Zuari Industries Revises UPSI Fair Disclosure Code

Date: 13 August 2026

The Board of Directors has approved a revised Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI).
This revised code supersedes the earlier code adopted by the Company on the subject.
The approval is pursuant to Regulation 8 of the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended.

Background and Objective:

The code was formulated to comply with Regulation 8 of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
Its objective is to ensure timely, adequate, fair, uniform, and universal disclosure and dissemination of UPSI to prevent selective disclosure.

Applicability:

The code applies to the Company and its directors, officers, employees, and other persons who may come into possession of UPSI in the course of their association with the Company.

Chief Investor Relations Officer (CIRO):

The Chief Financial Officer and Company Secretary of the Company are designated as the Chief Investor Relations Officers.
CIROs are responsible for ensuring timely, adequate, uniform, and universal dissemination and disclosure of UPSI.
They are to act in consultation with other Key Managerial Personnel where necessary.

Principles and Procedures for Fair Disclosure:

Prompt Public Disclosure: The Company shall make prompt public disclosure of UPSI that would impact price discovery in an accurate, fair, and timely manner.
Uniform Dissemination: UPSI shall be disseminated by promptly intimating it to the Stock Exchanges and disclosing it on the Company's website.
Handling Inadvertent Disclosure: If UPSI is disclosed selectively or inadvertently, the responsible person must promptly inform the CIROs, who will then disseminate it to make it generally available.
Response to Rumors: The Company generally will not comment on market rumors but will provide appropriate responses to queries from Stock Exchanges, SEBI, or other regulatory authorities.
Analyst Interactions: Only generally available information shall be shared with analysts and research personnel. Transcripts of meetings shall be made available on the company website.
Need-to-Know Basis: UPSI is to be handled on a "need to know" basis, and recipients must be notified to maintain confidentiality and not trade in securities.

Legitimate Purpose:

UPSI may be shared in the ordinary course of business with collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, credit rating agencies, insolvency professionals, or other advisors.
Sharing must not be carried out to evade the prohibitions of the Regulations.
Recipients of UPSI for a legitimate purpose are considered Insiders and must maintain confidentiality.

Amendment and Review:

The code shall be reviewed by the Board as and when considered necessary and amended to reflect changes in SEBI PIT Regulations or other applicable laws.