Glass Wall Systems (India) Limited has submitted a formal intimation to BSE Limited and National Stock Exchange of India Limited regarding compliance with Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (PIT Regulations).

The disclosure includes the company's complete "Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information and Determination of Legitimate Purposes" which was approved by the Board of Directors on August 05, 2025, with version number GWS/UPSIPOLICY/V01.

Key Policy Provisions:

Unpublished Price Sensitive Information (UPSI) Handling:

  • The company shall promptly disclose UPSI that would impact price discovery once credible and concrete information comes into being
  • UPSI shall be uniformly and universally disseminated to avoid selective disclosure
  • If UPSI gets disclosed selectively, prompt steps shall be taken to make such information generally available

Chief Investor Relations Officer (CIRO):

  • The CFO or Company Secretary shall serve as CIRO, responsible for dissemination of information and disclosure of UPSI
  • The CIRO is also responsible for responding to queries on news reports and verification of market rumors by regulatory authorities
  • In the CIRO's temporary absence, the managing director/whole time director/chief executive officer shall nominate another official

General Obligations:

  • All UPSI shall be handled on a need-to-know basis according to PIT Regulations and company policies
  • Information must be specific and intended for general availability to avoid creating false markets
  • CIRO may consult officials within the company to ensure correctness and credibility of UPSI
  • All communications of UPSI with stock exchanges must be approved by CIRO
  • Information disclosure should normally be approved in advance by CIRO

Analyst and Research Interactions:

  • The company shall ensure information shared with analysts is not UPSI or is simultaneously made public
  • CIRO shall develop best practices for transcripts of meetings with analysts and upload them on the official website

Market Rumors:

  • CIRO shall ensure appropriate and fair responses to queries on news reports and verification requests from regulatory authorities
  • Copies of replies to any stock exchange shall be sent to other stock exchanges where company securities are listed

Policy Review and Amendments:

  • The Board reserves the power to review and amend this Code from time to time
  • All provisions subject to revision/amendment in accordance with applicable laws
  • Notice of amendments will be given to stock exchanges

Legitimate Purposes Policy (Annexure A):

  • Defines legitimate purposes as sharing UPSI in ordinary course of business with specified entities
  • Permitted recipients include: company's partners, auditors, accountancy firms, legal advisors, merchant bankers, collaborators, lenders, customers, suppliers, insolvency professionals, and other advisors/consultants/partners
  • Assessment factors include whether sharing is in ordinary course of business, not to evade regulations, in company's best interests, for legal/contractual obligations, and commensurate with purpose
  • Maintains structured digital database containing nature of UPSI and names of persons/entities with whom information is shared, along with PAN or other identifiers
  • Database maintained with internal controls including time stamping and audit trails to ensure non-tampering
  • Digital database preserved for not less than eight years after completion of relevant transactions

Restrictions on Communication:

  • Recipients of UPSI shall be considered "insiders" and must maintain confidentiality
  • Company must inform recipients via written intimation/contractual agreement that information is UPSI, they become insiders, must maintain confidentiality, use only for approved purposes, provide written undertaking not to trade while possessing UPSI, and extend cooperation

The intimation was digitally signed by Sagar Lambole, Company Secretary and Compliance Officer (Membership No. A45005) on September 17, 2026, at 16:24:59 +05'30'.