Ramsons Projects Limited

CIN: L68100DL1994PLC063708

Corp. Office: Unit 501, 05th Floor, SAS Tower, Tower-B,
Sector- 38, Gurugram – 122001, Haryana
Phone: +91 124 4679000
Email: [email protected]
Website: www.ramsonsprojects.com

Ref No. 2026\RPL\62
May 19, 2026

Scrip ID: RAMSONS
Scrip Code: 530925

To,
The General Manager
Department of Corporate Services
BSE Limited
Phiroze Jeejeebhoy Towers,
Dalal Street, Mumbai 400 001

Subject: Outcome of Board Meeting held on 19th May 2026.
Ref: Regulation 30 of SEBI (Listing Obligations and Disclosures Requirements) Regulations, 2015 as amended.

Dear Sir/ Madam,

We would like to inform you that the Board of Directors of Ramsons Projects Limited (the "Company"), at its meeting held today, i.e., Tuesday, May 19, 2026, inter-alia considered and approved the following matters:

Audited Standalone Financial Results of the Company for the Fourth Quarter and Financial Year ended on March 31st 2026.

The Board of Directors considered and approved the Audited Standalone Financial Results of the Company for the fourth quarter and Financial Year ended March 31, 2026, together with the Auditor's Report thereon.

The certified copies of Financial Results along with Audit Report are enclosed herewith as Annexure A, pursuant to Regulation 33 of the SEBI Listing Regulations.

Further, in terms of requirements of Regulation 33(3)(d), we hereby confirm you that the aforesaid Audit Report of the Statutory Auditors 'M/s NVM & Co., Chartered Accountants' is Unmodified and contains no audit qualifications.

Re-appointment of Internal Auditor

The Board considered and approved the re-appointment of Mr. Piyush Rampuria, Chartered Accountant, as Internal Auditor of the Company for the Financial Year 2026-27.

Regd. Office: 201, Empire Apartments, First Floor, Sultanpur, Gadaipur, New Delhi - 110030

Ramsons Projects Limited

CIN: L68100DL1994PLC063708

Corp. Office: Unit 501, 05th Floor, SAS Tower, Tower-B,
Sector- 38, Gurugram – 122001, Haryana
Phone: +91 124 4679000
Email: [email protected]
Website: www.ramsonsprojects.com

The details of the aforesaid matters pursuant to the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and the SEBI Master circular bearing reference number HO/49/14/14(7)2025-CFD-POD2/I/3762/2026 dated January 30, 2026, is enclosed herewith as Annexure B.

3. Revision of Insider Trading Codes

Pursuant to Regulation 8 and Regulation 9 of the SEBI (Prohibition of Insider Trading) Regulations, 2015, the Board reviewed and approved the amended:

‘Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons and their Immediate Relatives and the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information.’

The amended Insider Trading Code are enclosed herewith in Annexure “C” and are also available on the Company's website at www.ramsonsprojects.com .

4. Place of Maintenance of Books and Registers

The Board of Directors approved the maintenance and keeping of the books of account, statutory registers, and other relevant books, papers, and financial statements of the Company at the following address:

Unit 501, 5th Floor, Eleven Bay (previously known as SAS Tower), Tower B, Sector-38, Gurugram – 122001, Haryana, India.

The Board meeting commenced at 3:55 P.M. and concluded at 4:15 P.M.

Kindly acknowledge the receipt.

Thanking You,

For and on behalf of
Ramsons Projects Limited

ASHWARYA
MAHESHWARI
Digitally signed by
ASHWARYA
MAHESHWARI
Date: 2026.05.19
18:39:39 +05'30'

Ashwarya Maheshwari
Company Secretary cum
Compliance Officer
Mem. No. A71660
Add: Unit no. 501, 5th Floor, SAS Tower,
Tower-B, Sector 38, Gurugram – 122001,
Haryana
Encl: As above

Regd. Office: 201, Empire Apartments, First Floor, Sultanpur, Gadaipur, New Delhi - 110030

NVM & COMPANY

Chartered Accountants

Annexure A

INDEPENDENT AUDITOR'S REPORT ON STANDALONE ANNUAL FINANCIAL RESULTS

Pursuant to Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (as amended)

The Board of Directors of

Ramsons Projects Limited

Opinion

We have audited the accompanying standalone annual financial results of Ramsons Projects Limited ('the Company') for the year ended 31 March 2026, attached herewith, being submitted by the Company pursuant to the requirements of Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (as amended) ('Listing Regulations').
In our opinion and to the best of our information and according to the explanations given to us, the aforesaid standalone annual financial statement:

i. presents financial results in accordance with the requirements of Regulation 33 of the Listing Regulations; and

ii. gives a true and fair view in conformity with the recognition and measurement principles laid down in the applicable Indian Accounting Standards ('Ind AS') specified under section 133 of the Companies Act, 2013 ('the Act'), read with the Companies (Indian Accounting Standards) Rules, 2015, and other accounting principles generally accepted in India, of the standalone net profit after tax and other comprehensive income and other financial information of the Company for the year ended 31 March 2026.

Basis for Opinion

We conducted our audit in accordance with the Standards on Auditing specified under section 143(10) of the Act. Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Standalone Annual Financial Results section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India ('ICAI') together with the ethical requirements that are relevant to our audit of the standalone financial statement under the provisions of the Act and the rules thereunder, and we have fulfilled our other ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the audit evidence obtained by us is sufficient and appropriate to provide a basis for our opinion on the standalone annual financial results.

J-30, 1st Floor, Lajpat Nagar-3, New Delhi-110024, Tel : +91-11-41345500, 41345566

M : +91-9810147151, E-mail : [email protected], www.nvmindia.com

Page 2 of 3

Responsibilities of Management and Those Charged with Governance for the Statement

This Standalone annual financial result has been prepared on the basis of the standalone annual financial statements and has been approved by the Company's Board of Directors. The Company's Board of Directors is responsible for the preparation and presentation of the Standalone annual financial results that gives a true and fair view of the net profit/(loss) and other comprehensive income and other financial information of the Company in accordance with the Indian Accounting Standards prescribed under section 133 of the Act, read with the Companies (Indian Accounting Standards) Rules, 2015 and other accounting principles generally accepted in India, and in compliance with Regulation 33 of the Listing Regulations. This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding of the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring accuracy and completeness of the accounting records, relevant to the preparation and presentation of the Standalone annual financial results that gives a true and fair view and is free from material misstatement, whether due to fraud or error.
In preparing the Standalone annual financial results, the Board of Directors is responsible for assessing the Company's ability to continue as a going concern, disclosing, as applicable, matters related to going concern, and using the going concern basis of accounting unless the Board of Directors either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.
The Board of Directors is also responsible for overseeing the Company's financial reporting process.

Auditor's Responsibilities for the Audit of the Statement

Our objectives are to obtain reasonable assurance about whether the Standalone annual financial results as a whole is free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with Standards on Auditing, specified under section 143(10) of the Act, will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these Standalone annual financial results.
As part of an audit in accordance with the Standards on Auditing, specified under section 143(10) of the Act, we exercise professional judgment and maintain professional skepticism throughout the audit. We also:
Identify and assess the risks of material misstatement of the Standalone annual financial results, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control;

Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the Company has adequate internal financial controls with reference to financial statements and the operating effectiveness of such controls;
Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by the Board of Directors;
Conclude on the appropriateness of the Board of Directors’ use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Company’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the Standalone annual financial results or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause the Company to cease to continue as a going concern; and
Evaluate the overall presentation, structure and content of the Standalone annual financial results, including the disclosures, and whether the Standalone annual financial results represent the underlying transactions and events in a manner that achieves fair presentation.
We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.
We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards.

Other Matter

The Standalone annual financial results include the results for the quarter ended 31 March 2026, being the balancing figures between the audited figures in respect of the full financial year and the published unaudited year-to-date figures up to the third quarter of the current financial year, which were subject to limited review by us.

