Date: October 19, 2026

Board Meeting Outcomes

The Board of Directors of Orient Technologies Limited, via circular resolution, considered and approved the "Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information" on October 19, 2026. The code was formulated in terms of SEBI (Prohibition of Insider Trading) Regulations, 2015.

The code was originally formulated effective from October 16, 2023, and the board approved amendments to the code on October 19, 2026, with the amended code coming into effect from October 19, 2026.

Code of Fair Disclosure Provisions

Objective

The code intends to formulate a defined framework and policy for fair disclosure of events and occurrences that could impact price discovery in the market for the Company's securities. It aims to maintain uniformity, transparency and fairness in dealings with all stakeholders and ensure adherence to applicable laws and regulations.

Definitions

The code defines key terms including:

  • Unpublished Price Sensitive Information (UPSI): Information relating to the Company or its securities that is not generally available and would likely materially affect the price of securities upon becoming generally available
  • Generally Available Information: Information accessible to the public on a non-discriminatory basis
  • Mainstream Media: Includes newspapers registered with RNI, news channels permitted by Ministry of Information and Broadcasting, and content publishers under IT Rules 2021

Principles of Fair Disclosure

The Company shall adhere to principles including:

  • Prompt public disclosure of UPSI
  • Uniform and universal dissemination of UPSI to avoid selective disclosure
  • Designation of a Company Secretary or senior officer as Chief Investor Relations Officer
  • Appropriate response to queries on news reports and market rumors
  • Handling UPSI on a need-to-know basis

Chief Investor Relations Officer

The Board has designated the Company Secretary as the Chief Investor Relations Officer (CIRO) to deal with dissemination of information and disclosure of UPSI. The CIRO is responsible for ensuring compliance under this code, overseeing disclosure of UPSI to stock exchanges, shareholders, analysts and media.

Disclosure Procedures

The Company will ensure any event bearing on share price is disseminated promptly to all stock exchanges where securities are listed, simultaneously, and published on the Company's website at https://www.orientindia.in/

Market Rumors Response

The Company shall generally not respond to market rumors unless required by law or necessary to prevent false markets. The CIRO shall decide whether public announcement is necessary for verifying or denying rumors. The Company will respond to stock exchange queries regarding market rumors promptly.

Sharing UPSI for Legitimate Purpose

UPSI may be shared for legitimate purposes including with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, and other advisors. Recipients must maintain confidentiality and use information only for legitimate purposes.

Digital Database Maintenance

The Company shall maintain a structured digital database of persons with whom UPSI is shared, containing names and PAN or other identifiers. The database shall be preserved for at least eight years after completion of relevant transactions.

Amendment Procedure

The Board may amend the code as per applicable laws, rules and regulations. Amendments will be intimated to Stock Exchanges and hosted on the Company's website.

Compliance Status

The code has been submitted to Bombay Stock Exchange and National Stock Exchange of India and is available on the Company's website in the Policies, Codes & Other Documents section.