EAAA India Adopts UPSI Fair Disclosure Code

Date: November 2, 2026

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Policy Adoption and Disclosure:

EAAA India Alternatives Limited has intimated the National Stock Exchange of India Limited and BSE Limited about the framing of its 'Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI)'.
The policy was approved by the Company's Board of Directors at its meeting held on November 18, 2024.
The policy is Version 1.0 and is a new policy, with the Compliance Team designated as the Policy Owner.
The intimation is also available on the Company's website at https://www.eaaa.in in compliance with SEBI Listing Regulations.

Policy Content Summary:

1. Prompt Public Disclosure of UPSI:

The policy mandates prompt disclosure of events impacting price discovery as soon as credible information is available.
It provides an indicative list of 17 material and/or price-sensitive events requiring disclosure, along with their specific trigger points for disclosure.

2. Uniform and Universal Dissemination of UPSI:

Information must be disclosed to the Stock Exchanges first before being released to media/analysts.
If UPSI is accidentally disclosed to a section of the market first (e.g., at an investor meet), it must be immediately provided to the exchanges.
The Chief Operating Officer (COO) is responsible for overseeing the dissemination and disclosure of information, which requires their prior approval.

3. Response to Media Comments and Rumours:

The Company will provide appropriate and fair responses to queries on news reports and requests for verification of market rumours by regulatory authorities, without compromising on its UPSI disclosure obligations.

4. Policy for Determination of 'Legitimate Purpose' for Sharing UPSI:

Defines 'legitimate purpose' as sharing UPSI in the ordinary course of business with partners, collaborators, lenders, customers, suppliers, legal advisors, auditors, rating agencies, statutory authorities, directors, potential investors, etc., provided it is not to evade regulations.
For transactions requiring specific Board approval, the Board itself will approve the sharing of UPSI if it is in the company's best interest and for a legitimate purpose.
For sharing in the ordinary course of business, the COO (in consultation with the concerned President of the strategy) is authorized to evaluate instances based on guiding principles, including need-to-know basis, best interests of the company, and existence of confidentiality agreements.
A process is outlined where Presidents submit proposals to the COO, who may also consult the Managing Director & CEO. The Secretarial Department must maintain central, time-stamped digital records of all such sharing.

5. Procedures for Sharing UPSI:

UPSI can only be shared on a need-to-know basis and for a legitimate purpose until it becomes generally available.
The recipient of UPSI becomes an "Insider" and must be made aware of their obligations.
The President sharing the information must ensure compliance with the legitimate purpose policy, obtain signed confidentiality agreements, provide a copy of the Company's Trading Code of Conduct, obtain an undertaking of compliance from the recipient, and maintain digital records of the recipient's details (PAN or other identifier).
Presentations and records from meetings with analysts must be made available on the company website.

6. Amendment:

The Board reserves the right to amend or alter this Code at its discretion, subject to applicable law.