For NVM & Company.
Chartered Accountants
FRN: 012974N

Sachin Sharma
Partner
Membership No.: 537682
Place: Delhi
Date: 19-05-2026
UDIN: 26537682VTBKYL5446

Page 3 of 3

RAMSONS PROJECTS LIMITED

Regd. Office : 201, Empire Apartments, First Floor, Sultsapur, Gedeipur, South West Delhi, New Delhi-110030

CIN: L68100DL1994PLC063708

STATEMENT OF FINANCIAL RESULTS FOR THE YEAR ENDED 31ST MARCH 2026

INR in Lakh (except stated otherwise)

	PARTICULARS	QUARTER ENDED			YEAR ENDED	YEAR ENDED
		31-Mar-26	31-Dec-28	31-Mar-25	31-Mar-26	31-Mar-25
		(AUDITED)	(UNAUDITED)	(AUDITED)	(AUDITED)	(AUDITED)
	INCOME:
1	REVENUE FROM OPERATIONS*	-	-	-	-	-
2	OTHER INCOME	228.73	18.51	281.98	921.23	366.29
3	TOTAL INCOME	228.73	18.51	281.98	921.23	366.29

	EXPENSE:
	EMPLOYEE BENEFITS EXPENSE	13.74	11.38	3.77	35.34	13.83
	FINANCE COSTS	0.01	0.00	0.01	0.06	0.06
	DEPRECIATION AND AMORTIZATION EXPENSE	1.43	1.51	0.35	5.99	0.74
	PROVISIONS FOR STANDARD ASSETS AND WRITE OFF/(REVERSAL)	-	0.00	(2.10)	-	-
	OTHER EXPENSES	1.03	3.80	14.58	28.67	25.30
4	TOTAL EXPENSES	18.21	16.69	16.63	70.06	39.93

5	PROFIT BEFORE PRIOR PERIOD AND EXCEPTIONAL ITEMS AND TAX	210.53	1.82	265.35	851.17	326.35
6	PRIOR PERIOD EXPENSE AND EXCEPTIONAL ITEMS	-	-	-	-	-
7	PROFIT BEFORE TAX	210.53	1.82	265.35	851.17	326.35

	TAX EXPENSE
8	CURRENT TAX/MAT/TAX EARLIER YEARS/DEFERRED TAX	(2.21)	0.95	38.61	95.97	55.08
9	PROFIT FOR THE PERIOD FROM CONTINUING OPERATIONS	212.74	0.87	226.75	755.20	271.27

10	PROFIT FROM DISCONTINUED OPERATIONS	-	-	-	-	-
11	TAX EXPENSE OF DISCONTINUED OPERATIONS	-	-	-	-	-
12	PROFIT FROM DISCONTINUED OPERATIONS (AFTER TAX)	-	-	-	-	-

13	PROFIT FOR THE PERIOD	212.74	0.87	226.75	755.20	271.27
14	OTHER COMPREHENSIVE INCOME
	A) (I) ITEMS THAT WILL NOT BE RECLASSIFIED TO PROFIT OR LOSS	(28.44)	(1.13)	(0.08)	(30.75)	3.84
	(II) INCOME TAX RELATING TO ITEMS THAT WILL NOT BE RECLASSIFIED TO PROFIT OR LOSS	-	-	-	-	-
	(III) INCOME TAX RELATING TO ITEMS THAT WILL BE RECLASSIFIED TO PROFIT OR LOSS	-	-	-	-	-
	(IV) INCOME TAX RELATING TO ITEMS THAT WILL BE RECLASSIFIED TO PROFIT OR LOSS	-	-	-	-	-
15	OTHER COMPREHENSIVE INCOME / (LOSS) (NET OF TAX)	(28.44)	(1.13)	(0.08)	(30.75)	3.84

16	TOTAL COMPREHENSIVE INCOME (AFTER TAX)	184.30	(0.26)	226.67	724.48	275.12
17	EARNINGS PER EQUITY SHARE (FACE VALUE OF R5.10/- EACH)
	A) BASIC (R5.)	7.08	0.03	7.34	25.12	9.02
	B) DILUTED (R5.)	7.08	0.03	7.34	25.12	9.02

The financial results of the company for the period ended as on 31-03-2026 has been prepared on standalone basis, there is no situation where consolidation is required in the case of the company.
*Pursuant to the Company's application for voluntary surrender of its NBFC registration, the Reserve Bank of India ("RBI"), side its Order dated 19th September 2025, approved the cancellation of the Company's Certificate of Registration as a Non-Banking Financial Company ("NBFC"). Consequently, the Company ceased to be an NBFC with effect from the said date and, accordingly, these results are presented in the format applicable to non-NBFC, listed companies i.e. Schedule III Division II of the Companies Act, 2013.

FOR AND ON BEHALF OF THE BOARD OF RAMSONS PROJECTS LIMITED

(YOGESH KUMAR SACHDIWA)

MANAGING DIRECTOR

DIN: 00171917

RAMSONS PROJECTS LIMITED

Regd. Office : 201, Empire Apartments, First Floor, Sultanpur, Gadalpur, South West Delhi, New Delhi-110030
CIN: L68100DL1994PLC063708
STANDALONE BALANCE SHEET AS AT 31ST MARCH 2026

INR in Lakh (except stated otherwise)
PARTICULARS	NOTE NO.	AS ON 31-Mar-26	AS ON 31-Mar-25
I ASSETS
NON CURRENT ASSETS
PROPERTY, PLANT & EQUIPMENT	3	38.04	44.02
INTANGIBLE ASSETS	4	-	2.24
FINANCIAL ASSETS:
INVESTMENTS	5	730.87	49.29
OTHER FINANCIAL ASSETS	6	50.00	-
DEFERRED TAX ASSETS (NET)	7	34.89	24.10
TOTAL NON CURRENT ASSETS		853.80	119.65
CURRENT ASSETS
FINANCIAL ASSETS:
CASH & CASH EQUIVALENTS	8	642.81	1,099.40
OTHER BANK BALANCES	9	506.09	-
LOANS	10	-	110.38
OTHER FINANCIAL ASSETS	11	26.26	0.40
CURRENT TAX ASSET (NET)	12	16.88	4.88
OTHER CURRENT ASSETS	13	10.58	0.90
TOTAL CURRENT ASSETS		1,202.62	1,215.96
TOTAL ASSETS		2,056.42	1,335.61
II EQUITY AND LIABILITIES
EQUITY
SHARE CAPITAL	14	300.65	300.65
OTHER EQUITY	15	1,752.71	1,028.25
TOTAL EQUITY		2,053.36	1,328.90
LIABILITIES
CURRENT LIABILITIES
OTHER CURRENT LIABILITIES	16	3.06	6.71
		3.06	6.71
TOTAL LIABILITIES		3.06	6.71
TOTAL EQUITY AND LIABILITIES		2,056.42	1,335.61

FOR AND ON BEHALF OF THE BOARD OF RAMSONS PROJECTS LIMITED

WIGESH KUMAR SACHDEVA)
MANAGING DIRECTOR
DIN: 00171917

RAMSONS PROJECTS LIMITED

Regd. Office : 201, Empire Apartments, First Floor, Sultanpur, Gadaipur, South West Delhi, New Delhi-110030

CIN: L68100DL1994PLC063708

STATEMENT OF CASH FLOWS FOR THE YEAR ENDED 31ST MARCH 2026

PARTICULARS	INR in Lakh (except stated otherwise)
	YEAR ENDED
31-Mar-26	YEAR ENDED
31-Mar-25
A. CASH FLOW FROM OPERATING ACTIVITIES
PROFIT FOR THE YEAR	851.17	326.35
ADJUSTMENTS FOR:
DEPRECIATION	5.99	0.76
LOSS/(PROFIT) ON SHARE OF LLP	(211.14)	-
PROFIT ON SALE OF TDR	(639.91)	(258.25)
REVERSAL OF PROVISION OF DOUBTFUL DEBTS - STANDARD ASSETS	(0.44)	(1.18)
OPERATING PROFIT BEFORE WORKING CAPITAL CHANGES	5.67	67.70
ADJUSTMENTS FOR :
CHANGES IN WORKING CAPITAL
CURRENT LIABILITIES	(3.65)	(4.96)
CURRENT ASSETS	(528.94)	5.56
OTHER ASSETS	(86.65)	4.27
CASH GENERATED FROM OPERATIONS	(613.57)	72.56
LESS: DIRECT TAXES PAID	95.97	55.06
NET CASH FROM OPERATING ACTIVITIES: (A)	(709.54)	17.50
B. CASH FROM INVESTING ACTIVITIES
PURCHASE OF FIXED ASSETS	-	(37.19)
PROCEEDS FROM SALE OF TDR	642.15	261.00
CAPITAL CONTRIBUTION IN LLP	(500.00)	-
NET CASH USED IN INVESTING ACTIVITIES: (B)	142.15	223.81
C. CASH FLOW FROM FINANCING ACTIVITIES
LOANS GIVEN/(RECOVERED)	110.82	289.20
NET CASH FLOW FROM FINANCING ACTIVITIES: (C)	110.82	289.20
NET INCREASE IN CASH AND CASH EQUIVALENT: (A+B+C)	(456.58)	530.51
OPENING BALANCE OF CASH AND CASH EQUIVALENTS	1,099.40	568.86
CLOSING BALANCE OF CASH AND CASH EQUIVALENTS	642.81	1,099.40

NOTE: THE CASH FLOW STATEMENT HAS BEEN PREPARED UNDER THE INDIRECT METHOD AS SET OUT IN THE INDAS 7 'STATEMENT OF CASH FLOWS'.

