Aequs Limited has implemented a comprehensive Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) in compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015. The code, submitted to BSE Limited and National Stock Exchange of India Limited on December 10, 2025, establishes clear protocols for handling sensitive information and ensuring transparent market communication.

Regulatory Framework and Compliance

The code has been framed pursuant to Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, specifically under Regulation 8 read with Schedule A. The framework aims to ensure consistent, transparent, regular and timely public disclosure and dissemination of UPSI by the company.

Governance Structure and Key Personnel

The company has established a clear governance structure for UPSI management. The Board of Directors will designate a senior officer as the Chief Investor Relations Officer (CIRO) who will be responsible for ensuring timely, adequate, uniform and universal dissemination of information. Company Secretary and Compliance Officer Ravi Mallikarjun Hugar (Membership Number: A20823) has been appointed to oversee compliance with the code.

The code defines various categories of personnel including Designated Persons, Connected Persons, and Key Managerial Personnel (KMP), each with specific responsibilities and restrictions regarding UPSI handling.

UPSI Definition and Scope

The code provides a comprehensive definition of UPSI, which includes information not generally available that could materially affect security prices. Key categories of UPSI include:

• Financial results and dividend declarations
• Changes in capital structure
• Mergers, acquisitions, and business expansions
• Changes in key managerial personnel
• Credit rating changes
• Fundraising proposals
• Regulatory actions and legal proceedings

Disclosure Principles and Procedures

The CIRO must ensure prompt public disclosure of UPSI that would impact price discovery as soon as credible and concrete information becomes available. The code emphasizes uniform and universal dissemination to avoid selective disclosure and requires prompt dissemination of any information that gets disclosed selectively or inadvertently.

Legitimate Purpose Policy

The code includes a detailed policy for determining legitimate purposes for UPSI sharing. This covers sharing information in the ordinary course of business with partners, lenders, customers, suppliers, advisors, and consultants, provided such sharing is not intended to evade regulatory prohibitions.

Legitimate purposes include obtaining regulatory approvals, credit facilities, legal compliance, business development, and routine operations. The company must maintain a Structured Digital Database (SDD) containing details of all persons with whom UPSI is shared, preserved for at least eight years.

Trading Restrictions and Enforcement

The code establishes clear trading restrictions for employees and their immediate relatives during restricted trading periods. The restricted period applies from the end of every quarter until 48 hours after declaration of financial results. Violations may result in disciplinary action including termination, suspension, wage freeze, or forfeiture of stock options.

Digital Database and Record Maintenance

Aequs Limited will maintain comprehensive records of all UPSI disclosures through various means under relevant provisions of the Companies Act, 2013, SEBI Act, 1992, and listing agreements. The company must ensure adequate internal controls including timestamping and audit trails to prevent database tampering.

The Board reserves the power to review and amend the code periodically to ensure continued compliance with evolving regulatory requirements and best practices in corporate governance.

Aequs Limited has formally intimated the stock exchanges about the appointment of its Compliance Officer in accordance with regulatory requirements. The company submitted the intimation to both BSE Limited and National Stock Exchange of India Limited on December 10, 2025, ensuring compliance with listing obligations.

Compliance Officer Appointment Details

The company has provided specific details regarding the appointment of its Compliance Officer:

Mr. Hugar serves as the Compliance Officer under Regulation 6(1) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015. His appointment ensures the company maintains proper regulatory compliance and adherence to listing requirements.

Regulatory Compliance Framework

The intimation was submitted under Regulation 6(1) of SEBI's Listing Obligations and Disclosure Requirements Regulations, 2015. This regulation mandates listed companies to appoint a qualified Company Secretary as Compliance Officer to ensure proper adherence to listing requirements and regulatory obligations.

The communication was signed by Rajeev Kaul, Managing Director (DIN: 01468590), from Mumbai on December 10, 2025. The company requested the stock exchanges to take the intimation on record and disseminate the information appropriately to all concerned parties.

Company Information

Aequs Limited, formerly known as Aequs Private Limited, operates with Corporate Identity Number U80302KA2000PLC026760. The company maintains its registered office at Aequs Tower, Whitefield Main Road, Bengaluru, Karnataka, while its corporate office is located at Aequs SEZ in Belagavi, Karnataka. The company trades on BSE with scrip code 544634 and on NSE with symbol AEQUS.