Indo-MIM Limited has adopted a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) to comply with the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015. The Governing Board approved the framework on Aug 07, 2026, aiming to ensure transparency, fairness, and uniformity in disclosing information that could impact the company’s security prices. This move strengthens the firm’s internal controls against insider trading and ensures equitable access to material information for all investors.

The filing was submitted to the National Stock Exchange of India Limited and BSE Limited pursuant to Regulation 8(2) of the SEBI PIT Regulations. Santosh Kumar Dash, Company Secretary and Compliance Officer, signed the intimation. The Code is also available on the company’s website at www.indo-mim.com .

Key Provisions of the Fair Disclosure Code

The Code establishes strict protocols for handling UPSI, designating the Company Secretary as the Chief Investor Relations Officer (CIRO) unless otherwise appointed by the Board. The CIRO must approve all information dissemination in advance. In cases of accidental disclosure, the responsible party must immediately inform the CIRO, who will then notify the Managing Director, Chief Executive Officer, or Chief Financial Officer.

Disclosure Principles

To adhere to Schedule A of the SEBI PIT Regulations, Indo-MIM Limited has outlined several core principles:

• Timely Public Disclosure: The company will promptly disclose any UPSI that impacts price discovery once credible and concrete information is available.
• Uniform Dissemination: UPSI will be communicated to stock exchanges and published on the website before being released to media or analysts to avoid selective disclosure.
• Restricted Communication: Employees are prohibited from responding to enquiries from stock exchanges, media, or others unless authorized by the CIRO or senior management.
• Final Decisions Only: Public announcements will be made only after a final or definitive decision is taken. The company will not disclose proposals still in progress or under negotiation if doing so could prejudice its legitimate interests.

Handling UPSI for Legitimate Purposes

The Code defines "Legitimate Purpose" to include sharing UPSI with partners, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, and other consultants in the ordinary course of business. Any person receiving UPSI for such purposes is considered an "Insider" and must maintain confidentiality.

Access to UPSI is restricted to a need-to-know basis. However, exceptions are made for transactions that:

• Entail an obligation to make an open offer under Takeover Regulations, where the Board believes sharing information is in the company’s best interest.
• Do not attract an open offer obligation but require sharing information in the company’s best interest, provided the UPSI is made Generally Available Information at least two trading days prior to the transaction.

In such cases, parties must execute confidentiality and non-disclosure agreements and refrain from trading in the company’s securities while in possession of UPSI.

Database Maintenance and Review

Indo-MIM Limited is required to maintain a structured digital database containing details of persons or entities with whom UPSI is shared, including their Permanent Account Number (PAN) or other legal identifiers. This database must include time-stamping and audit trails to prevent tampering and be retained for a minimum of eight years, or longer if enforcement proceedings are pending.

Entries for information received from outside the organization must be recorded within two calendar days of receipt. The Board of Directors will review the Fair Disclosure Code and the Policy for Determination of Legitimate Purpose at least once every three financial years, updating it as necessary to align with any amendments to the SEBI PIT Regulations.

Indo-MIM Limited has authorized its Key Managerial Personnel (KMPs) to determine the materiality of events and information for regulatory disclosure. The Board of Directors made this decision on Aug 07, 2026, pursuant to Regulation 30(5) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements), Regulations, 2015, read with the company’s Material Events Policy.

This authorization empowers specific executives to assess whether an event constitutes a material fact requiring immediate disclosure to stock exchanges. The move streamlines the compliance process by delegating the determination of materiality to senior management, ensuring timely adherence to SEBI Listing Regulations. The disclosure was filed with both the National Stock Exchange of India Limited and BSE Limited.

The Board authorized the following three individuals to exercise this authority:

Santosh Kumar Dash, the Company Secretary and Compliance Officer with Membership No. F11798, signed the communication on behalf of the company. The disclosure is also available on the company’s website at www.indo-mim.com .

Regulatory Context

Regulation 30 of the SEBI Listing Regulations mandates listed entities to make timely disclosure of material events to recognized stock exchanges. Regulation 30(5) specifically allows the board to authorize KMPs to determine the materiality of events or information. This delegation ensures that decisions regarding disclosure are made by personnel with direct oversight of corporate governance and financial reporting.

The authorization applies to all future determinations of materiality unless revoked or amended by the Board. The company must continue to adhere to its Material Events Policy while exercising this delegated authority.