HEG Ltd. — Regulatory Filings 2026

Feb 21, 2026

HEG/SECTT/2026

February 21, 2026

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BSE Limited National Stock Exchange of India Limited P J Towers Exchange Plaza, 5[th] Floor Dalal Street Plot No.C/1, G Block, Bandra - Kurla Complex MUMBAI - 400 001. Bandra (E), MUMBAI - 400 051. Scrip Code : 509631 Scrip Code : HEG

Sub: Intimation of violation under the Company’s Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons and Immediate Relatives and SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended (“SEBI PIT Regulations”)

Dear Sir/Madam,

This is to report violations in terms of the SEBI (Prohibition of Insider Trading) Regulations, 2015, and Code of Conduct for Regulating, Monitoring & Reporting Trading by Insiders to Regulate, Monitor and Report Trading by Insiders for Trading in Equity Shares of HEG Limited by Designated Persons, in accordance with SEBI Circular No. SEBI/HO/ISD/ISD/CIR/P/2020/135 dated July 23, 2020.

The details of violation by the Designated Persons along with the action taken by the Company thereon is enclosed as “Annexure A” to this letter.

The aforesaid information is also available on the website of the Company i.e. www.hegltd.com.

Thanking You,

Yours faithfully,

For HEG Limited

VIVEK Digitally signed by VIVEK CHAUD CHAUDHARY Date: 2026.02.21 HARY 20:49:46 +05'30' (Vivek Chaudhary) Company Secretary M.No. A-13263 heg.investor@lnjbhilwara.com

Encl: as above

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Annexure-A

Report by HEG Ltd for violations related to Code of Conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015

[Schedule B read with Regulation 9(1) of SEBI (Prohibition of Insider Trading) Regulation, 2015]

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Sr. No. Particulars Details
1. Name of the listed company/ HEG Limited
Intermediary/Fiduciary
2. Please tick appropriate checkbox Listed Company
Reporting in capacity of :
√ Listed Company
☐ Intermediary
☐ Fiduciary
3. A. Details of Designated Person ( DP )
i. Name of the DP Mr. Nivedan Churiwal
ii. PAN of the DP Mr. Nivedan Churiwal- ACKPC3738M
iii. Designation of DP Members of the Promoter Group
iv. Functional Role of DP Members of the Promoter Group
v. Whether DP is Promoter or belongs to Yes
Promoter Group
B. If Reporting is for immediate relative of DP
i. Name of the immediate relative of DP Not Applicable
ii. PAN of the immediate relative of DP Not Applicable
C. Details of transaction(s)
i. Name of the scrip HEG Limited
NSE Symbol: HEG
BSE Scrip Code: 509631
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ii. No of shares traded and Name Date Transa No of Value (Rs)
value (Rs.) (Date- wise) ction Share
Nivedan 30.12.2025 Buy 3935 23,64,852.74
Churiwal
Nivedan 30.12.2025 Sale 35 21,079.78
Churiwal
D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter
Sr.
Particulars Details
No.
i. Date of intimation of trade(s) by On 17 [th] January, 2026, the above members of
concerned DP/director/promoter Promoters Group, pursuant to Show Cause Notice
dated 16.01.2026 has submitted their disclosure of
/promoter group to Company under
trading in Form B to the Company and thereafter
Regulation 7 of SEBI (PIT) Regulations,
the Company has submitted the same to Stock
2015.
Exchanges in terms of SEBI Regulations.
ii. Date of intimation of trade(s) by 17 [[th]] January 2026
Company to stock exchanges under
regulation 7 of SEBI (PIT) Regulations,
2015
4. Details of violations observed under Code of Sr. Name Details of Non-Compliance
Conduct No.
1 Mr. Nivedan Trading without pre-clearance,
Churiwal Contra trade and
non-disclosure of transaction to
the Company.
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ii. Date of intimation of trade(s) by 17[[th]] January 2026 Company to stock exchanges under regulation 7 of SEBI (PIT) Regulations, 2015 4. Details of violations observed under Code of Sr. Name Details of Non-Compliance Conduct No. 1 Mr. Nivedan Trading without pre-clearance, Churiwal Contra trade and non-disclosure of transaction to the Company. 5. Action taken by Listed company/ The Company after considering the facts and ~~Intermediary/ Fiduciary~~ circumstances of the case, including the review of trading data, the role of the individual concerned, the number of securities transacted, the explanation and submissions made by the concerned persons and the aforesaid Framework to Penalize, and in order to ensure regulatory compliance, uphold the standards of corporate governance and maintain market integrity, the Company considered it appropriate to take following action in accordance with the Code of Conduct and the applicable provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015 issued by SEBI:

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• a. Keeping in view of the aforesaid violation of the SEBI (Prohibition of Insider Trading) Regulations, 2015, the concerned persons are advised to immediately sell the entire equity shares of HEG Limited acquired on 30 December 2025 and to intimate the Company of the same in Form B within one (1) working day from the date of execution of the sale.

