Aakaar Medical Technologies Limited has informed the National Stock Exchange of India Limited that its Board of Directors approved the updation and revision of its "Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information" on May 14, 2026. The intimation was made pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended. The revised code has been made available on the company's official website at https://aakaarmedical.in/disclosures-as-per-regulation-46-of-the-sebi-lodr-regulations/ .

Policy Overview and Approval Details

The updated code carries Policy No. 07/CS/COC/2024-25 (Revision: 01/2026) and was prepared by Company Secretary Anoopkumar V. Pillai, and approved by Managing Director Dilip Ramesh Meswani and CEO & Director Dr. Rahul Sawakhande. The following table summarises the key administrative details of the policy:

Objective and Scope

The primary objective of the code is to establish a framework for the fair disclosure of events and occurrences that could impact price discovery in the market for the company's securities. The code applies to all disclosures of Unpublished Price Sensitive Information (UPSI) by the company, its subsidiaries, associates, and companies under the same management. It has been framed in compliance with Regulations 3, 8(1), and Schedule 'A' of the SEBI Insider Trading Regulations.

Key Principles of Fair Disclosure

The code mandates that Aakaar Medical Technologies adhere to the following core principles:

• Prompt public disclosure of UPSI that would impact price discovery, as soon as credible and concrete information comes into being
• Uniform and universal dissemination of UPSI to avoid selective disclosure
• Prompt remediation if UPSI is disclosed selectively or inadvertently
• Appropriate response to queries on news reports and requests for verification of market rumors from regulatory authorities
• Maintenance of transcripts or records of analyst meetings and investor relations conferences on the official website
• Need-to-know basis handling of all UPSI for legitimate purposes
• Designation of a senior officer as Investor Relations Officer for dissemination of information and UPSI disclosure

Compliance Officer Responsibilities

The Compliance Officer holds primary responsibility for overseeing all disclosures under the code. Key responsibilities include ensuring regulatory conformity, coordinating with the Board and recognised stock exchanges, verifying the correctness and authenticity of filed information, and monitoring the investor grievance redressal email address. The Compliance Officer is also required to approve disclosures in advance and respond promptly to any selective disclosure of UPSI.

Interactions with Analysts and Investors

The code provides detailed guidelines for interactions with equity research analysts, institutional investors, and research personnel. The company is required to ensure that no UPSI is selectively disclosed during such interactions. For structured communication events, simultaneous audio broadcast over phone, internet, or other suitable media is to be arranged, with recordings made available on the official website for a period of one year. Unanticipated questions raising material issues may be taken on notice, with public announcements made prior to responding if the answer involves UPSI.

Digital Database and Legitimate Purposes

The Board is required to maintain a structured digital database containing the nature of UPSI and the names of persons or entities with whom UPSI has been shared under Regulation 3 of the Insider Trading Regulations, along with their Permanent Account Number (PAN) or any other legally authorised identifier. The database must be maintained with adequate internal controls, including time stamping and audit trails. The code also includes an Annexure A — "Policy for Determination of Legitimate Purposes" — which identifies permissible exceptions for sharing UPSI in the ordinary course of business, including with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, and other advisors or consultants, provided such sharing is not intended to evade or circumvent the prohibitions under the Insider Trading Regulations.

Aakaar Medical Technologies Limited has filed its Structured Digital Database (SDD) compliance certificate with the National Stock Exchange of India Limited for the financial year ended March 31, 2026. The submission was made on May 09, 2026, pursuant to Regulations 3(5) and 3(6) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, read with NSE Circular no. NSE/CML/31 dated October 18, 2024. The certificate was signed by Anoopkumar Pillai, Company Secretary & Compliance Officer of the company.

SDD Compliance Certificate Highlights

The compliance certificate was issued by Devendra V Deshpande, Practicing Company Secretary and Proprietor of DVD & Associates, Company Secretaries, based in Pune. The certificate confirms the company's adherence to the SDD requirements under the PIT Regulations for the financial year ended March 31, 2026. The following key compliance points were certified:

• The company has a Structured Digital Database in place
• Controls exist as to who can access the SDD
• All UPSI disseminated during the year have been captured in the database
• The system has captured the nature of UPSI along with date and time
• The database has been maintained internally, and an audit trail is maintained
• The database is non-tamperable and has the capability to maintain records for 8 years

UPSI Events and Technical Issue

The certificate details the total number of UPSI events required to be captured and the company's compliance status for the financial year.

The company informed the certifying authority of a temporary technical issue in its SDD during February 2026. The issue was promptly resolved, and all relevant UPSI-related entries were duly recorded. No data loss or integrity issues were reported, and the matter was placed before the Audit Committee and noted.

Certification Details

The compliance certificate was issued by DVD & Associates, Company Secretaries, with offices in Pune, Mumbai, Kolhapur, Yavatmal, and Dubai. The relevant certification details are as follows:

Aakaar Medical Technologies confirmed that no non-compliance was observed during the financial year ended March 31, 2026, underscoring the company's adherence to SEBI's insider trading prevention framework.