Suraj Industries Ltd announced that its Board of Directors has approved amendments to the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) during a meeting held on March 19, 2026. The amendments ensure compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015.

Board Approval and Regulatory Compliance

The company informed BSE Limited about the amendments pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015. Company Secretary and Compliance Officer Snehlata Sharma signed the regulatory intimation, confirming the Board's approval of the updated fair disclosure framework.

Key Features of the Amended Code

The updated Code of Fair Disclosure establishes comprehensive principles for handling UPSI and ensuring transparent communication with stakeholders. The framework emphasizes prompt public disclosure of information that would impact price discovery and uniform dissemination to avoid selective disclosure.

The Company Secretary serves as the Chief Investor Relations Officer (CIRO), responsible for disseminating information and ensuring compliance with disclosure requirements. The code mandates that all UPSI be handled on a need-to-know basis within the organization.

UPSI Categories and Disclosure Framework

The amended code defines various categories of information considered as UPSI, including:

• Financial results and dividend announcements
• Changes in capital structure and business transactions
• Key managerial personnel changes and rating modifications
• Fund raising initiatives and management control agreements
• Regulatory actions and litigation outcomes
• License approvals and guarantee arrangements

Digital Database and Enforcement Measures

The company will maintain a Structured Digital Database containing names of persons with whom UPSI is shared, along with their Permanent Account Number (PAN) or authorized identifiers. The Compliance Officer oversees this database under Board supervision, ensuring adequate internal controls and confidentiality safeguards.

Violations of the code may result in disciplinary action including termination, suspension, or exclusion from employee stock option programs. The company has established a Vigil Mechanism for reporting suspected UPSI misuse while protecting whistleblowers from adverse action.

Legitimate Purpose Policy

The code includes a Policy for Determination of Legitimate Purposes, allowing UPSI sharing with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, and consultants in the ordinary course of business. Recipients of UPSI for legitimate purposes are considered insiders and must maintain confidentiality in compliance with PIT Regulations.

The amended code has been uploaded on the company's website at www.surajindustries.org for stakeholder reference and regulatory compliance.

Suraj Industries Limited has officially dispatched its second final reminder-cum-forfeiture notice on March 18, 2026, following the Rights Issue Committee's approval for collecting outstanding call money from shareholders who failed to respond to earlier notices.

Official Dispatch and Regulatory Compliance

The company submitted its regulatory filing to BSE Limited confirming the dispatch of the second final reminder-cum-forfeiture notice through both electronic mode and speed post. This action follows previous intimations dated January 20, 2026, January 28, 2026, February 19, 2026, and March 16, 2026, regarding the first call on partly paid-up equity shares.

Payment Period and Outstanding Amounts

The second final reminder-cum-forfeiture notice establishes a 15-day payment window for shareholders to settle their outstanding obligations. The company previously collected substantial amounts from responsive shareholders while maintaining strict enforcement for remaining defaults.

Previous Collection Results

The Rights Issue Committee's March 16, 2026 meeting reviewed the response to the first final reminder-cum-forfeiture notice, revealing significant collection success from the majority of shareholders.

Payment Instructions and Compliance Requirements

The company has established specific payment procedures to ensure regulatory compliance and proper processing. Cash payments are strictly prohibited, and no partial payments will be accepted under any circumstances.

Share Conversion and Corporate Actions

The committee approved the conversion of 88,48,110 partly paid-up equity shares from ₹2.50 paid-up status to ₹5.00 paid-up status, each having a face value of ₹10.00. The shares will transition from ISIN IN9170U01027 to ISIN IN9170U01035.

Forfeiture Consequences

The company has clearly warned that failure to pay the first call money within the stipulated period will render the partly paid-up equity shares, including amounts already paid, liable to be forfeited in accordance with the Companies Act, Articles of Association, and the Letter of Offer dated October 9, 2025. Third-party bank account payments are liable to be rejected, and the company reserves the right to reject delayed receipts after April 3, 2026.