Ramsons Projects Limited

Notes to the Audited Financial Results for Q4 & FY ended March 31, 2026

The above standalone financial results of Ramsons Projects Limited (‘the Company’) for the quarter and year ended March 31, 2026 have been reviewed by the Audit Committee and approved by the Board of Directors at their respective meetings.
These results have been prepared in accordance with the recognition and measurement principles laid down in the applicable Indian Accounting Standards specified under Section 133 of the Companies Act, 2013 read with the Companies (Indian Accounting Standards) Rules, 2015 (as amended) and other accounting principles generally accepted in India, and are in compliance with the presentation and disclosure requirements of Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (as amended).
Pursuant to the Company’s application for voluntary surrender of its NBFC registration, the Reserve Bank of India, vide its Order dated September 19, 2025, approved the cancellation of the Company’s Certificate of Registration as a Non-Banking Financial Company. Consequently, the Company ceased to be an NBFC with effect from the said date and these results are presented in the format applicable to non-NBFC, listed companies (Schedule III, Division II). The requirement to create Statutory Reserve under Section 45-IC of the RBI Act, 1934 is no longer applicable.
The Company operates in a single business segment, comprising real estate and related investment activities, and accordingly separate segment reporting under Ind AS 108 is not applicable.
Total income of INR 921.23 Lakh (PY: INR 366.29 Lakh) was earned through Other Income, primarily comprising profit on sale of Transferable Development Rights of INR 639.91 Lakh, share of profit from SAS Fininvest LLP of INR 211.14 Lakh, and interest income of INR 69.55 Lakh.
During the year, the Company made a capital contribution of INR 500 Lakh in SAS Fininvest LLP (a related party) and was credited with a profit share of INR 211.14 Lakh, taking the closing carrying value to INR 711.14 Lakh, classified under Non-Current Investments. Profit After Tax for the year stood at INR 755.20 Lakh (PY: INR 271.27 Lakh), with Basic and Diluted EPS of INR 25.12 (PY: INR 9.02).
The figures for the quarter ended March 31, 2026 and March 31, 2025 are the balancing figures between the audited figures for the full financial year and the unaudited year-to-date figures up to the third quarter, which were subjected to limited review. Previous year figures have been regrouped/reclassified wherever necessary to conform to the current year’s presentation.

For and on behalf of the Board of Directors of
Ramsons Projects Limited

Yogesh Kumar Sachdeva
(Managing Director)
DIN: 00171917

Place: Gurugram
Date: 19/05/2026

Ramsons Projects Limited

CIN: L68100DL1994PLC063708

Corp. Office: Unit 501, 05th Floor, SAS Tower, Tower-B,

Sector- 38, Gurugram – 122001, Haryana

Phone: +91 124 4679000

Email: [email protected]

Website: www.ramsonsprojects.com

Date- May 19, 2026

To,

The General Manager

Department of Corporate Services

BSE Limited

Phiroze Jeejeebhoy Towers

Dalal Street, Mumbai 400 001

Subject: Declaration on Audited Financial Results in compliance with the Regulation 33(3)(d) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015

In terms of Regulation 33(3)(d) of the SEBI (LODR) Regulations, 2015, we hereby declare that M/s. NVM and Co., Chartered Accountant, (Firm Reg. No. 012974N), Statutory Auditors of the Company, have issued Audit Reports with Unmodified opinion on the Annual Audited Financial Results of the Company for Financial year ended on March 31, 2026.

For and on behalf of

Ramsons Projects Limited

Yogesh Kumar Sachdeva

Managing Director

DIN: 00171917

Regd. Office: 201, Empire Apartments, First Floor, Sultanpur, Gadaipur, New Delhi - 110030

Ramsons Projects Limited

CIN: L68100DL1994PLC063708

Corp. Office: Unit 501, 05th Floor, SAS Tower, Tower-B,

Sector- 38, Gurugram – 122001, Haryana

Phone: +91 124 4679000

Email: [email protected]

Website: www.ramsonsprojects.com

Annexure-B

Details under Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 read with SEBI circular HO/49/14/14(7)2025-CFD-POD2/I/3762/2026 dated January 30, 2026

Re-appointment of Internal auditor

Sr. No	Particulars	Re-appointment of Internal Auditor
1.	Reason for change viz. appointment, reappointment, resignation, removal, death or otherwise;	Re -appointment of Mr. Piyush Rampuria as Internal Auditor of the Company.
2.	Date of re-appointment/ cessation (as applicable) & term of appointment/ re-appointment	Date of Re-appointment – 19^{th} May 2026
Term of Re-appointment- Financial Year 2026-27.
3.	Brief profile (in case of appointment)	Not Applicable
4.	Disclosure of relationships between directors (in case of appointment of a Director);	Not Applicable

Regd. Office: 201, Empire Apartments, First Floor, Sultanpur, Gadaipur, New Delhi - 110030

Ramsons Projects Limited

Annexure "C"

RAMSONS PROJECTS LIMITED

CODE OF CONDUCT TO REGULATE, MONITOR AND REPORT TRADING BY DESIGNATED PERSONS

AND

CODE OF PRACTICE AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION

Ramsons Projects Limited

1. Preamble

In terms of the Regulation 8(1) and 9(1) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 as amended from time to time ('SEBI PIT Regulation'), the board of directors ("Board" or "Board of Directors") of every listed company is required to formulate and publish on its official website, a code of practices and procedures for fair disclosure of unpublished price sensitive information that it would follow in order to adhere to each of the principles set out in Schedule A and the chief executive officer or managing director is required to formulate a code of conduct with the Board's approval for regulating, monitoring and reporting trades by its designated persons and immediate relatives of designated persons by adopting the minimum standards set out in Schedule B of the SEBI PIT Regulations, respectively.

Pursuant to Regulation 8(1) and 9 (1) of the SEBI PIT Regulations, the Company hereby adopts this code (herein referred to as "Code" or "Insider Trading Code") to ensure fair disclosure of unpublished price sensitive information and to regulate, monitor and report trading by its designated persons and immediate relatives of designated persons towards achieving compliance with the SEBI PIT Regulations.

The Insider Trading Code approved by the Board of Directors of the Company at its meeting held on 19.05.2026 incorporates the amendments made to the SEBI (Prohibition of Insider Trading) Regulations, 2015 up to 12th March 2025.

This Code contains two parts:

Part – A i.e. Code of conduct to regulate, monitor and report trading by designated person
Part – B i.e. Code of practices and procedures for fair disclosure of unpublished price sensitive information

The Code shall be called as "Code of Practice and Procedures for Fair Disclosure of Unpublished Price Sensitive Information and Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons". The Code will come into force with immediate effect.

This Code aims to ensure transparency, fairness, and equality of access to Unpublished Price Sensitive Information (UPSI) through timely and adequate public disclosures, while also regulating, monitoring, and reporting the trading activities of Designated Persons to prevent insider trading and protect investor interests. All designated persons and immediate relatives thereof shall be bound by the SEBI PIT Regulations and this Code.

Definitions:

‘Act’ means the Securities and Exchange Board of India Act, 1992

“Company” means Ramsons Projects Limited.

“Compliance Officer” means any senior officer, designated so and reporting to the board of directors or head of the organization in case board is not there, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under these regulations and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the preservation of unpublished price sensitive information,

Ramsons Projects Limited

monitoring of trades and the implementation of the codes specified in these regulations under the overall supervision of the board of directors of the listed company or the head of an organization, as the case may be.

