Intimation under Regulation 8(2) of Securities and Exchange Board of India (Prohibition of Insider Trading ) Regulations, 2015

Mart Limited Date: 28.08.2026 National Stock Exchange of India Limited BSE Limited (“BSE”) Listing Department Listing Department Exchange Plaza, C-1 Block G, Bandra Kurla Corporate Relationship Department Phiroze Complex, Bandra (E), Mumbai-400051 Jeejeebhoy Towers, Dalal Street Fort, Mumbai-400001 NSE Scrip Symbol: LALITHAA BSE Scrip Code: 544879 ISIN: INE0K9O01026 ISIN: INE0K9O01026 Sub: Intimation under Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Dear Sir/ Madam, This is to inform you that, pursuant to Regulation 8(1) of the Securities Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”), Lalithaa Jewellery Mart Limited (“Company”) has framed a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information.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, the same is being submitted herewith. The policy has also been uploaded on the Company’s website www.lalithaajewellery.com. This is for your information and records Thanking you. Yours faithfully, For Lalithaa Jewellery Mart Limited Jitendra Kumar Pal Company Secretary & Compliance Officer ACS-15338 Regd. Off : 123, Usman Road, Panagal Park, T. Nagar, Chennai 600 017. Phone : 2814 1155, 2814 1177, 2814 1188 Fax : 91-44-2814 4311 E-mail : info @ lalithaajewellery.com www.lalithaajewellery.com CIN : U36911TN1985PLC012417 Lalithaa Jewellery Mart Limited CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION Under Regulation 8 and 3(2A) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION 1.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Trading) Regulations, 2015 requires the Company to formulate a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (“Fair Disclosure Code”). 2. Scope Lalithaa Jewellery Mart Limited endeavors to preserve the confidentiality of unpublished price sensitive information (UPSI) and to prevent its misuse. To achieve these objectives and in compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015, the Company has adopted this fair disclosure code. This 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. Definitions a) "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, dividends; (ii) change in capital structure; (iii) mergers, de‐mergers, acquisitions, delisting, disposals, expansion of business; (iv) Changes in key managerial personnel and such other transactions; (v) 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. b) "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. c) "Compliance Officer" means any senior officer designated by Board of Directors for ensuring compliance of SEBI (Prohibition of Insider Trading) Regulations, 2015. Unless the Board designates any personnel as compliance officer, the chief financial officer shall be deemed to be the Compliance Officer. 4. Fair disclosure of Unpublished Price Sensitive Information a) The Company shall promptly disclose to public, UPSI that would impact price discovery no sooner than credible and concrete information comes into being in order to make such information generally available. b) The Company shall follow uniform and universal dissemination of unpublished price sensitive information to avoid selective disclosure. c) The Chief Financial Officer of the Company has been designated as the Chief Investor Relations Officer of the Company to deal with dissemination of information and disclosure of UPSI. d) Prompt dissemination of UPSI that gets disclosed selectively, inadvertently or otherwise to make such information generally available. e) The Company shall ensure appropriate and fair response to queries on news reports and requests for verification of market rumors by regulatory authorities. f) The Company shall ensure that information shared with analysts and research personnel is not UPSI. g) Meetings / calls with analysists analysts or investor relations conferences shall be transcripted or recorded on the official website of the Company to ensure official confirmation and documentation of disclosures made. h) The UPSI can be shared as an exception by an insider for legitimate purposes, in the ordinary course of business of the Company. Policy for determination of Legitimate Purposes for which UPSI can be shared, has been formulated and mentioned below. i) The Board of Directors of the Company, in sync with applicable laws, rules and regulations, may amend / substitute any provision(s) with a new provision(s) or replace this entire Code with a new code. Any amendment to the Code, upon approval of the Board of the Company shall be intimated to the Stock Exchanges and shall also be updated on the Company’s website. 5. The UPSI can be shared as an exception by an insider for legitimate purposes, in the ordinary course of business of the Company. Policy for determination of Legitimate Purposes for which UPSI can be shared, has been formulated and attached with this Code and marked as “Annexure – A”. 6. The Board of Directors of the Company, in accordance with applicable laws, rules and regulations, may amend / substitute any provision(s) with a new provision(s) or replace this entire Code with a new Code. Any amendment to the Code, upon approval of the Board of the Company shall be intimated to the Stock Exchanges and shall also be updated on the Company’s website. Annexure A POLICY FOR DETERMINATION OF LEGITIMATE PURPOSES [Pursuant to Regulation 3 (2A) of SEBI (Prohibition of Insider Trading) Regulations, 2015] 1. PREFACE This Policy, which is part of "Codes of Fair Disclosure and Conduct" formulated under Regulation 8 of SEBI (Prohibition of Insider Trading) Regulations 2015, is known as "Policy for Determination of Legitimate Purposes" hereinafter referred to as the "Policy". This Policy is prepared in accordance with Regulation 3(2A) of SEBI (Prohibition of Insider Trading) (Amendment) Regulations, 2018. 2. PURPOSE The policy is formulated with an objective to identify 'Legitimate Purposes' for which an insider is entitled to communicate, provide, or allow access to any unpublished price sensitive information (UPSI), relating to the Company, its listed securities or securities which are proposed to be listed, to any person including other insiders, in the ordinary course of business. 3. DEFINITIONS a) "Insider” means any person in receipt of UPSI pursuant to a "legitimate purpose" and due notice shall be given to such persons (Insiders) to maintain confidentiality of such unpublished price sensitive information in compliance with these regulations. b) "Legitimate Purposes" shall mean sharing of UPSI in the ordinary course of business by an Insider with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals or other adviso [Showing first 8,000 characters — download PDF for full document]