Updates

Ref : GAJA/CS/02/2026-27 Date: August 26, 2026 To, To, National Stock Exchange of India Limited BSE Limited (“BSE”) (“NSE”) Listing Department Listing Department Corporate Relationship Department Exchange Plaza, C-1 Block G, Bandra Kurla Phiroze Jeejeebhoy Towers, Complex Bandra [E], Mumbai – 400051 Dalal Street, Fort, Mumbai - 400 001 NSE Scrip Symbol: GAJA BSE Scrip Code: 544885 ISIN: INE18UN01038 ISIN: INE18UN01038 Subject: Intimation under Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Dear Sir/ Madam, Pursuant to Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (‘SEBI PIT Regulations’), please find attached herewith the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information framed under Regulation 8 (1) of SEBI PIT Regulations which forms part of the Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons of the Company. This is for your information and records. Thanking You, For Gaja Alternative Asset Management Limited Ishu Jain Company Secretary and Compliance Of(cid:976)icer Membership No.: F10679 Address: 1402 Tower 2B One World Center, Senapati Bapat Marg Lower Parel, Delisle Road, Mumbai, Mumbai, Maharashtra, India, 400013 Encl: Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information GAJA ALTERNATIVE ASSET MANAGEMENT LIMITED Corporate Of(cid:976)ice :1402, Tower 2B, One World Center, Registered Of(cid:976)ice: 302, 3rd Floor, Kanchenjunga S.B. Marg, Lower Parel, Mumbai –400013 Building 18, Barakhamba Road, New Delhi –110001 Tel: 91-22-2421 2280 | Email: Compliance@gajacapital.com | CIN: U67190DL1999PLC099260 | Website: www.gajacapital.com GAJA ALTERNATIVE ASSET MANAGEMENT LIMITED (Formerly known as GAJA ALTERNATIVE ASSET MANAGEMENT PRIVATE LIMITED) Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons Original Policy : COC(PIT)/01/February 27, 2025 Amendment : COC(PIT)/02/August 24, 2026 1. PREAMBLE In terms of the Regulation 9(1) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended, (“SEBI PIT Regulations”), the board of directors (“Board”) of every listed company shall ensure that the chief executive officer or managing director formulates a code of conduct with the Board’s approval to regulate, monitor and report trading by its designated persons and immediate relatives of designated persons towards achieving compliance with the SEBI PIT Regulations, adopting the minimum standards set out in Schedule B of the SEBI PIT Regulations. Pursuant to Regulation 9(1) of the SEBI PIT Regulations, Gaja Alternative Asset Management Limited (“Company”) hereby adopts this code (“Code”) to regulate, monitor and report trading by its designated persons and immediate relatives of designated persons towards achieving compliance with the SEBI PIT Regulations. This Code aims to preserve the confidentiality and prevent the misuse of any unpublished price sensitive information and to put in place a policy for prohibition of insider trading on the basis of unpublished price sensitive information. All designated persons and immediate relatives thereof shall be bound by the SEBI PIT Regulations and this Code. The Code shall be applicable to the Company with effect from the listing of the equity shares of the Company on one or more recognized stock exchanges. 2. CODE The Code shall be called “Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons”. This Code will come into force with immediate effect. 3. DEFINITIONS “Company” means Gaja Alternative Asset Management Limited. “Compliance Officer” means the Company Secretary or any senior officer, designated so and reporting to the Board, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under these regulations and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the preservation of unpublished price sensitive information, monitoring of trades and the implementation of the codes specified in these regulations under the overall supervision of the Board. “Connected Person” shall have the meaning assigned to such term under the SEBI PIT Regulations. “Designated Persons” shall mean: (i) Promoters of the Company; (ii) Directors and key managerial personnel of the Company and its subsidiaries; (iii) Senior management of the Company including employees up to two levels below the managing director of the Company and its subsidiaries; (iv) Officers in the grade of Associates and above of the Company and its subsidiaries; (v) Employees of such other functions of the Company and its subsidiaries, who are in possession or likely to be in possession of Unpublished Price Sensitive Information; (vi) operational heads and unit heads of the Company and its subsidiaries, and employees up to two levels below operational heads and unit heads of the Company and its subsidiaries, irrespective of their functional role in the company or ability to have access to Unpublished Price Sensitive Information (vii) Any support staff of the Company, subsidiaries, intermediary or fiduciary such as IT staff or secretarial staff who have access to unpublished price sensitive information; (viii) Such other persons who may be designated as such from time to time, by the Board in consultation with the Compliance Officer, for the purpose of this Code, on the basis of their role and function in the organisation and the access that such role and function would provide to unpublished price sensitive information in addition to seniority and professional designation; (ix) Immediate Relatives of persons specified above and HUF of which such designated person is a member unless stated otherwise. Original Policy : COC(PIT)/01/February 27, 2025 Amendment : COC(PIT)/02/August 24, 2026 “Fiduciaries” collectively to be referred as professional firms such as auditors, accountancy firms, law firms, analysts, consultants, banks, valuation agencies, fund accountants etc. assisting or advising the Company. “Financially Literate” shall mean a person who has the ability to read and understand basic financial statements i.e., balance sheet, profit and loss account, and statement of cash flows. “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, including information published on the website of stock exchanges on which the securities of the Company are listed. “Immediate Relative” means a spouse of a person, and includes parent, sibling, and child of such person or of the spouse, any of whom is either dependent financially on such person, or consults such person in taking decisions relating to trading in securities. “Insider” means any person who is: i) a Connected Person; or ii) in possession of or having access to Unpublished Price Sensitive Information. “Key Managerial Personnel” or “KMP” shall have the same meaning assigned to it under the Companies Act, 2013, as amended from time to time. “Material Subsidiary” shall have the same meaning assigned to it under Regulation 16(1)(c) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to time. “Promoter” shall have the meaning assigned to it under the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 or any modification thereof. “Promoter Group” shall have the meaning assigned to it under the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 or any modification thereof. “SEBI” shall mean Securities and Exchange Boar [Showing first 8,000 characters — download PDF for full document]