The Company Secretary of the Company shall be the Compliance Officer for the purpose of this Policy.

“Board”; means Board of Director of the Company

“Code” means this Code of Conduct to Regulate, Monitor and Report Trading by Insiders and the Code of Fair Disclosure, as applicable, including modifications made thereto from time-to-time.

"Connected Person" means,-

any person who is or has been, during the six months prior to the concerned act, associated with a company, in any capacity, directly or indirectly, including by reason of frequent communication with its officers or by being in any contractual, fiduciary or employment relationship or by being a director, officer or an employee of the company or holds any position including a professional or business relationship, whether temporary or permanent, with the company, that allows such a person, directly or indirectly, access to unpublished price sensitive information or is reasonably expected to allow such access.

(ii) Without prejudice to the generality of the foregoing, the persons falling within the following categories shall be deemed to be connected persons unless the contrary is established, -

(a). relative of connected persons specified in clause (i); or
(b). a holding company or associate company or subsidiary company; or
(c). an intermediary as specified in section 12 of the Act or an employee or director thereof; or
(d). an investment company, trustee company, asset management company or an employee or director thereof; or
(e). an official of a stock exchange or of clearing house or corporation; or
(f). a member of board of trustees of a mutual fund or a member of the board of directors of the asset management company of a mutual fund or is an employee thereof; or
(g). a member of the board of directors or an employee, of a public financial institution as defined in section 2 (72) of the Companies Act, 2013; or
(h). an official or an employee of a self-regulatory organization recognised or authorized by the SEBI; or
(i). a banker of the company; or
(j). a concern, firm, trust, Hindu undivided family, company or association of persons wherein a director of a company or his relative or banker of the company, has more than ten per cent. of the holding or interest;
(k). a firm or its partner or its employee in which a connected person specified in sub-clause (i) of clause (d) is also a partner; or
(l). a person sharing household or residence with a connected person specified in sub-clause (i) of clause (d);

“Designated Persons”

The term Designated Person shall consist of, Connected Persons who are:

a) Promoters of the Company.
b) Directors and Key Managerial Personnel (KMP) e Company and its material subsidiaries.
c) Senior Management Personnel of the Company i.e. employees up to two levels below the Board of the Company and its material subsidiaries including the functional and department

Ramsons Projects Limited

heads.

d) All employees of the Finance, Accounts, Audit, Taxation, Legal & Secretarial, Corporate Communication functions of Corporate Finance, irrespective of their grade.
e) Employees of such other functions of the Company and material subsidiaries of listed Company who are in possession or likely to be in possession of Unpublished Price Sensitive Information.
f) Any support staff of the Company, intermediary or fiduciary such as IT staff or secretarial staff who have access to unpublished price sensitive information.
g) Such other persons who may be designated as such from time to time, by the Board of Directors in consultation with the Compliance Officer, for the purpose of this Code, on the basis of their role and function in the organisation and the access that such role and function would provide to unpublished price sensitive information in addition to seniority and professional designation.

Note

The list of Designated Persons under this section is subject to change/updation from time to time with the approval of Managing Director and the same will be notified to all the employees of the Company through internal circular issued by Board of Director and Secretarial Department.
Immediate Relatives of the Designated Persons (means a spouse of the person, and includes parent, sibling, and child of such person or of the spouse, any of whom is either dependent financially on such person or consults such person in taking decisions relating to trading in securities).

"Fiduciaries" collectively to be referred as professional firms such as auditors, accountancy firms, law firms, analysts, insolvency professional entities, consultants, banks etc., assisting or advising the Company.

"Financially Literate" shall mean a person who has the ability to read and understand basic financial statements i.e. balance sheet, profit and loss account, and statement of cash flows.

"Generally Available Information" means information that is accessible to the public on a non-discriminatory basis, and shall not include unverified event or information reported in print or electronic media. For example, information which is published on the website of stock exchange(s) where the Securities of the Company are listed or published by way of a press release by the Company, would ordinarily be considered generally available.

"Immediate Relative" means a spouse of a person, and includes parent, sibling, and child of such person or of the spouse, any of whom is either dependent financially on such person, or consults such person in taking decisions relating to trading in securities.

"Insider" means any person who is:

i) a Connected Person; or
ii) in possession of or having access to unpublished price sensitive information.

"Key Managerial Personnel" or "KMP" shall have the same meaning assigned to it under the Companies Act, 2013, as amended from time to time.

"Listing Regulations" shall mean the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 and every modifications or amendment thereof.

Ramsons Projects Limited

"Material Financial Relationship" shall mean a relationship in which one person is a recipient of any kind of payment such as by way of a loan or gift from a Designated Person during the immediately preceding twelve months, equivalent to at least 25% of the annual income of such Designated Person but shall exclude relationships in which the payment is based on arm's length transactions.

"Material Subsidiary" shall have the same meaning assigned to it under Regulation 16(1)(c) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to time.

"Promoter" shall have the meaning assigned to it under the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 or any modification thereof.

"Promoter Group" shall have the meaning assigned to it under the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 or any modification thereof.

"SEBI" shall mean Securities and Exchange Board of India.

"SEBI PIT Regulations" shall mean the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 and every modifications and amendment thereof.

"Securities" shall have the meaning assigned to it under the Securities Contracts (Regulation) Act, 1956 or any modification thereof except units of a mutual fund.

"Takeover Regulations" means the Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 and any amendments thereto.

"Trading" means and includes subscribing, buying, selling, dealing, or agreeing to subscribe, buy, sell, deal in securities, and "trade" shall be construed accordingly.

"Trading Day" means a day on which the recognized stock exchanges are open for trading.

"Trading Window" means the period during which trading may be carried out in Company's securities by Designated Persons.

"Unpublished Price Sensitive Information" ("UPSI") shall have the meaning assigned to it under Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015.

"Relative" shall mean the following:

(i) Spouse of the person;
(ii) Parent of the person and parent of its spouse;
(iii) Sibling of the person and sibling of its spouse;
(iv) Child of the person and child of its spouse;
(v) Spouse of the person listed at clause (iii) above; and
(vi) Spouse of the person listed at clause (iv).

"Need to know":

The Designated Persons who are privy to UPSI, shall handle the same strictly on a "Need to Know" basis. This means the UPSI shall be disclosed only to those persons who need to

Ramsons Projects Limited

know the same in furtherance of a legitimate purpose, the course of performance or discharge of their duty and whose possession of UPSI will not in any manner give rise to a conflict of interest or likelihood of misuse of the information.

"Legitimate Purpose":

The term legitimate purpose" shall include sharing of unpublished price sensitive information in the ordinary course of business by an insider with partners, collaborators, lenders, customers, suppliers, merchant bankers, legal advisors, auditors, insolvency professionals or other advisors or consultants, provided that such sharing has not been carried out to evade or circumvent the prohibitions of these regulations.

Any person in receipt of unpublished price sensitive information pursuant to a "legitimate purpose" shall be considered an "insider" for purposes of these regulations and due notice shall be given to such persons to maintain confidentiality of such unpublished price sensitive information in compliance with these regulations.

Policy on Determination of Legitimate Purpose is attached to this Code (see Annexure A).

"Trading Plans":

The Regulations recognize the concept of Trading Plans. An Insider intending to formulate a Trading Plan shall consult the Compliance Officer to discuss the applicable rules and procedure. The Compliance Officer shall only approve a Trading Plan in accordance with the applicable provisions of the Regulations.

"Interpretation: In this document, unless contrary intention appears: (a) The singular includes the plural and vice versa; (b) Any word or expression importing the masculine, feminine or neuter genders only, shall be taken to include all three genders.

Words and expressions used and not defined herein but defined in the Securities and Exchange Board of India Act, 1992, the Securities Contracts (Regulation) Act, 1956 the Depositories Act, 1996 or the Companies Act, 2013 and rules and regulations made thereunder shall have the meanings respectively assigned to them in such legislation.

