CLOSURE OF TRADING WINDOW CHECKLIST FOR DECEMBER 2025 QUARTER 

(Pursuant to SEBI (Prohibition of Insider Trading) Regulations, 2015)

1. Overview

In accordance with the SEBI (Prohibition of Insider Trading) Regulations, 2015 (“SEBI PIT Regulations”) and the Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons adopted by the Company, the Trading Window for dealing in the securities of the Company is required to be closed during the period when unpublished price sensitive information (“UPSI”) is available, including the period prior to declaration of financial results.

The following checklist captures the key compliances required to be undertaken by the Company for the closure of the trading window for the quarter ended 31 December 2025.

2. Trading Window Closure – Compliance Checklist

3. Frequently Asked Questions (FAQs) – Trading Window Closure & PAN Freezing

3.1 Whether the end date entered in the depositories system is modifiable?

Yes. The end date in the depositories system is modifiable. The issuer may initially enter a notional end date at the time of trading window closure. Once the Board Meeting date for approval of financial results is finalized, the end date may be modified based on the requirement of T-2 trading days prior to the Board Meeting.

3.2 Whether pledge invocation is permitted during the PAN freezing period?

No. Pledge invocation is not permitted during the tenure of PAN freezing. However, pledge invocation may be allowed only if the pledge was created prior to the commencement of the trading window closure period.

3.3 In case a person holds multiple demat accounts across both depositories, whether PAN freezing applies to both?

PAN freezing is carried out on a PAN–ISIN level basis. Where a client PAN is linked to multiple demat accounts across both depositories, freezing shall apply across all such accounts, provided the PAN has been uploaded in the Structured Digital Database with the Designated Depository.
It is clarified that the issuer is required to update the details only with the Designated Depository, and not separately with both depositories.

3.4 Whether depositories send intimation regarding PAN freezing to Designated Persons?

Yes. The respective depository sends an SMS and/or email intimation to the demat account holder regarding PAN freezing.
However, this does not absolve the issuer of its obligation. The issuer must independently send communication to all Designated Persons and their Immediate Relatives informing them of the trading window closure and PAN freezing.

3.5 Whether PAN freezing applies only to Designated Persons or also to their Immediate Relatives?

PAN freezing applies to both Designated Persons and their Immediate Relatives. Freezing is carried out on the PANs submitted by the issuer on the depository portal, irrespective of whether the PAN belongs to a Designated Person or an Immediate Relative.

4. Format of Intimation to Stock Exchanges

(Closure of Trading Window)

To
BSE LIMITED
The General Manager
Corporate Relationship Department
Phiroze Jeejeebhoy Towers,
25th Floor, Dalal Street,
Mumbai – 400 001

Scrip Code: __________

AND

NATIONAL STOCK EXCHANGE OF INDIA LIMITED
Listing Department
Exchange Plaza,
Bandra Kurla Complex,
Bandra (East),
Mumbai – 400 051

NSE Symbol: __________

Subject: Intimation of Closure of Trading Window

Dear Sir / Madam,

Pursuant to the Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons adopted by the Company in accordance with the provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (as amended), we hereby inform you that the Trading Window for dealing in the Equity Shares of the Company shall remain closedfor all Designated Persons and their Immediate Relatives.

The Trading Window shall be closed with effect from 1 January 2026 and shall remain closed till the expiry of 48 hours after the declaration of the Audited Financial Results of the Company for the quarter and year ended 31 December 2025.

During the aforesaid period of Trading Window closure, the Designated Persons, as defined under the Company’s Code of Conduct, shall not trade in the securities of the Company.

The date of the Board Meeting for consideration and approval of the Audited Financial Results for the quarter and year ended 31 December 2025 shall be intimated to the Stock Exchanges in due course, in compliance with applicable SEBI Listing Regulations.

We request you to kindly take the above information on record.

Thanking you,

Yours faithfully,

For [Company Name]

[Name of Director / Company Secretary]
[Designation]
DIN / Membership No.: _________

5. Disclaimer

The contents of this document have been prepared on the basis of applicable provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015, circulars issued thereunder, and information available as on date. While due care has been taken to ensure accuracy and completeness, no responsibility is assumed for any errors or omissions. This document is intended solely for informational and compliance reference purposes and shall not be construed as legal advice. Users are advised to independently refer to the applicable laws, rules, regulations, and professional guidance before acting upon the contents herein.