Please find enclosed herewith Copy of Code of Practices and Procedures for fair disclosure of UPSI.

Date - August 19, 2026 National Stock Exchange of India Limited BSE Limited Exchange Plaza, 5th Floor, Department of Corporate Services/ Plot No. C/1, G Block, Listing Phiroze Jeejeebhoy Bandra-Kurla Complex, Jeejeebhoy Towers Bandra (East), Mumbai – 400051 Dalal Street, Fort, Mumbai – 400001 SYMBOL: XTRANET SCRIP CODE: 544838 Sub: Intimation under Regulation 8 (2) of the Securities and Exchange Board of India (Prohibition of Insider Trading), Regulations 2015 (“SEBI PIT Regulations”). Dear Sir / Madam, Pursuant to Regulation 8(1) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations 2015 (“SEBI PIT Regulations”), we wish to inform that XtraNet Technologies Limited (“the Company”) has framed a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information. In accordance with Regulation 8(2) of the SEBI PIT Regulations, please find enclosed copy of the aforesaid Code. The said code is also available on the Company’s website at https://xtranetindia.com/. You are requested to kindly take the same on record. Thanking you Yours Sincerely For Xtranet Technologies Limited Kavita Malik Company Secretary and Compliance Officer Membership No.: ACS 24700 Encl.: A/a XtraNet Technologies Limited (Previously known as XtraNet Technologies Private Limited) (An ISO-9001:2015, ISO/IEC 27001:2013, ISO/IEC 20000-1:2011 & CMMi Level-5 Certified Company) HO: - Z-24, Zone-I, M.P. Nagar, Bhopal – 462 011 (M.P.) INDIA Tel.: +91-755- 4223295, +91-755- 4229295, 4209295, CIN : U72200MP2002PLC014956, Web : www.xtranetindia.com, Email : info@xtranetindia.com CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION 1. Introduction: 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of Insider Trading) Regulations, 2015, the Company has a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI), as adopted by the Board of Directors of the Company at its meeting held on August 19, 2026. 2. Scope: 2.1. XTRANET endeavors to preserve the confidentiality of UPSI and to prevent its misuse. To achieve these objectives, and in compliance with the PIT Regulations, XTRANET has adopted this Fair Disclosure Code. 2.2. This Fair Disclosure Code ensures timely and adequate disclosure of UPSI which would impact the price of its securities and to maintain uniformity, transparency and fairness in dealing with all its stakeholders. 2.3. XTRANET is committed to timely and accurate disclosure based on applicable legal and regulatory requirements. 3. Terms and Definitions: 3.1. Words and expressions used but not defined in this Fair Disclosure Code shall have the same meaning assigned to them in the SEBI PIT Regulations or the Securities and Exchange Board of India Act, 1992, the Securities Contracts (Regulation) Act, 1956, the Depositories Act, 1996 or the Companies Act, 2013 and the rules and regulations made thereunder, as the case may be or in any amendment thereto. 4. Policy Details: 4.1. Chief Investor Relations Officer: 4.1.1. “Chief Investor Relations Officer (CIRO)” means the Company Secretary & Compliance Officer of the Company or such other senior officer of the Company appointed by the Board of directors to deal with dissemination of information and disclosure of UPSI in a fair and unbiased manner to the stock exchanges, analysts, shareholders and media. Unless otherwise designated by the Board, the Company Secretary for the time being of the Company shall be deemed to be the Chief Investor Relations Officer. 4.1.2. Information disclosure/dissemination needs to be approved in advance by the CIRO. 4.1.3. If information is accidentally disclosed without prior approval, the person responsible or the person who discovers or comes in contact with such accidentally disclosed information should inform the CIRO immediately who in turn will promptly inform to the Managing Director or Chief Executive Officer or Chief Financial Officer for further action. XtraNet Technologies Limited (Previously known as XtraNet Technologies Private Limited) (An ISO-9001:2015, ISO/IEC 27001:2013, ISO/IEC 20000-1:2011 & CMMi Level-5 Certified Company) HO: - Z-24, Zone-I, M.P. Nagar, Bhopal – 462 011 (M.P.) INDIA Tel.: +91-755- 4223295, +91-755- 4229295, 4209295, CIN : U72200MP2002PLC014956, Web : www.xtranetindia.com, Email : info@xtranetindia.com 4.1.4. The CIRO shall take prior approval of the Managing Director or Chief Executive Officer or Chief Financial Officer or any other appropriate authority, as may be decided by the Board, before dissemination/disclosure of UPSI. 4.2. Principles of Fair Disclosure: To adhere with the principles as mentioned in Schedule A to the SEBI PIT Regulations, XTRANET shall ensure the following: 4.2.1. Promptly disclose publicly any UPSI that would impact price discovery no sooner than credible and concrete information comes into being so that such information is generally available. 4.2.2. Uniformly and universally disseminate in a timely manner UPSI to avoid selective disclosure by communicating the same to the stock exchange(s) and disclosing the same on its website before releasing such information to media or analysts. 4.2.3. Employees of XTRANET shall not respond under any circumstances to enquiries from the Stock Exchanges, the media or others, unless authorized to do so by the CIRO or Managing Director or Chief Executive Officer or Chief Financial Officer or any other officer as may be decided by the Board of Directors of XTRANET (including any committee of the Board of Directors of XTRANET) in this regard. 4.2.4. Make a public announcement with respect to any matter only after XTRANET has taken a final or definitive decision. When there are rumors or news reports and XTRANET is queried by the regulatory authorities including stock exchanges, XTRANET will provide appropriate and fair reply by accepting, denying, or clarifying the same. XTRANET will not be required to make disclosures in cases where the proposal is still in progress, or there are impending negotiations or incomplete proposals, the disclosure of which will not be appropriate and could prejudice XTRANET’s legitimate interests. 4.2.5. Promptly disseminate UPSI to the market through the stock exchanges in case UPSI gets disclosed selectively, inadvertently or otherwise to a section of the market, to make such information generally available. 4.2.6. The Company may communicate with its Institutional shareholders through meetings with analysts and discussions between fund managers and management. The Company may also participate at investor conferences from time to time. All interactions with institutional shareholders, fund managers, research associates and analysts shall be based on generally available information that is accessible to the public on a non-discriminative basis and information shared with such persons should not include UPSI. The CIRO shall develop best practicesto make transcripts or records of proceedings of meetings with analysts and other investor relations conferences on the official website to ensure official confirmation and documentation of disclosures made. For the purpose of this clause, ‘meet’ shall mean group meetings or group conference calls conducted physically or through digital means. XtraNet Technologies Limited (Previously known as XtraNet Technologies Private Limited) (An ISO-9001:2015, ISO/IEC 27001:2013, ISO/IEC 20000-1:2011 & CMMi Level-5 Certified Company) HO: - Z-24, Zone-I, M.P. Nagar, Bhopal – 462 011 (M.P.) INDIA Tel.: +91-755- 4223295, +91-755- 4229295, 4209295, CIN : U72200MP2002PLC014956, Web : www.xtranetindia.com, Email : info@xtranetindia.com 5. The “Policy for determination of Legitimate Purposes” is as below: 5.1. The term “Legitimate Purpose” shall for the purpose of this Code and the SEBI Regulations, includes sharing of UPSI in the ordinary course of business by an insider with partners, collaborators, le [Showing first 8,000 characters — download PDF for full document]