Ramsons Projects Limited

PART – A

CODE OF CONDUCT TO REGULATE, MONITOR AND REPORT TRADING BY

DESIGNATED PERSON

1. Roles and Responsibilities of the Compliance Officer

Subject to the supervision of the Board of Directors, the Compliance Officer shall be responsible for:

a) Setting forth policies, procedures, monitoring adherence to the rules for the preservation of Unpublished Price Sensitive Information, approval and review of trading plans, pre-clearances of Trades and monitoring of Trades maintaining a structured digital database and implementation of the Code under the overall supervision of the Board of Directors of the Company.

b) Assisting and addressing all the clarifications of the Insiders, Designated Persons and their immediate relatives, with respect to the Code and the SEBI PIT Regulations.

c) Maintaining and preserving all disclosures/ undertakings and applications made under the Code and monitoring the effective system of Internal control.

d) Obtain all the declarations/ information as may be required from time to time from the identified Designated Persons for ensuring compliance of the SEBI PIT Regulations.

e) Regulating and monitoring the Trading Window of the Securities of the Company.

f) Undertaking such other duties and responsibilities as set out under the SEBI PIT Regulations.

The Compliance Officer shall report on the compliance of this code to the Board of Directors and in particular, shall provide reports to the Chairman of the Audit Committee or to the Chairman of the Board of Director at least once in a financial year.

2. Restrictions on communication or procurement of unpublished price sensitive information

No insider shall communicate, provide, or allow access to any UPSI, relating to the Company or securities, to any person including other insiders except where such communication is in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

No person shall procure from or cause the communication by any insider of UPSI, relating to the Company or securities, except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

However, UPSI may be communicated, provided, allowed access to or procured, in connection with a transaction which:

Ramsons Projects Limited

a) Entail an obligation to make an open offer under the Takeover Regulations where the Board of the Company is of the informed opinion that sharing of such information is in the best interests of the Company;

b) Not attract the obligation to make an open offer under the Takeover Regulations but where the Board of the Company is of informed opinion that sharing of such information is in the best interests of the Company and Unpublished Price Sensitive Information is disseminated to be made generally available at least two trading days prior to the proposed transaction being effected in such form as the Board may determine to be adequate and fair to cover all relevant and material facts.

c) This prohibition does not apply where such communication is in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

d) Any person in receipt of Unpublished Price Sensitive Information pursuant to a "legitimate purpose" shall be considered an "Insider" for purposes of these SEBI PIT Regulations and this Code and due notice shall be given to such persons to maintain confidentiality of such Unpublished Price Sensitive Information in compliance with SEBI PIT Regulations and this Code.

For the purpose of above, any party dealing with the Company and having access to any Unpublished Price Sensitive Information (UPSI) shall execute agreements to contract confidentiality and non-disclosure obligations on the part of such parties and such parties shall keep information so received confidential, except for the purpose of above, and shall not otherwise trade in Securities of the Company when in possession of Unpublished Price Sensitive Information.

3. INSTITUTIONAL MECHANISM FOR PREVENTION OF INSIDER TRADING:

The Managing Director, Compliance Officer of the Company or any other person authorized by the Board shall put in place an adequate and effective system of internal controls to ensure compliance with the requirements given in the Regulations to prevent insider trading.

The internal controls include the following:

a) all Employees who have access to UPSI shall be identified as designated persons;

b) all UPSI shall be identified and its confidentiality shall be maintained as per the requirements of this Code and the Regulations;

c) adequate restrictions shall be placed on communication or procurement of UPSI as required by the Code;

d) lists of all employees and other persons with whom UPSI is shared shall be maintained and confidentiality agreements shall be signed or notice shall be served to all such employees and persons;

e) all other relevant requirements specified under the Code shall be complied with;

f) periodic process review, on an annual basis shall be conducted.

The Board of the Company shall ensure that the Managing Director or Compliance Officer or any other person authorized by the Board ensures compliance with Regulations 9(1), 9(2), 9A(1) and 9A(2).

The Audit Committee of the Company shall review compliance with the provisions of the Regulations, at least once in a financial year, on the basis of the Internal Audit Report presented and shall verify that the systems for internal control are adequate and are operating effectively.

Ramsons Projects Limited

Policy and procedure for inquiry in case of leak or suspected leak of UPSI (mentioned in point no.7), has been formulated by the Company and duly approved by Board of the Company. Accordingly, the Chairman of Audit Committee of the Company shall initiate appropriate inquiries on becoming aware of leak of UPSI or suspected leak of UPSI and promptly inform SEBI only after the verification by the Audit Committee.

The Company shall have a whistle-blower policy which shall be available on the website of the Company. The Company shall also take steps to create awareness amongst its employees to enable them to report instances of leak of any UPSI.

If an inquiry is initiated by the Company in case of reported leakage of UPSI or suspected leak of UPSI, the Intermediaries and Fiduciaries engaged by the Company shall be duty bound to co-operate with the Company in connection with such inquiry conducted by the Company.

4. Preservation of unpublished price sensitive information

a) Insider shall maintain the confidentiality of all Unpublished Price Sensitive Information. They shall, while in possession of any Unpublished Price Sensitive Information, neither Trade in the Securities of the Company on the basis of Unpublished Price Sensitive Information nor pass on such information to any person directly or indirectly by way of making a recommendation for Trading in Securities of the Company.

b) Access to or handling of Unpublished Price Sensitive Information shall be on a “need-to-know” basis and no Unpublished Price Sensitive Information shall be communicated to any person except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

c) Files containing Unpublished Price Sensitive Information shall be kept secure. Computer files shall have adequate security of login and passwords, etc. guidelines for maintenance of electronic records.

d) To prevent the misuse of Unpublished Price Sensitive Information, the Company adopts the “Chinese Wall” policy which separates those areas of the Company which routinely have access to Unpublished Price Sensitive Information, considered “insider areas” from other areas or departments, considered “public areas”. Only specified persons are permitted to “cross the wall”.

e) The employees in the inside areas shall not communicate any UPSI to any one in public area. Demarcation of various departments as ‘inside area’ may be implemented by the Compliance Officer, in consultation with the Board.

In exceptional circumstances i.e. in furtherance of legitimate purposes, performance of duties or discharge of legal obligations, any Designated Person may be permitted to ‘cross the wall’ and give UPSI to any person on a ‘need to know’ basis, under intimation to the Compliance Officer.

5. Prevention of misuse of Unpublished Price Sensitive Information

All insider shall be subject to the trading restrictions as enumerated below;

Ramsons Projects Limited

A. Trading Plans

Insider who may be perpetually in possession of Unpublished Price Sensitive Information are entitled to formulate a trading plan to enable them to plan for trades to be executed in future and present it to the Compliance Officer for approval and public disclosure. Upon approval of the Trading Plan, the Compliance Officer shall notify the plan to the Stock Exchanges on which the Securities are listed. A insider who has formulated a Trading Plan and obtained approval of Compliance Officer shall carry out his trading as per the requirements provided under the SEBI PIT Regulations.

Non-Implementation of the trading plan

In case of non-implementation (full/partial) of the trading plan due to reasons such as permanent incapacity, bankruptcy, or operation of law or failure of execution of trade due to inadequate liquidity in the scrip, the following procedure shall be adopted:

Timely reporting to compliance officer within two trading days of end of tenure of the trading plan with reasons thereof and supporting documents, if any.
Compliance Officer to place the matter before Audit Committee in its immediate next meeting with his recommendation.
Audit Committee to review non-implementation of the trading plan for bona fide reasons.
Audit Committee’s decision to be notified to the stock exchanges on which securities are listed on the same day.
In case Audit Committee does not accept the submissions made by the insider, Compliance Officer to take action as per the Code of Conduct.

B. Trading Window

a) Other than the period(s) for which the ‘Trading Window’ is closed as prescribed hereunder, the same shall remain open for trading in the Securities of the Company by the Designated Persons and their Immediate Relatives. The Designated Persons and their immediate relatives shall not trade in securities when the trading window is closed.

b) In case of declaration of financial results, the Trading Window shall be closed during the period from the end of each quarter till 48 (forty eight) hours after the declaration of financial results. In all other circumstances, the time for commencement of closing of Trading Window shall be as determined by the Compliance Officer in consultation with the Board of Directors.

c) For unpublished price sensitive information not emanating from within the Company, trading window may not be closed.

d) The Compliance Officer after taking into account various factors including the Unpublished Price Sensitive Information in question becoming Generally Available Information and being capable of assimilation by the market, shall decide the timing for re-opening of the trading window, which however shall not in any event be earlier than 48 (forty eight) hours after the information becoming Generally Available Information. It shall be closed at the time of generation of UPSI from inside the Company.

e) In addition to the items specified above, the Trading Window shall also be closed when

Ramsons Projects Limited

the Compliance Officer determines that Designated Person(s) or class of them can reasonably be expected to have possession of Unpublished Price Sensitive Information. Such closure shall be imposed in relation to such Securities or such person to which such Unpublished Price Sensitive Information relates.

f) All Designated Persons (including their Immediate Relatives) shall conduct all their dealings in the Securities of the Company only in a valid trading window after procuring pre- clearance as referred under this Code, or as per approved trading plan and shall not deal in any transaction involving the purchase or sale of the Company's Securities during the periods when trading window is closed, or during any other period as may be specified by the Company from time to time.

g) Trading Window may be closed by the Company during such time in addition to the above period, as may be deemed fit by the Compliance Officer in consultation with the Board.

