Date: October 27, 2026

Board Meeting Outcomes

  • Board of Directors approved Version 3.0 of the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information in their meeting held on October 26, 2026
  • The updated code became effective immediately upon board approval on October 26, 2026

Policy Framework

Version History:

  • Version 1.0: Approved July 10, 2021, Effective July 10, 2021
  • Version 2.0: Approved July 22, 2025, Effective July 22, 2025
  • Version 3.0: Approved October 26, 2026, Effective October 26, 2026

Key Principles of Fair Disclosure:

  • Prompt public disclosure of UPSI that would impact price discovery
  • Uniform and universal dissemination of UPSI to avoid selective disclosure
  • Prompt dissemination of selectively disclosed UPSI
  • Appropriate response to queries on news reports and market rumors
  • Ensuring information shared with analysts is not UPSI
  • Maintaining transcripts of meetings with analysts on official website
  • Handling UPSI on need-to-know basis

Designated Roles:

  • Chief Financial Officer designated as Chief Investor Relations Officer (CIRO)
  • CIRO responsible for overseeing dissemination of information and disclosure of UPSI
  • CIRO may consult relevant officials to verify correctness and credibility of UPSI

Legitimate Purpose Policy:

  • UPSI may be shared for legitimate purposes in ordinary course of business
  • Permitted recipients include: auditors, accountancy firms, legal advisors, merchant bankers, consultants; contractual counterparties and business/commercial partners; lenders; customers and suppliers; other advisors/consultants/partners
  • Recipients must be notified of confidentiality obligations and considered Insiders under PIT Regulations
  • For transactions under Regulation 3(3), confidentiality agreements must be executed

Database Requirements:

  • Company maintains structured digital database as per Regulations 3(5) and 3(6) of PIT Regulations
  • Database not outsourced
  • Information relating to UPSI not originating internally entered within 2 calendar days of receipt

Compliance Procedures:

  • Code hosted on company website: https://ir.paytm.com/
  • Company follows inquiry policy for leaks or suspected leaks of UPSI under Regulation 9A(5)
  • Every amendment to Code promptly intimated to stock exchanges