Date: September 30, 2026

Compliance Disclosure

GSPL Transmission Limited has adopted a new 'Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information' (the Code) effective from May 1, 2026. The Code is consistent with SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended.

Key Principles of the Fair Disclosure Code

  • Prompt disclosure of Unpublished Price Sensitive Information (UPSI) that would impact price discovery, made no sooner than credible and concrete information comes into being
  • Uniform and universal disclosure of UPSI through widely circulated media and/or stock exchanges where equity shares are listed to avoid selective disclosure
  • Designated Person(s) of the Company must promptly disclose any UPSI to the Chief Investor Relations Officer
  • Chief Financial Officer serves as the Chief Investor Relations Officer (CIRO) responsible for dissemination of information and disclosure of UPSI
  • Prompt dissemination of UPSI that gets disclosed selectively, inadvertently or otherwise to make such information generally available
  • Appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities
  • Ensuring information shared with analysts and research personnel is not UPSI
  • Publishing proceedings of meetings with analysts and investor relations conferences on official website (www.gspltrans.com)
  • Handling all UPSI on a Need-to-Know basis only

Legitimate Purpose Information Sharing

  • Sharing of information with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals, other advisors or consultants is considered "Legitimate Purposes" for sharing UPSI in ordinary course of business
  • Such sharing must not be carried out to evade or circumvent the prohibitions of SEBI (Prohibition of Insider Trading) Regulations, 2015

Structured Digital Database Requirements

  • Maintenance of Structured Digital Database containing names of persons/entities with whom information is shared for Legitimate Purposes
  • Database to include Permanent Account Number or any other identifier authorized by law where PAN is not available
  • Adequate internal controls and checks including time stamping and audit trails to ensure non-tampering of the database

Insider Status for Recipients

  • Any person receiving UPSI pursuant to a "Legitimate Purpose" shall be considered an "Insider" under SEBI (Prohibition of Insider Trading) Regulations, 2015
  • Such persons are required to ensure confidentiality of UPSI shared with them in compliance with SEBI regulations

Board Authority

The Board of Directors may stipulate further guidelines, procedures and rules from time to time to ensure Fair Disclosure of Unpublished Price Sensitive Information.

Availability

The Code is available on the company website at www.gspltrans.com.