C. Pre-clearance of Trade

a) All Designated Persons or their Immediate Relatives who intend to deal in the Securities of the Company exceeding 5,000 in number or Rs.10,00,000/- (Rupees Ten lakhs Only) in value, whichever is lower, during a calendar quarter should pre-clear the transactions as per the pre-clearing procedure as discussed hereunder:

An application may be made to the Compliance Officer indicating the estimated number of Securities that the Designated Persons or their immediate relative intends to deal in, the detail of securities he already has and the details as to the depository participant(s) with which he has a security account.
An undertaking shall be executed in favour of the Company by such Designed Person incorporating, inter alia, the following clauses, as may be applicable:
That the Designated Person or his immediate relative does not have any access or has not received "Unpublished Price Sensitive Information" up to the time of signing the undertaking;
That in case the Designated Person has access to or receives "Unpublished Price Sensitive Information" after the signing of the undertaking but before the execution of the transaction he/she shall inform the Compliance Officer of the Company about change in his/her position and he/she would completely refrain from dealing in the securities of the company till the time such information becomes public;
That he/she has not contravened this Code, as notified by the Company from time to time.
That he/she has made a full and true disclosure.
The Compliance Officer shall either clear the requested deal or decline to clear the requested deal within 7 (seven) working days of the receipt of the application in the form as prescribed herein below. For the purpose of this clause, the term "Woking Days" shall mean days on which business is conducted at the registered office of the

Ramsons Projects Limited

Company, and shall exclude Saturdays, Sundays, National Holidays and other declared holidays.

In case the Compliance Officer declines to clear the requested deal, he shall assign reasons in writing for doing so.

b) In case the Compliance Officer or any of his Immediate Relative(s) intend to deal in the Securities of the Company then an application shall be made to the Managing Director or the Chairperson of the Company who would consider the requested deal within 7 (seven) working days as aforesaid. The remaining procedure for pre-clearance of Trade, as applicable to Designated Persons or their immediate relative(s), shall also apply to the Compliance Officer.

c) The person who has obtained the pre-clearance, shall complete execution of their pre-cleared trades in respect of Securities of the Company not later than 7 (seven) Trading Days after the approval of pre-clearance is given, failing which fresh pre-clearance would be required for the trades to be executed.

d) The person executing pre-cleared trades shall file within 2 (two) trading days of the execution of the Trade, the details of such Trade, with the Compliance Officer in the format set out herein below in this Code. In the event such Trade is not executed, a report to that effect shall be filed with the Compliance Officer also in the format set out herein below in this Code.

e) All the persons who are permitted to trade shall not enter into a contra trade during the next 6 (six) months following the prior trade. However, this restriction shall not be applicable for trades pursuant to exercise of stock options.

f) In case the contra trade is necessitated by emergency, the Compliance Officer may waive the holding period after recording in writing reasons in this regard provided such waiver does not violate the SEBI PIT Regulations and the Code. Similarly in the case of emergency of Trade by a Compliance Officer, the Compliance Officer may obtain the waiver from the Managing Director or in his absence, the Chairman of the Board, provided that such waiver does not violate the Code or the SEBI PIT Regulations. The application for waiver shall be made in the format prescribed in as set out herein below in this Code.

g) In case a contra trade is executed, inadvertently or otherwise, in violation of such a restriction, the profits from such trade shall be liable to be disgorged for remittance to SEBI for credit to the Investor Protection and Education Fund administered by SEBI under the Securities and Exchange Board of India Act, 1992.

6. Dealing in case of suspected leak or leak of Unpublished Price Sensitive Information

(a) Inquiry for Leakage of Unpublished Price Sensitive Information

All Unpublished Price Sensitive Information shall be handled on a need to know basis only. In case of any Unpublished Price Sensitive Information is proposed to be provided, the person proposing to provide the information shall consult the Chief Financial Officer / Compliance Officer/ Chairman and Managing Director in advance.

In case any Unpublished Price Sensitive Information is leaked or is suspected to be leaked by any insider, the Compliance Officer/Chief Financial Officer will investigate the matter and collect / gather the evidences and will report to the Chairman of Audit Committee. The

Ramsons Projects Limited

Chairman of the Audit Committee will thereafter convene a meeting of Audit Committee depending on severity of the matter.

(b) Process for inquiry

All the matters concerning leak of Unpublished Price Sensitive Information or suspected leak of Unpublished Price Sensitive Information, will be thoroughly investigated by the Compliance Officer / Chief Financial Officer or any other person authorized by the Board. The Compliance Officer / Chief Financial Officer may at their discretion, consider involving external investigators for the purpose of the investigation.

The Compliance Officer / Chief Financial Officer may ask the concerned insider to remain present for investigation, discussion etc. and for such investigation task team may ask for personal bank account statement or such other details or documents as it deems fit.

(c) Report to Audit Committee for appropriate action:

The Compliance Officer / Chief Financial Officer or any other person authorized by the Board will report to the Chairman of the Audit Committee and upon receipt of report by the Chairman, he will convene meeting of the Audit Committee, depending on severity of the matter. The Audit Committee will, based on such report, decide the suitable action including but not limited to withholding of salary / termination of employment / monetary penalty.

7. Reporting Requirements

a) Every person on appointment as a key managerial personnel or a director of the company or upon becoming a promoter or member of the promoter group shall disclose his / her holding of securities of the Company as on the date of appointment or becoming a promoter, to the Company within seven days of such appointment or becoming a promoter.

b) Every promoter, member of the promoter group, Designated Person and /or Immediate Relative and director of the Company shall disclose to the Company, the number of such Securities acquired or disposed of within two Trading Days of such transaction if the value of the Securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of Rs.10,00,000 (Rupees Ten Lakh) or such other value as may be specified.

c) Every Designated Person shall disclose mandatory details viz, Permanent Account Number, details of DEMAT accounts, names of educational institutions from which they have graduated and names of their past employers.

d) Every Designated Person shall mandatorily disclose Name, Permanent Account Number or any other identifier authorized by law and Phone/ Mobile numbers of himself and the following persons to the Company:

(i) Immediate relatives

(ii) persons with whom such Designated Person(s) shares a material financial relationship

Note: “Material Financial Relationship” shall mean a relationship in which one person is a recipient of any kind of payment such as by way of a loan or gift from a Designated Person during the immediately preceding twelve months, equivalent to at least 25% of the annual income of such Designated Person but shall exclude relationships in which the payment is based on arm’s length transactions.

Ramsons Projects Limited

e) The Compliance Officer or the Company may, at its discretion require any other Connected Person or class of Connected Persons to make disclosures of his/its/their holdings and trading the Securities of the Company in the format specified in as set out herein below in this Code, at such frequency as may be determined by the Compliance Officer in order to monitor compliance with the SEBI PIT Regulations.

f) The disclosures of Trading in Securities shall also include trading in derivatives of Securities and the traded value of the derivatives shall be taken into account for purposes of disclosure. Provided that trading in derivatives of Securities is permitted by any law for the time being in force.

g) All submissions envisaged in this Code should be addressed to the Compliance Officer and forwarded to the Secretarial Department of the Company at its registered office, for administrative purpose and taking appropriate action.