• b. The entire sale proceeds arising from the aforesaid transaction shall be deposited / disgorged by the concerned persons into the designated account of the SEBI.

• c. The concerned persons shall submit to the Company documentary evidence of the sale of shares, along with proof of deposit of the entire sale proceeds with SEBI, immediately upon completion of the above actions, for placing the same before the Audit Committee for its record.

• d. The concerned persons shall, on an immediate basis, inform their Portfolio Management Services (PMS) provider / broker to place the scrip of HEG Limited on the restricted / negative list, so as to ensure that no further trading is undertaken in the securities of the Company without strict adherence to the provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015 and the Company’s Code of Conduct.

• e. The above directions are issued as corrective and preventive measures consequent to the violation observed and are without prejudice to any action that may be initiated or taken by SEBI or any other statutory or regulatory authority under applicable law.

• f. The concerned persons are further advised to ensure strict and continuous compliance with all applicable laws and internal codes at all times going forward.

• Reasons recorded in writing for taking action stated above

The Company took note of the these violations and, after considering the facts and circumstances of the case, including the review of trading data, the role of the individual concerned, the number of securities transacted, the explanation and submissions made by the concerned persons and in order to ensure regulatory compliance, uphold the standards of

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corporate governance and maintain market
integrity, the Company considered it appropriate to
take action in accordance with the Code of Conduct
and the applicable provisions of the SEBI
(Prohibition of Insider Trading) Regulations, 2015
issued by SEBI.
7. Details of the previous instances of None
violations, if any, since last financial year
8. If any amount collected for Code of Conduct violation(s)
i. Mode of transfer to SEBI - IPEF Online
(Online/Demand Draft)
iii. Details of transfer/payment
In case of Online:
Particulars Details
Name of the transferor Nivedan Churiwal
Bank Name, branch Bank of Baroda, Rash Behari Branch, Kolkata
Bank Account number 77810100002209
UTR/Transaction reference Number BARBR52026022100801249
Transaction date 21-02-2026
Transaction Amount (in Rs.) 20,97,450
In case of Demand Draft (DD): Not Applicable
Particulars Details
Bank Name and branch
DD Number
DD date Not Applicable
DD amount (in Rs.)
9. Any other relevant information Nil
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Report by HEG Ltd for violations related to Code of Conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015

[Schedule B read with Regulation 9(1) of SEBI (Prohibition of Insider Trading) Regulation, 2015]

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Sr. No. Particulars Details
1. Name of the listed company/ HEG Limited
Intermediary/Fiduciary
2. Please tick appropriate checkbox Listed Company
Reporting in capacity of :
√ Listed Company
☐ Intermediary
☐ Fiduciary
3. A. Details of Designated Person ( DP )
i. Name of the DP Ms. Shubha Churiwal
ii. PAN of the DP Ms. Shubha Churiwal -AEXPC0890B
iii. Designation of DP Members of the Promoter Group
iv. Functional Role of DP Members of the Promoter Group
v. Whether DP is Promoter or belongs to Yes
Promoter Group
B. If Reporting is for immediate relative of DP
i. Name of the immediate relative of DP Not Applicable
ii. PAN of the immediate relative of DP Not Applicable
C. Details of transaction(s)
i. Name of the scrip HEG Limited
NSE Symbol: HEG
BSE Scrip Code: 509631
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ii. No of shares traded and Name Date Transa No of Value (Rs)
value (Rs.) (Date- wise) ction Share
Shubha 30.12.2025 Buy 1500 9,04,765.16
Churiwal
D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter
Sr.
Particulars Details
No.
i. Date of intimation of trade(s) by On 17 [th] January, 2026, the above members of
concerned DP/director/promoter Promoters Group, pursuant to Show Cause Notice
dated 16.01.2026 has submitted their disclosure of
/promoter group to Company under
trading in Form B to the Company and thereafter
Regulation 7 of SEBI (PIT) Regulations,
the Company has submitted the same to Stock
2015.
Exchanges in terms of SEBI Regulations.
ii. Date of intimation of trade(s) by 17 [[th]] January 2026
Company to stock exchanges under
regulation 7 of SEBI (PIT) Regulations,
2015
4. Details of violations observed under Code of Sr. Name Details of Non-Compliance
Conduct No.
1 Ms. Shubha Trading without pre-clearance
Churiwal and non-disclosure of
transaction to the Company.
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ii. Date of intimation of trade(s) by 17[[th]] January 2026 Company to stock exchanges under regulation 7 of SEBI (PIT) Regulations, 2015 4. Details of violations observed under Code of Sr. Name Details of Non-Compliance Conduct No. 1 Ms. Shubha Trading without pre-clearance Churiwal and non-disclosure of transaction to the Company. 5. Action taken by Listed company/ The Company after considering the facts and ~~Intermediary/ Fiduciary~~ circumstances of the case, including the review of trading data, the role of the individual concerned, the number of securities transacted, the explanation and submissions made by the concerned persons and the aforesaid Framework to Penalize, and in order to ensure regulatory compliance, uphold the standards of corporate governance and maintain market integrity, the Company considered it appropriate to take following action in accordance with the Code of Conduct and the applicable provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015 issued by SEBI:

