A-One Steels Adopts Corporate Disclosure Code

Date: October 01, 2026

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A-One Steels India Ltd has framed a Code of Corporate Disclosure Practices pursuant to Regulation 8 of the SEBI (Prohibition of Insider Trading) Regulations, 2015
The code has been submitted to BSE Limited and National Stock Exchange of India Limited
The code has been uploaded on the Company's website at https://www.aonesteelgroup.com/investors
The submission was made by Pooja Sara Nagaraja, Company Secretary and Compliance Officer (Membership No: A52496)

The Board shall designate a senior officer as Chief Investor Relations Officer
Responsible for timely, adequate, uniform and universal dissemination of Unpublished Price Sensitive Information (UPSI)
Reports to Managing Director/Chief Executive Officer and coordinates with Compliance Officer
Ensures information shared with analysts is not UPSI
Oversees disclosure of UPSI to analysts, shareholders and media
Educates employees on disclosure policies and procedures
All UPSI disclosure must be first approved by the Chief Investor Relations Officer

Employees/Directors must direct all market rumor queries to Chief Investor Relations Officer
Chief Investor Relations Officer consults with MD/CEO for appropriate response
Decides necessity of public announcements to verify/deny rumors
All requests must be documented and preferably in writing
No disclosure without MD/CEO approval

Only authorized persons may disclose information to analysts
Chief Investor Relations Officer must attend all analyst meetings
Only public information may be provided to analysts unless UPSI approval obtained
Unanticipated questions requiring UPSI must be handled through public dissemination first
UPSI handled on need-to-know basis only

UPSI disseminated to stock exchanges first, then to press
Information supplemented on company website
Press releases copied to Chief - Group Corporate Affairs and Media for group website updates
Stock exchange filings also posted on company website

Sharing UPSI in ordinary course of business or on need-to-know basis
Includes sharing with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, advisors or consultants
Must not be carried out to evade or circumvent regulatory prohibitions

Investigation/query from statutory/governmental authorities (MCA, Income Tax, SEBI, RBI, etc.)
Court/tribunal proceedings (NCLT, NCLAT, arbitration)
Compliance with applicable laws and regulations
Contractual obligations (due diligence for M&A, joint ventures, share purchase agreements)
Business requirements with Promoters and their advisors
Professional services from intermediaries, fiduciaries, consultants
Business partners essential to fulfill contract terms
Evaluation of new products and business opportunities
Statutory consolidation requirements
Processes leading to Schedule III disclosure events

1. Satisfy that information is UPSI and sharing is for legitimate purpose

2. Identify recipients

3. Notify recipients and execute confidentiality/non-disclosure agreements

4. Share via email (direct without copies), hard copy, electronic mode, or server access

5. Maintain database of recipients with PAN/identifier, time stamps, and audit trails

Periodic annual audit to ensure system integrity
Policy reviewed periodically according to internal control changes and regulatory requirements
Legal provisions override policy in case of inconsistency