8. Maintenance of Structured Digital Database

a) The Board or the Compliance officer or any other person authorized by the Board shall maintain a structured digital database containing the nature of Unpublished Price Sensitive Information and the names of such persons or entities as the case may be who have shared the information and also the names of such persons with whom information is shared along with the Permanent Account Number or any other identifier authorized by law where Permanent Account Number is not available. Every Designated Person or his/her Immediate Relative who is in receipt Unpublished Price Sensitive Information or who shares Unpublished Price Sensitive Information regarding the Company or its Securities for any other purpose as provided in this Code and/or the SEBI PIT Regulations, are required to provide the details including, their name, Permanent Account Number, nature of Unpublished Price Sensitive Information and other details as may be required to maintain the Company’s digital database under the SEBI PIT Regulations.

b) The said digital database shall be maintained with adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering of the database. The Board or the Compliance officer or any other person authorized by the Board shall ensure that the structured digital database is preserved for a period of not less than eight years after completion of the relevant transactions and in the event of receipt of any information from the Board regarding any investigation or enforcement proceedings, the relevant information in the structured digital database shall be preserved till the completion of such proceedings.

9. Rules regarding Informants

a) Any individual may voluntarily inform the SEBI and nothing in this Code precludes any person from submitting to the SEBI information regarding an alleged violation of insider trading laws (as defined under the SEBI PIT Regulations) that has occurred, is occurring or has a reasonable belief that it is about to occur, in the manner prescribed under the SEBI PIT Regulations. Such an individual is an “Informant”.

b) An Informant is entitled to be protected from retaliation and victimization and any retaliation or victimization is strictly prohibited under this Code and the Company’s whistle blower policy. Complete protection shall be given to an Informant against any “unfair treatment” by virtue of: (a) his/her having reported Original Information (as

Ramsons Projects Limited

defined under the SEBI PIT Regulations) by filing a Voluntary Information Disclosure Form (as defined under the SEBI PIT Regulations) under the SEBI PIT Regulations; (b) testifying in, participating in or otherwise assisting the SEBI in any investigation, inquiry, audit, examination of proceeding instituted or about to be instituted for an alleged violation of insider trading laws; or (c) breaching any confidentiality agreement or any terms and conditions of employment or engagement, solely to prevent any employee from cooperating with the SEBI in any manner. "Unfair treatment" includes, but is not limited to, discharge, termination, demotion, suspension, threats, harassment, discrimination (directly or indirectly) against an Informant.

c) No one should compel the disclosure of the identity and/or existence of an Informant or the information provided by the Informant, except to the extent required under the SEBI PIT Regulations and other applicable laws. The Informant shall not be required to notify the filing of any Voluntary Information Disclosure Form to the Company or seek prior permission or consent or guidance of any person engaged by the Company before or after such filing.

Informants are not exempt from the consequences of their own misconduct, unethical or improper practice, inadequate performance or other disciplinary issues unrelated to a disclosure made under Chapter IIIA of the SEBI PIT Regulations.

10. Penalty for Contravention

Any person who Trades in Securities or communicates, provides or allows access to any Unpublished Price Sensitive Information for Trading in Securities in contravention of this Code, shall be penalized and appropriate action shall be taken against him/her by the Company. He/she shall also be subject to disciplinary action as deemed appropriate by the Board of Directors, which may include termination of services, suspension, wage freeze, withholding of promotions, termination of employment, recovery of money, clawback of money etc. or other such action as the Board of Directors may deem fit. However, an employee shall not be discharged, terminated, demoted, suspended, threatened, harassed, directly or indirectly or discriminated if he has filed a Voluntary Information Disclosure Form, irrespective of whether the information is considered or rejected by the SEBI or he is eligible for a reward under SEBI PIT Regulations.

If it is observed by the Company that there has been violation of SEBI PIT Regulations, it shall inform Stock Exchanges on which the Securities are listed in accordance with the process ascribed by SEBI in this behalf, if any.

In addition to the action which may be taken by the Company, the persons violating the SEBI PIT Regulations or the Code shall also be subject to action under the Securities and Exchange Board of India Act, 1992 and other applicable laws.

11. Interpretation

Any ambiguities, difficulties and interpretative issues regarding this Code shall be resolved by the Board of Directors of the Company in line with the intent of this Code read with the applicable provisions of the Securities and Exchange Board of India Act, 1992 and the rules and regulations made thereunder, including the SEBI PIT Regulations.

In any circumstance where the terms of this Code differ from any existing or newly enacted law, rule, regulation or standard governing the Company, the law, rule, regulation or standard

Ramsons Projects Limited

will take precedence over this Code and procedures until such time as this Code is amended to conform to the law, rule, regulation or standard.

In the event of any conflict between the provisions of this Code and the Securities and Exchange Board of India Act, 1992 or the SEBI PIT Regulations or any other cognate statutory enactments or rules then the provisions of the Securities and Exchange Board of India Act, 1992 or the SEBI PIT Regulations or such other cognate statutory enactments or rules made thereunder shall prevail over to this Code and the part(s) so repugnant shall be deemed to severed from this Code and the rest of the Code shall remain in force.

12. Amendments

The decision of the Board of Directors with regard to any or all matters relating to the Code shall be final and binding on all concerned. The Board of Directors shall have the power to modify, amend and replace the Code in part or full, as may be thought fit from time to time in their absolute discretion.

THIS POLICY IS ONLY INTERNAL CODE OF CONDUCT AND ONE OF THE MEASURES TO AVOID INSIDER TRADING. IT WILL BE THE RESPONSIBILITY OF EACH PERSON TO ENSURE COMPLIANCE OF SEBI REGULATIONS AND OTHER RELATED STATUTES FULLY

Ramsons Projects Limited

FORM B

SEBI (Prohibition of Insider Trading) Regulations, 2015

[Regulation 7 (1) (b) read with Regulation 6(2) – Disclosure on becoming a

Key Managerial Personnel/ Director/ Promoter/ Member of the promoter group

Name of the company:

ISIN of the company:

Details of Securities held on appointment of Key Managerial Personnel (KMP) or Director or upon becoming a Promoter or member of promoter group of the Company and immediate relative of such persons and other such persons as mentioned in Regulation 6(2).

Name, PAN, CIN/DIN & Address with contact nos.	Category of Person (Promoters/Promoter group/KMP / Directors/immediate relative to/others etc.)	Date of appointment of Director /KMP OR Date of becoming Promoter or member of promoter group	Securities held at the time of appointment of KMP/ Director or upon becoming Promoter or member of the promoter group		% of Shareholding
			Type of security (For eg. – Shares, Warrants, Convertible Debentures Rights, entitlements etc.)	No.
1	2	3	4	5	6

Note: "Securities" shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015.

Details of Open Interest (OI) in derivatives on the securities of the company held on appointment of Key Managerial Personnel (KMP) or Director or upon becoming a Promoter/member of the promoter group of the Company and other such persons as mentioned in Regulation 6(2).

Open Interest of the Future contracts held at the time of becoming Promoter/member of the promoter group/appointment of Director/KMP			Open Interest of the Option Contracts held at the time of becoming Promoter/member of the promoter group/appointment of Director/KMP
Contract Specifications	Number of units (contracts * lot size)	Notional value in Rupee terms	Contract Specifications	Number of units (contracts * lot size)	Notional value in Rupee terms
7	8	9	10	11	12

Note: In case of Options, notional value shall be calculated based on premium plus strike price of options

Name & Signature:

Designation:

Date:

Place:

Ramsons Projects Limited

FORM C

SEBI (Prohibition of Insider Trading) Regulations, 2015

[Regulation 7 (2) read with Regulation 6(2) – Continual disclosure]

Name of the company: _______

ISIN of the company: _______

Details of change in holding of Securities of Promoter, member of the promoter group, Designated Person or Director of the Company and immediate relatives of such persons and other such persons as mentioned in Regulation 6(2).

| Name
PAN, CIN/DIN, &
address with contact nos. | Category of Person
(Promoter members of the promoter group/designated person/Director/immediate relative to others etc. | Securities held prior to acquisition/disposal | | Securities acquired/Disposed | | | | Securities held post acquisition/disposal | | Date of allotment advice/acquisition of shares/sale of shares specify | | Date of intimation to company | Mode of acquisition/disposal (on market/public/rights/preferential offer / off market/Inter-se transfer, ESOPstc.) | Exchange on which the trade was executed |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | Type of security (For eg. – Shares, Warrants, Convertible Debentures, Rights entitlements etc.) | No. and % of shareholding | Type of security (For eg. – Shares, Warrants, Convertible Debentures, Rights entitlements etc.) | No. | Value | Transaction Type (Purchase/Sale/Pledge/Revocation/Insscation/Others please specify | Type of security (For eg. – Shares, Warrants, Convertible Debentures, Rights entitlements etc.) | No. and % of shareholding | From | To | | | |
| 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 | 10 | 11 | 12 | 13 | 14 | 15 |

Note: (i) “Securities” shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015.
(ii) Value of transaction excludes taxes/brokerage/any other charges

Details of trading in derivatives on the securities of the company by Promoter, member of the promoter group, Employee or Director of a listed company and other such persons as mentioned in Regulation 6(2).

