Date: September 30, 2026

KMP / Board / Auditor Changes

Not Specified

Dividend Declaration or Non-Declaration

Not Specified

Board Meeting Outcomes

Not Specified

Financial Results (Standalone & Consolidated)

Not Specified

Auditor’s Report

Not Specified

Disinvestment / Strategic Actions

Not Specified

Other Operational / Legal / Strategic Disclosures

Policy Adoption and Framework:

  • Elevate Campuses Limited has intimated the adoption of its "Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information and determination of Legitimate Purposes" to BSE Limited and the National Stock Exchange of India Limited.
  • The Code was originally approved by the Board at its meeting held on September 25, 2025.
  • The Code was revised and approved by the Board at its meeting held on September 17, 2026.
  • The Code has been uploaded on the company's website at www.elevatecampuses.com.

Chief Investor Relations Officer (CIRO):

  • The Chief Financial Officer of the Company is designated as the CIRO.
  • The CIRO is responsible for the dissemination of information and disclosure of Unpublished Price Sensitive Information (UPSI).
  • The CIRO is responsible for responding to queries on news reports and requests for verification of market rumours by regulatory authorities.
  • In the temporary absence of the CIRO, the executive director/whole-time director/managing director/chief executive officer shall nominate another official to perform these duties.

Policy for Determination of Legitimate Purposes (Annexure A):

  • The Policy identifies 'Legitimate Purposes' for sharing UPSI as an exception for performance of duties or discharge of legal obligations.
  • Factors for determining legitimate purpose include whether sharing is in the ordinary course of business, not to evade regulations, in the best interests of the company, for discharging legal/contractual obligations, and commensurate with the purpose.
  • An indicative list of legitimate purposes includes sharing with: Company's partners; Auditors, accountancy firms, legal advisors, and merchant bankers; Collaborators; Lenders; Customers; Suppliers; Insolvency professionals; Credit Rating Agencies; Bankers; Any other advisors/consultants/partners; and Promoters (Genius Bidco Holdings Pte. Ltd. and Genius Rajkot Investment Holdings Pte. Ltd.).
  • Specific legitimate purposes include sharing for business/commercial/operational/management/strategic advisory purposes, consolidation requirements, customary disclosure obligations, requirements under applicable law, contractual obligations, and audit purposes.

Structured Digital Database Requirements:

  • A structured digital database must be maintained containing the nature of UPSI and the names of persons/entities with whom information is shared.
  • The database must include Permanent Account Numbers or other authorized identifiers.
  • The database must be maintained with internal controls and checks such as time stamping and audit trails to ensure non-tampering.
  • Information not emanating from within the Company must be entered not later than two calendar days from receipt.
  • The database must be preserved for a period of not less than eight years after completion of relevant transactions.
  • If SEBI investigation proceedings are initiated, relevant information must be preserved until completion.

Recipient Obligations:

  • Persons with whom UPSI is shared pursuant to a legitimate purpose are considered "insiders".
  • The Company must inform recipients that the information is UPSI and that the Company is its exclusive owner.
  • Recipients must maintain confidentiality and may use UPSI only for the approved purposes.
  • Recipients should provide a written undertaking not to trade in the company's securities while in possession of UPSI.