General Updates

ll Shree Shankeshwar Parshwanathay Namah Il i App Store ® Google Play di) eC Tel.: 91-22-23470009 / 91-22-23470008 Office No. 12, 3rd Floor, 101, Mumbadevi Diamond Premises Co-op. Soc. Ltd., Zaveri Bazar, Jewellers Ltd. Mumbai - 400 002. MAHARASHTRA, INDIA. e CIN No.: U36910MH2005PLC154679 Formery: Knowrins Website : www.shankeshjewellers.com e Email : shankjewel@gmail.com, info@shankeshjewellers.com Shankesh Jewellers pvt. ltd. Date: August 25, 2026 To, TO, Listing/Compliance Department Listing/Compliance Department BSE Limited National Stock Exchange of India Limited Phiroze Jeejeebhoy Towers, Exchange Plaza, Plot No. C/1, Dalal Street, G-Block, Bandra-Kurla Complex, Mumbai - 400001 Bandra (E), Mumbai - 400051 BSE Scrip Code: 544882 NSE Symbol: SJL Dear Sir/ Ma‘am, Subject: Intimation of Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (‘Code’) Ref: Regulation 8(2) of the Securities Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (‘SEBI PIT Regulations’) In reference to the captioned subject, please find attached herewith the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information framed under Regulation 8 (1) of SEBI PIT Regulations. The Code has been uploaded on the website of the Company — at: https://www.shankeshjewellers.com/ This is submitted for your information and records. Thank You FOR SHANKESH JEWELLERS LIMITED (Formerly known as SHANKESH JEWELLERS PRIVATE LIMITED) SHWETA RAVANKAR COMPANY SECRETARY AND COMPLIANCE OFFICER Membership No: A68236 CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION (Under Regulation 8 and 3(2A) of the SEBI (Prohibition of Insider Trading) Regulations, 2015) (“SEBI PIT Regulations”) CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION 1. Introduction Regulation 8 of the SEBI (Prohibition of Insider Trading) Regulations, 2015 requires the company to formulate a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Fair Disclosure Code”). The board of directors of the company, whose securities are listed on a stock exchange, shall formulate a stated framework and policy for fair disclosure of events and occurrences that could impact price discovery in the market for its securities and publish on its official website, a code of practices and procedures for fair disclosure of unpublished price sensitive information that it would follow in order to adhere to each of the principles set out in the regulations, without diluting the provisions of these regulations in any manner 2. Scope Shankesh Jewellers Limited endeavors to preserve the confidentiality of Unpublished Price Sensitive Information (UPSI) and to prevent its misuse. To achieve these objectives and incompliance with SEBI PIT Regulations, the company has adopted this Fair Disclosure Code. 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. Our Company is committed to timely and accurate disclosures based on applicable legal and regulatory requirements. 3. Investor Relations Officer The senior official appointed /nominated as such by the Company from time to time shall be the Investor Relations Officer (“IRO”) for the purpose of the Code. At present, the Chief Financial Officer of the Company shall act as Investor Relations Officer for the purpose of this code. The Investor Relations Officer shall be responsible for, and deal with, the dissemination of information and disclosure of Unpublished Price Sensitive Information. 4. Definitions “Unpublished Price Sensitive Information” (UPSI) means any information, relating to a company or its securities, directly or indirectly, that is not generally available which upon becoming generally available, is likely to materially affect the price of the securities and shall, ordinarily including but not restricted to, information relating to the following: i. financial results; ii. dividends; iii. change in capital structure; iv. mergers, de-mergers, acquisitions, delistings, 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 noting the normal course of business xvi. granting, withdrawal, surrender, cancellation or suspension of key licenses or regulatory approvals  It is clarified that UPSI is not restricted to information regarding the events mentioned above and may include direct or indirect information relating to the Company or its securities. “Generally Available Information” means information that is accessible to the public on a non‐ discriminatory basis. Information relating to the Company published on the website of stock exchanges or the Company’s website shall ordinarily be considered as Generally Available Information. "Compliance Officer" means any senior officer designated by Board of Directors for ensuring compliance of SEBI (Prohibition of Insider Trading) Regulations, 2015. Words and expressions used and not defined in this Policy shall have the meaning ascribed to them in the SEBI Listing Regulations, the Securities and Exchange Board of India Act, 1992, SEBI (Prohibition of Insider Trading) Regulations, 2015 and other applicable regulations. 5. Procedures for responding to any queries on news reports and/or requests for verification of market rumors by regulatory authorities. Appropriate, fair and prompt response shall be submitted to all queries on news reports and/ or requests for verification of market rumors received from regulatory authorities. 6. Procedures for Disclosure / dissemination of Information with reference to analysts, Institutional Investors and research personnel a) The Company and the Board shall ensure the information shared with analysts and research personnel is not Unpublished Price Sensitive Information. b) The Company shall develop best practices to make transcripts or records of proceedings of meetings with analysts and other investor relations conferences on the [Showing first 8,000 characters — download PDF for full document]