Fair Disclosure Code for Unpublished Price Sensitive Information

Elevate Campuses has adopted a code of practices and procedures for fair disclosure of unpublished price sensitive information, as required by SEBI insider trading regulations.

Wed 30 Sep 2026

Board Approval Date

September 17, 2026

Policy Focus

Fair disclosure of unpublished price sensitive information (UPSI)

Regulatory Authority

SEBI insider trading regulations

Chief Officer Responsibility

Chief Financial Officer as Chief Investor Relations Officer

What the Code Requires

Elevate Campuses has established formal procedures to ensure fair and prompt disclosure of unpublished price sensitive information—facts that could influence the stock price and are not yet public. The code applies to the company, its subsidiaries and associates.

Key Principles

• UPSI must be disclosed promptly once it becomes credible and concrete, to avoid creating false markets
• Disclosure must be uniform and universal — the same information to all investors at the same time, with no selective sharing
• Material events are disseminated as required by stock exchange regulations
• If UPSI is inadvertently disclosed to some people first, the company must immediately make it generally available

Who Handles Disclosures

The Chief Financial Officer acts as Chief Investor Relations Officer and is responsible for deciding what counts as UPSI, authorizing its release, and handling questions from regulators about market rumours. If the CFO is temporarily absent, the executive director or managing director nominates a replacement. All communications with stock exchanges must be approved by this officer.

Sharing with Analysts

When the company speaks to analysts and research teams, it can only share information that is already public, or must make that information public at the same time. Transcripts of analyst meetings are posted on the company website and stock exchange websites for transparency.

Accidental Disclosure

If information is accidentally released without approval, the responsible person must inform the Chief Investor Relations Officer immediately, even if they think it is not price-sensitive. The officer will then take steps to rectify the situation.

Amendments

The board reserves the right to revise this code. Any changes in SEBI's insider trading regulations automatically apply to this policy, and amendments are promptly communicated to the stock exchanges.

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