Luxury Time approved a revised Whistle Blower Policy during its board meeting held on August 14, 2026. The updated framework aims to strengthen the company’s vigil mechanism by providing an effective channel for reporting genuine concerns regarding unethical conduct, fraud, or financial irregularities.

The revision ensures compliance with Regulation 22 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as well as Sections 177(9) and 177(10) of the Companies Act, 2013. The policy establishes safeguards against victimisation for whistle blowers who report issues in good faith.

Key Provisions

The revised policy outlines specific mechanisms for reporting and investigation:

• Reporting Channels: Disclosures can be made via email to the Company Secretary & Compliance Officer or through written communication to the registered office.
• Audit Committee Oversight: The Audit Committee oversees the implementation of the vigil mechanism, including appointing investigators and reviewing findings.
• Direct Access: In exceptional cases, whistle blowers may report directly to the Chairperson of the Audit Committee.
• Confidentiality: The identity of the whistle blower remains confidential unless disclosure is mandated by law or necessary for investigation.

The company has hosted the revised policy on its website for stakeholder reference. The framework excludes routine employment grievances such as salary or promotion disputes, focusing instead on misconduct involving fraud, corruption, or violation of laws.

Governance Impact

This update reinforces Luxury Time’s commitment to corporate governance and ethical business practices. By formalising the process for handling protected disclosures, the company aims to facilitate early detection of potential risks and maintain transparency in its operations.

The Board of Directors of Luxury Time approved the revised Corporate Social Responsibility (CSR) Policy during its meeting held on August 14, 2026. The update aligns the company’s social initiatives with the latest provisions of Section 135 of the Companies Act, 2013 and the Companies (Corporate Social Responsibility Policy) Rules, 2014. The policy aims to create sustainable social value through inclusive growth, environmental responsibility, and community development.

Governance and Implementation

The revised policy defines a clear governance framework comprising the Board of Directors and a dedicated CSR Committee. The Board retains overall responsibility for ensuring statutory compliance and approving the Annual Action Plan. The CSR Committee assists in formulating the policy, identifying projects, monitoring progress, and reviewing fund utilization.

Key governance responsibilities include:

• Formulating and recommending the CSR Policy and Annual Action Plan to the Board.
• Identifying eligible implementing agencies for project execution.
• Monitoring the implementation status and financial utilization of approved projects.
• Recommending modifications to the Annual Action Plan based on reasonable justification.

Focus Areas and Expenditure

Luxury Time will undertake CSR activities in areas specified under Schedule VII of the Companies Act, 2013. The primary focus areas include eradicating hunger and poverty, promoting education and vocational skills, ensuring gender equality, and supporting environmental sustainability. The company may also contribute to disaster management, rural development, and sports promotion.

The company must spend at least 2% of its average net profits from the three immediately preceding financial years on approved CSR activities. Administrative overheads are capped at limits prescribed by the CSR Rules, while expenses directly attributable to specific projects are excluded from this overhead calculation.

Project Identification and Monitoring

Projects will be identified based on community needs, expected social impact, and resource availability. Preference is given to local areas around the company’s operations, though activities can be undertaken anywhere in India. Implementation can occur directly by the company, through eligible registered agencies, or in collaboration with other companies where permitted.

The policy mandates periodic monitoring of project progress and fund utilization. Where applicable under the CSR Rules, an independent agency will conduct impact assessments of eligible projects. Any surplus arising from CSR activities will not form part of business profits but will be utilized solely for further CSR purposes. The full text of the revised policy has been uploaded to the company’s website for stakeholder reference.