a. Keeping in view of the aforesaid violation of the SEBI (Prohibition of Insider Trading) Regulations, 2015, the concerned persons are advised to immediately sell the entire equity

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shares of HEG Limited acquired on 30 December 2025 and to intimate the Company of the same in Form B within one (1) working day from the date of execution of the sale.

• b. The entire sale proceeds arising from the aforesaid transaction shall be deposited / disgorged by the concerned persons into the designated account of the SEBI.

• c. The concerned persons shall submit to the Company documentary evidence of the sale of shares, along with proof of deposit of the entire sale proceeds with SEBI, immediately upon completion of the above actions, for placing the same before the Audit Committee for its record.

• d. The concerned persons shall, on an immediate basis, inform their Portfolio Management Services (PMS) provider / broker to place the scrip of HEG Limited on the restricted / negative list, so as to ensure that no further trading is undertaken in the securities of the Company without strict adherence to the provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015 and the Company’s Code of Conduct.

• e. The above directions are issued as corrective and preventive measures consequent to the violation observed and are without prejudice to any action that may be initiated or taken by SEBI or any other statutory or regulatory authority under applicable law.

• f. The concerned persons are further advised to ensure strict and continuous compliance with all applicable laws and internal codes at all times going forward.

• Reasons recorded in writing for taking action stated above

• The Company took note of the these violations and, after considering the facts and circumstances of the case, including the review of trading data, the role of the individual concerned, the number of securities transacted, the explanation and submissions made by the concerned persons and in order to ensure regulatory compliance, uphold the standards of corporate governance and maintain market integrity, the Company considered it appropriate to take action in accordance with the Code of Conduct

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and the applicable provisions of the SEBI
(Prohibition of Insider Trading) Regulations, 2015
issued by SEBI.
7. Details of the previous instances of None
violations, if any, since last financial year
8. If any amount collected for Code of Conduct violation(s)
i. Mode of transfer to SEBI - IPEF Online
(Online/Demand Draft)
iii. Details of transfer/payment
In case of Online:
Particulars Details
Name of the transferor Shubha Churiwal
Bank Name, branch Bank of Baroda, Rash Behari Branch, Kolkata
Bank Account number 77810100000083
UTR/Transaction reference Number BARBR52026022100801397
Transaction date 21-02-2026
Transaction Amount (in Rs.) 8,07,923
In case of Demand Draft (DD): Not Applicable
Particulars Details
Bank Name and branch
DD Number
DD date Not Applicable
DD amount (in Rs.)
9. Any other relevant information Nil
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Report by HEG Ltd for violations related to Code of Conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015

[Schedule B read with Regulation 9(1) of SEBI (Prohibition of Insider Trading) Regulation, 2015]

**Sr. No. **	Particulars Details	Particulars Details
1.	Name of the listed company/ Intermediary/Fiduciary HEG Limited
2.	Please tick appropriate checkbox Reporting in capacity of : √Listed Company ☐ Intermediary ☐ Fiduciary Listed Company
3.	A. Details of Designated Person(DP)
	i. Name of the DP Ms. Sudha Churiwal
	ii. PAN of the DP Ms. Sudha Churiwal- ACDPC4077G
	iii. Designation of DP Members of the Promoter Group
	iv. Functional Role of DP Members of the Promoter Group
	v. Whether DP is Promoter or belongs to Promoter Group Yes
	B. If Reporting is for immediate relative of DP
	i. Name of the immediate relative of DP	Not Applicable
	ii. PAN of the immediate relative of DP	Not Applicable
	C. Details of transaction(s)
	i. Name of the scrip	HEG Limited NSE Symbol: HEG BSE Scrip Code: 509631

