclosed to the Stock Exchanges and to the press may also be supplemented by prompt updates on the Company‘s website and/or other modes of public disclosure so as to improve investor access to the same. iv. It is clarified that information to be termed UPSI should be specific and intended to be generally made available at a point of time to ensure it does not lead to [Showing first 8,000 characters — download PDF for full document]