This document is an intimation to the stock exchanges (BSE Limited and National Stock Exchange of India Limited) under Regulation 8(2) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (PIT Regulations).

The Board of Directors of Route Mobile Limited approved an amended Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (Fair Disclosure Code) by way of circular resolution. The majority approval for this amendment was received on June 29, 2026, at 8:02 P.M. IST. This is the third version of the policy, with Version 1 becoming effective on September 4, 2020, and Version 2 amended on January 28, 2021.

The amended Fair Disclosure Code has been uploaded to the company's website at www.routemobile.com.

Key Provisions of the Amended Fair Disclosure Code:

Purpose and Objective: The code is formulated in compliance with SEBI PIT Regulations to preserve the confidentiality of Unpublished Price Sensitive Information (UPSI), prevent its misuse, and ensure timely and adequate disclosure.

Key Personnel:

  • The Investor Relations Officer (IRO) is designated to oversee corporate disclosures and dissemination of UPSI.
  • The Compliance Officer is defined as the Company Secretary.
  • Authorized persons for communicating with investors/media are: Chairman, Managing Director, Chief Executive Officer (CEO), Executive Director(s), and Chief Financial Officer (CFO).

The IRO is responsible for responding to market rumor verification requests from regulators and deciding on the necessity of public announcements regarding rumors.

Dissemination of Information: UPSI must be disclosed promptly to stock exchanges and on the company's website to make it generally available. Disclosure should be continuous, immediate, uniform, and universal.

Analyst Interactions:

  • Only public information may be provided to analysts/research personnel.
  • Meetings should ideally have at least two company representatives present.
  • A transcript, recording, or detailed summary of analyst meets, earnings calls, or investor conferences must be uploaded to the company website and submitted to the stock exchanges within 24 hours of conclusion.
  • Unanticipated questions containing UPSI should be answered only after a public disclosure is made.

Quiet Period: A "Quiet Period" is to be observed from the end of each quarter until the financial results are announced. During this period, management shall not initiate or participate in meetings with analysts or investors, and the IRO will only direct queries to publicly available information. This period coincides with the Trading Window closure for designated persons.

Handling of UPSI: UPSI is to be shared strictly on a "need to know" basis for legitimate purposes, which includes sharing in the ordinary course of business with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, etc. Recipients of UPSI must be notified to maintain its confidentiality.

Structured Digital Database: The company is required to maintain a non-outsourceable Structured Digital Database with details of all persons with whom UPSI is shared. The database must include:

  • For individuals: Nature of UPSI, recipient's name, affiliated organization, postal address, email address, and PAN/UID.
  • For entities: Nature of UPSI, entity name, registered office address, and PAN.

The database must be maintained internally with adequate controls (time-stamping, audit trails), preserved for at least eight years post-transaction, and access is restricted to persons authorized by the Compliance Officer.

Amendments and Disclosure: The Board of Directors may amend this code. The code and any amendments are published on the company's website and intimated to the stock exchanges.