Bagmane Prime Office REIT, acting through its Investment Manager Bagmane Realty Investment Manager Private Limited, has filed its Policy on Unpublished Price Sensitive Information and Dealing in Securities along with the Code of Practices and Procedures for Fair Disclosure with the National Stock Exchange of India Limited and BSE Limited. The filing, dated May 15, 2026, was made pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, and has been signed by Venkatesh Ranganath P, Company Secretary and Compliance Officer.

Policy Overview and Approval

The Policy was approved by the Board of Directors of Bagmane Realty Investment Manager Private Limited on 28th December, 2025. It is applicable to Bagmane Prime Office REIT, the Manager, Holdco, and the Special Purpose Vehicles (SPVs), collectively referred to as Relevant Parties, as well as their respective Designated Persons with respect to units of the Bagmane REIT.

Scope and Applicability

The Policy applies to a broad set of stakeholders connected to the Bagmane REIT. Designated Persons include, but are not limited to, the Board of Directors, key personnel of the Manager, the Chief Executive Officer, the Chief Financial Officer, employees up to two levels below the Chief Executive Officer, support staff with access to UPSI, Sponsor(s) and members of the Sponsor Group, and any other category of persons as required under Applicable Laws. The SPVs covered under the Policy include Bagmane Rio Private Limited and Bagmane Green Power LLP, while the Holdco is identified as Bagmane Developers Private Limited.

Key Provisions on UPSI and Fair Disclosure

The Policy outlines a comprehensive framework for the identification, preservation, and disclosure of Unpublished Price Sensitive Information (UPSI). Key categories of UPSI include:

• Financial results and distributions
• Changes in capital structure
• Mergers, de-mergers, acquisitions, delistings, disposals, and expansion of business
• Changes in key managerial personnel (other than due to superannuation or end of term)
• Changes in ratings (other than ESG ratings)
• Fraud or defaults by the REIT, its promoter, director, or key managerial personnel
• Initiation of forensic audits and receipt of final forensic audit reports
• Actions initiated or orders passed by regulatory, statutory, enforcement, or judicial bodies
• Granting, withdrawal, surrender, cancellation, or suspension of key licenses or regulatory approvals

The Board is required to ensure prompt public disclosure of UPSI in a universal and uniform manner through widely circulated media and/or Stock Exchanges, and must guard against selective disclosure.

Trading Window and Pre-Clearance Requirements

The Policy establishes a structured trading window mechanism for Designated Persons. The trading window shall remain closed from a period not later than the first day after the end of every quarter until 48 hours after the declaration of financial results. Designated Persons and their Immediate Relatives are prohibited from trading during closed window periods.

Pre-clearance from the Compliance Officer is mandatory before any trade in Bagmane REIT units. Once approved, the trade must be executed by the end of the second Trading Day following receipt of approval. Designated Persons who trade in units are prohibited from entering into a contra trade during the next six months following the prior transaction. Continual disclosure of unit transactions is required within two Trading Days where the transaction value exceeds Rupees 10 lakhs.

Institutional Mechanisms and Penalties

The Compliance Officer is responsible for maintaining a structured digital database of UPSI-related records, which must be preserved for a period of not less than eight years after completion of relevant transactions. The Audit Committee is required to review compliance with the PIT Regulations and the Policy at least once in a financial year.

Designated Persons or Insiders found in violation of the Policy and PIT Regulations are subject to disciplinary actions, which may include wage freeze, suspension, recovery clawback, ineligibility for future participation in stock option plans, or termination. Profits arising from violating transactions are liable to be disgorged and remitted to SEBI for credit to the Investor Protection and Education Fund. The Policy also provides for protection against retaliation or victimisation of employees who file a Voluntary Information Disclosure Form or assist SEBI in any investigation or enforcement proceeding.

The Policy is available on the official website of Bagmane Prime Office REIT and has been simultaneously filed with both Stock Exchanges in accordance with regulatory requirements.