Date: August 5, 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 Submission

  • Manipal Health Enterprises Limited has framed a Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI) pursuant to Regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
  • The code was submitted to BSE Limited and the National Stock Exchange of India Limited on August 5, 2026, under Regulation 8(2) of the PIT Regulations.
  • A copy of the code has been uploaded on the company's website.

Code Objectives and Structure

  • The code's objective is to formulate a framework for fair disclosure of events that could impact price discovery, including UPSI, to maintain uniformity, transparency, and fairness in dealings with stakeholders.
  • It defines key terms including Board, Code, Company, Compliance Officer, Connected Person, Designated Person, Insider, Stock Exchange, and Unpublished Price Sensitive Information (UPSI).

Chief Investor Relations Officer (CIRO) Role

  • A Chief Investor Relations Officer (CIRO) shall be appointed by the Managing Director/Chief Executive Officer/Chief Finance Officer.
  • The CIRO is responsible for ensuring uniform dissemination of information and disclosure of UPSI to avoid selective disclosure.
  • Responsibilities include ensuring code compliance, overseeing information sharing by employees, reviewing disclosure processes, and assessing materiality of information with the Board/senior management.
  • The CIRO must observe SEBI regulatory timelines for disclosures.

Disclosure Procedures

  • UPSI shall be disclosed to stock exchanges by the CIRO or Compliance Officer and disseminated promptly on a continuous basis.
  • The company shall follow timelines stipulated in SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
  • UPSI shall be disseminated uniformly to all stakeholders through stock exchanges and the company website.
  • Procedures are established for responding to queries on news reports and verification of market rumors by regulatory authorities.
  • The Compliance Officer is responsible for timely reporting of shareholdings/ownership and changes in ownership.

Information Sharing with Analysts and Investors

  • The company will ensure information shared with analysts and institutional investors does not contain UPSI; if shared, it must be simultaneously made public.
  • Systems will be in place to record transcripts of conference calls and meetings with analysts, with disclosure to stock exchanges and website hosting.
  • Extra caution will be taken with unanticipated questions that may require consultation with the CIRO.

Handling of UPSI

  • UPSI shall be made available strictly on a need-to-know basis.
  • Appropriate wall-crossing procedures shall be followed for sharing UPSI within the company or with external parties for genuine business purposes.

Policy for Determination of 'Legitimate Purpose'

  • The policy recognizes that UPSI may be shared for legitimate purposes, performance of duties, or discharge of legal obligations.
  • Legitimate purpose includes sharing in the ordinary course of business with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, etc., provided it's not to evade PIT Regulations.
  • Guiding principles include assessment of purpose, analyzing the nature of UPSI, identifying recipients, and issuing notices to recipients.
  • Prior to sharing UPSI, recipients must be apprised that the information is UPSI, they become Insiders subject to PIT Regulations, must maintain confidentiality, provide written undertaking not to trade, and extend cooperation for database maintenance.
  • The company will maintain a structured digital database with time stamping and audit trails, preserved for at least eight years.
  • Illustrative legitimate purposes include: investigations by statutory authorities, court proceedings, compliance with laws, sharing with intermediaries for bona fide purposes, strategic alliances, and bona fide business/commercial purposes.

Policy Review and Amendments

  • The Board reserves the power to review and amend the code from time to time.
  • Provisions are subject to revision per applicable laws from statutory, governmental, and regulatory authorities.
  • The code and amendments shall be published on the company website and promptly intimated to stock exchanges.

Effective Date

  • The policy will be effective from the date of approval of the Draft Red Herring Prospectus by the Board.