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ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	ii. No of shares traded and value (Rs.) (Date- wise) Name Date Transact ion No of Share Va Sudha Churiwal 30.12.2025 Buy 895 5,3 D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter	lue (Rs)
			Sudha Churiwal			30.12.2025		Buy	895 5,3	9,805.52
	D. In case value of trade(s) is more than Rs.10 lacs in a calendar Quarter
Sr. No.		Particulars		Details
		i. Date of intimation of trade(s) by concerned DP/director/promoter /promoter group to Company under Regulation 7 of SEBI (PIT) Regulations, 2015.		On 17thJanuary, 2026, the above members of Promoters Group, pursuant to Show Cause Notice dated 16.01.2026 has submitted their disclosure of trading in Form B to the Company and thereafter the Company has submitted the same to Stock Exchanges in terms of SEBI Regulations.
		ii. Date of intimation of trade(s) by Company to stock exchanges under regulation 7 of SEBI (PIT) Regulations, 2015		17thJanuary 2026
4.		Details of violations observed under Code of Conduct		Sr. No.	Name		Details of Non-Compliance
				1	Ms. Sudha Churiwal		Trading without pre- clearance and non-disclosure of transaction to the Company.
5.		Action taken by Listed company/ ~~Intermediary/ Fiduciary~~		The Company after considering the facts and circumstances of the case, including the review of trading data, the role of the individual concerned, the number of securities transacted, the explanation and submissions made by the concerned persons and the aforesaid Framework to Penalize, and in order to ensure regulatory compliance, uphold the standards of corporate governance and maintain market integrity, the Company considered it appropriate to take following action in accordance with the Code of Conduct and the applicable provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015 issued by SEBI: a. Keeping in view of the aforesaid violation of the SEBI (Prohibition of Insider Trading) Regulations,2015,the concernedpersons are

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advised to immediately sell the entire equity shares of HEG Limited acquired on 30 December 2025 and to intimate the Company of the same in Form B within one (1) working day from the date of execution of the sale.

• b. The entire sale proceeds arising from the aforesaid transaction shall be deposited / disgorged by the concerned persons into the designated account of the SEBI.

• c. The concerned persons shall submit to the Company documentary evidence of the sale of shares, along with proof of deposit of the entire sale proceeds with SEBI, immediately upon completion of the above actions, for placing the same before the Audit Committee for its record.

• d. The concerned persons shall, on an immediate basis, inform their Portfolio Management Services (PMS) provider / broker to place the scrip of HEG Limited on the restricted / negative list, so as to ensure that no further trading is undertaken in the securities of the Company without strict adherence to the provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015 and the Company’s Code of Conduct.

• e. The above directions are issued as corrective and preventive measures consequent to the violation observed and are without prejudice to any action that may be initiated or taken by SEBI or any other statutory or regulatory authority under applicable law.

• f. The concerned persons are further advised to ensure strict and continuous compliance with all applicable laws and internal codes at all times going forward.

• Reasons recorded in writing for taking action stated above

The Company took note of the these violations and, after considering the facts and circumstances of the case, including the review of trading data, the role of the individual concerned, the number of securities transacted, the explanation and submissions made by the concerned persons and in order to ensure regulatory compliance, uphold the standards of corporate governance and maintain market integrity, the Company considered it appropriate to take action in accordance with the Code of Conduct

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and the applicable provisions of the SEBI
(Prohibition of Insider Trading) Regulations, 2015
issued by SEBI.
7. Details of the previous instances of None
violations, if any, since last financial year
8. If any amount collected for Code of Conduct violation(s)
i. Mode of transfer to SEBI - IPEF Online
(Online/Demand Draft)
iii. Details of transfer/payment
In case of Online:
Particulars Details
Name of the transferor Sudha Churiwal
Bank Name, branch Bank of Baroda, Rash Behari Branch, Kolkata
Bank Account number 77810100000123
UTR/Transaction reference Number BARBR52026022100801821
Transaction date 21-02-2026
Transaction Amount (in Rs.) 4,82,000
In case of Demand Draft (DD): Not Applicable
Particulars Details
Bank Name and branch
DD Number
DD date Not Applicable
DD amount (in Rs.)
9. Any other relevant information Nil
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Yours faithfully,

For HEG Limited

Digitally signed by VIVEK VIVEK CHAUDHARY CHAUDHARY Date: 2026.02.21 20:50:37 +05'30'

(Vivek Chaudhary) Company Secretary and Compliance Officer M.No. A-13263 heg.investor@lnjbhilwara.com

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