SBI Funds Management Limited has adopted a comprehensive Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) to ensure uniformity and transparency in its dealings with stakeholders. The code, approved by the Board of Directors on July 08, 2026, aligns with Regulation 8 of the SEBI (Prohibition of Insider Trading) Regulations, 2015. It establishes a structured framework for the disclosure of events and occurrences that could impact price discovery in the market for the company’s securities.

Governance and Oversight

The code designates the Compliance Officer as the Chief Investor Relations Officer (CIRO), who acts as the primary point of contact for all disclosures. The CIRO is responsible for the prompt public disclosure of UPSI as soon as credible and concrete information becomes available. This officer ensures uniform and universal dissemination of information to avoid selective disclosure and oversees the sharing of information by employees. The CIRO also assesses the materiality of information and determines the timing and adequacy of proposed disclosures in consultation with the Board, senior management, or the Chief Financial Officer.

Disclosure Procedures

The company mandates that UPSI be disseminated promptly to stock exchanges and made available on its official website. In the event of inadvertent or selective disclosure, the CIRO must ensure the information is made generally available immediately. The code outlines specific procedures for responding to queries from regulatory authorities regarding market rumors, requiring appropriate, fair, and prompt responses signed by the CIRO or an authorized representative.

Engagement with Analysts and Investors

Interactions with analysts, institutional investors, and research personnel are strictly regulated to prevent the leakage of UPSI. The company ensures that any information shared during such meetings is generally available. If unpublished information is intended to be discussed, it must be made public prior to the meeting. Authorized spokespersons include the Chairman, MD & CEO, Executive Director, the CIRO, and members of the Investor Relations team. The company maintains records of conference calls and meeting transcripts, disclosing them to stock exchanges and hosting them on its website.

Legitimate Purpose and Data Management

The code defines the policy for determining ‘legitimate purpose’ for sharing UPSI, such as compliance with legal obligations, statutory inquiries, or bona fide business purposes like strategic alliances. Before sharing UPSI, recipients must be apprised via confidentiality agreements that they are deemed insiders and must not trade while in possession of the information. The company maintains a structured digital database internally to record the nature of UPSI shared and recipient details, ensuring non-tampering through time stamping and audit trails.

The code will be reviewed once every three years or as deemed fit by the Board. Any amendments will be promptly intimated to the stock exchanges and published on the company’s website.

Source: https://lodr-files.dhan.co/lodr-inputs/Company/INE640G01020/3e1820ed2d774833.pdf

SBI Funds Management Limited has authorized its Key Managerial Personnel (KMPs) to determine the materiality of events and information to ensure timely disclosures under Regulation 30 of the SEBI Listing Regulations. This decision, taken by the Board of Directors, aligns with the company's Policy on Determination of Materiality and aims to streamline the reporting process to stock exchanges.

The authorization allows designated executives to assess the significance of specific events and make appropriate disclosures without waiting for Board approval for every instance. This mechanism is intended to facilitate compliance with the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015.

The following KMPs have been vested with the authority to determine materiality:

The disclosure was submitted to the National Stock Exchange of India Limited and BSE Limited on July 21, 2026. SBI Mutual Fund Trustee Company Private Limited serves as the trustee for the entity.