EverestIMS Technologies Limited has amended its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) in compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015 and SEBI Master Circular No. HO/43/15/12(3)2025 -ISD - POD2/I/11734/2026 dated May 15, 2026.

The amendments were approved by the Board of Directors on November 13, 2026, and became effective immediately on the same date. The document represents Version 2.0 of the code, superseding Version 1.0 which was approved on October 21, 2024.

Key Amendments:

  • The applicability of the code has been expanded to include "any person with Unpublished Price Sensitive Information" in addition to employees, officers, directors, and authorized spokespersons.
  • A new section 5 has been inserted outlining basic principles of disclosures as per Schedule A of the PIT Regulations, including requirements for prompt public disclosure, uniform dissemination, and handling of UPSI on a need-to-know basis.
  • The role of Compliance Officer/MD/CFO in various procedures has been replaced with a newly designated "Chief Investor Relations Officer (CIRO)" who reports to the Managing Director. The CIRO can be contacted at cs@everestims.com.
  • A new Annexure I has been added detailing the policy for determination of 'legitimate purposes' for sharing UPSI, which forms an integral part of the code.
  • A Document Control section (Section 19) has been inserted detailing version history and storage location.
  • Certain original content has been omitted, including specific procedures governing disclosure of material information and standard response language for market rumors.

Disclosure Requirements:

The code mandates prompt public disclosure of UPSI that would impact price discovery once information becomes credible and concrete. All Material Information (including UPSI and events specified in Annexure II-A, II-B, and III of the company's Material Events Policy) must be disclosed immediately through stock exchanges, except when confidentiality is required for legitimate business purposes.

Procedures:

Functional heads must contact the CIRO upon becoming aware of Material Information. The CIRO determines whether disclosure to stock exchanges is required in accordance with listing agreements. The company will not comment on market rumors unless required by regulatory authorities.

Legitimate Purpose Policy (Annexure I):

UPSI can be shared on a need-to-know basis for legitimate purposes including: compliance with laws/regulations; sharing with partners, collaborators, lenders, customers, suppliers, advisors; business requirements with promoters; and arising from contractual obligations. Any person receiving UPSI pursuant to a legitimate purpose is considered an "insider" under the regulations.