Caliber Mining and Logistics Limited submitted its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information to Indian stock exchanges on July 24, 2026. The filing, made pursuant to Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, details the company's framework for ensuring transparency and preventing misuse of unpublished price sensitive information (UPSI). This regulatory submission reinforces the company's compliance infrastructure regarding investor disclosures and insider trading protocols.

The submission was directed to the National Stock Exchange of India Ltd and BSE Limited by Riddhi Harish Varma, Company Secretary and Compliance Officer. The document serves as an intimation of the code framed under Regulation 8(1) of the SEBI PIT Regulations. The Board of Directors had originally formulated this code during a meeting held on December 17, 2024, establishing the procedural guidelines that are now being formally recorded with the exchanges.

Key Provisions of the Code

The code mandates strict adherence to confidentiality regarding UPSI, which includes information likely to materially affect the price of the company's securities upon becoming generally available. Key operational requirements include:

• Designated Persons: The code applies to promoters, board members, key managerial personnel, auditors, and specific employees with access to UPSI. Immediate relatives of these designated persons are also subject to restrictions.
• Trading Windows: Trading windows are closed at least seven calendar days prior to the first day of each quarter (April, July, October, January) and remain closed until two calendar days after the declaration of financial results. Additional closures apply around major announcements such as mergers or capital raises.
• Pre-Clearance: Designated persons must obtain prior approval from the Compliance Officer for any transaction exceeding ₹10,00,000 in a calendar quarter. Approvals are valid for seven calendar days.
• Contra Trade Restrictions: Designated persons cannot enter into opposite transactions (buying after selling or vice versa) within six months unless approved by the Compliance Officer.

Disclosure Mechanisms

The code designates the Company Secretary as the Chief Investor Relations Officer, responsible for overseeing corporate disclosures and coordinating with stock exchanges. In cases of inadvertent selective disclosure, the officer must ensure immediate general availability of the information. The company is required to disseminate UPSI uniformly to avoid selective advantage, utilizing media, stock exchange filings, and its official website.

Violations of the code may result in penalties including wage freezes, suspension, recovery, or clawback provisions. Serious breaches will be reported to SEBI for appropriate action. The code emphasizes that every designated person is individually responsible for compliance, extending to their immediate relatives' trading activities.

Caliber Mining & Logistics Limited has authorised six Key Managerial Personnel (KMPs) to determine the materiality of events or information and to make subsequent disclosures to stock exchanges. This internal governance measure, implemented on July 24, 2026, ensures that material information is promptly identified and disclosed in compliance with regulatory requirements, thereby enhancing transparency for investors.

The authorisation was made pursuant to Regulation 30(5) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (SEBI LODR Regulations). Under this provision, listed entities must designate specific individuals responsible for assessing whether an event or piece of information is material enough to warrant public disclosure under Regulation 30.

The company notified both the National Stock Exchange of India Ltd and BSE Limited of this decision. The intimation serves as a formal record that these specific executives hold the authority to trigger disclosure obligations, streamlining the compliance process and ensuring accountability within the senior management structure.

The following Key Managerial Personnel have been granted this authority:

Governance Implications

This designation aligns Caliber Mining & Logistics Limited with standard corporate governance practices mandated by SEBI. By explicitly naming the KMPs responsible for materiality assessments, the company reduces ambiguity in its disclosure workflow. This clarity helps prevent delays in reporting price-sensitive information, which is critical for maintaining market integrity and investor confidence.

The inclusion of both financial leadership (CFO) and operational oversight (Managing Director and Whole Time Directors) alongside the Company Secretary ensures a balanced approach to evaluating materiality. This multi-disciplinary team can assess both quantitative financial impacts and qualitative strategic implications of various events before deciding on disclosure.