Trading in derivatives (Specify type of contract, Futures or Options etc.)						Exchange on which the trade was executed
Type of Contract	Contract Specifications	Buy		Sell
		Notional Value	Number of units (contracts * lot size)	Notional Value	Number of units (contracts * lot size)
16	17	18	19	20	21	22

Note: In case of Options, notional value shall be calculated based on Premium plus strike price of options.

Name & Signature: _______

Designation: _______

Date: _______

Place: _______

Ramsons Projects Limited

FORM D (Indicative format)

SEBI (Prohibition of Insider Trading) Regulations, 2015

Regulation 7(3) – Transactions by Other Connected Persons as identified by the Company

Details of trading in Securities by other Connected Persons as identified by the Company

Name, PAN, CIN/DIN, & address with contact nos. of other connected persons as identified by the company	Connect ion with company	Securities held prior to acquisition/disposal		Securities acquired/Disposed				Securities held post acquisition/disposal		Date of allotment advice/acquisition of shares/sale of shares specify		Date of intimation to company	Mode of acquisition/disposal (on market/public rights/Preferential offer/off market/Interse transfer, ESOPs etc.)	Exchange on which the trade was executed
		Type of security (For eg. - Shares, Warrants, Convertible Debentures Rights entitlement, etc.)	No. and % of shareholding	Type of security (For eg. - Shares, Warrants, Convertible Debentures Rights entitlement, etc.)	No.	Value	Transaction Type (Buy/Sale/Pledge Revocation / Invocation/ Others -please specify)	Type of securities (For eg. - Shares, Warrants, Convertible Debentures, Rights entitlement, etc.)	No. and % of Shareholding	From	To
1	2	3	4	5	6	7	8	9	10	11	12	13	14	15

Note: ) (i) "Securities" shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015.
(ii) Value of transaction excludes taxes/brokerage/any other charges

Details of trading in derivatives by other Connected Persons as identified by the Company

Trading in derivatives (Specify type of contract, Futures or Options etc)
Type of Contract	Contract specifications	Buy		Sell
		Notional Value	Number of units (contracts * lot size)	Notional Value	Number of units (contracts * lot size)
16	17	18	19	20	21	22

Note: In case of Options, notional value shall be calculated based on premium plus strike price of options.

Name & Signature:

Designation:

Date:

Place:

Ramsons Projects Limited

Form E

(Application and Undertaking for pre-clearance of trade by Designated Person(s) and their immediate relative under Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons applicable to dealing in securities of Ramsons Projects Limited exceeding 5,000 in number or Rs.10,00,000/- in value, whichever is lower during a calendar quarter)

From

Mr./Mrs.

Address

*Designation

*Employee Code

*(applicable to employees only)

Date:

The Compliance Officer,

Ramsons Projects Limited

New Delhi

Dear Sir,

Sub: Pre-clearance of Trades

I/My immediate relative Mr./Ms ... intend to deal in equity shares of the company for which I/ on behalf of my immediate relative request pre-clearance of the trade.

The particulars of intended trade are as under:

Sr. No.	Details of the proposed Trade	Information provided by Declarant
1	Number of shares proposed to be traded
2	Proposed date of trading in securities
3	Current market price (as on date of application)
4	Demat A/c details	DP I.D. Client I.D.
5	Nature of Trade	* Purchase of securities Subscription to securities Sale of securities Pledge of securities Any other form of dealing in securities
6	The Depository for this Trade	*NSDL / CDSL
7	The trade is proposed to be carried out by	Myself / My immediate relative
8	My/ My immediate relative’s current holding

My undertaking for the purpose of pre-clearance is furnished herein below. This is to request you to pre-clear the proposed trade.

Ramsons Projects Limited

I/My immediate relative is aware that I/we have to execute the order in respect of securities of the company within seven Trading Days (as defined in the Code) after the approval of pre-clearance is given.

If the order is not executed within seven Trading Days after the approval is given, I/We would have to apply for pre-clearance of the transaction again.

Thanking You

(Signature)

*(Delete whatever is not applicable)

Undertaking

*I on my own behalf/ on behalf of immediate relative (we) do hereby solemnly state as under

That I/We do not have any access nor have we received “Unpublished Price Sensitive Information” up to the time of signing this undertaking.

That in case I/We get access to or receive “Unpublished Price Sensitive Information” after the signing of this undertaking but before the execution of the transaction I/We shall inform the Compliance Officer of the change in my/our position and that I/We would completely refrain from dealing in the securities of the Company till the time such information becomes public.

That I/We have not contravened the Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons as notified by the company from time to time.

I/ we undertake to submit the necessary report within two days of execution of the transaction / a ‘Nil’ report if the transaction is not undertaken within the stipulated period following receipt of pre-clearance.

That I/We have made a full and true disclosure in the matter.

Given under my hand this ………… day of ……………

(Signature)

*(Delete whatever is not applicable)

Note: This form to be filed for self and immediate relative, separately.

Ramsons Projects Limited

Form F

(Application and Undertaking for pre-clearance of trade by Compliance Officer and his/her immediate relative under Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons applicable to dealing in securities of Ramsons Projects Limited exceeding 5,000 in number or Rs.10,00,000/- in value, whichever is lower during a calendar quarter)

From

Mr./Mrs.

Address

*Designation

*Employee Code

*(applicable to employees only)

Date:

The Managing Director,

Ramsons Projects Limited

New Delhi

Dear Sir,

Sub: Pre-clearance of Trades

I/My immediate relative Mr./Ms... intend to deal in equity shares of the company for which I/ on behalf of my immediate relative request pre-clearance of the trade.

The particulars of intended trade are as under:

Sr. No.	Details of the proposed Trade	Information provided by Declarant
1	Number of shares proposed to be traded
2	Demat A/c details	DP I.D. Client I.D.
3	Nature of Trade	*Buy / Sale
4	The Depository for this Trade	*NSDL / CDSL
5	The trade is proposed to be carried out by	Myself / My immediate relative
6	My/ My immediate relative’s current holding

My undertaking for the purpose of pre-clearance is furnished herein below. This is to request you to pre-clear the proposed trade.

I/My immediate relative is aware that I/we have to execute the order in respect of securities of the company within one week after the approval of pre-clearance is given.

If the order is not executed within one week after the approval is given. I/We would have to pre-clear the transaction again.

Thanking You

(Signature)

*(Delete whatever is not applicable)

Ramsons Projects Limited

Undertaking

*I on my own behalf/ on behalf of immediate relative (we) do hereby solemnly state as under

That I/We do not have any access nor have we receive “Unpublished Price Sensitive Information” up to the time of signing this undertaking.

That in case I/We get access to or receives “Unpublished Price Sensitive Information” after the signing of this undertaking but before the execution of the transaction I/We shall inform the Compliance Officer of the change in my/our position and that I/We would completely refrain from dealing in the securities of the company till the time such information becomes public.

That I/We have not contravened the code of conduct for prevention of insider trading as notified by the company from time to time.

That I/We have made a full and true disclosure in the matter.

Given under my hand this ………… day of ………………

(Signature)

*(Delete whatever is not applicable)

Note: This form to be filed for self and dependent family member, separately.

Ramsons Projects Limited

FORM G

Annual Disclosure of Securities held by Promoter, Key Managerial Personnel, Director and Designated Persons and Immediate Relatives

Date:

To,

The Company Secretary & Compliance Officer

Sub: Disclosure of Trading in Securities of Ramsons Projects Limited during the year ended ______ and holding of securities of the Company as on that date.

Dear Sir,

Pursuant to Company’s Code of Conduct to Regulate, Monitor and Report Trading by Designated Persons (“Code”), I hereby disclose trading in securities of the Company during the year ended and holding as on that date.

Disclosure of Securities by Director and Designated Persons
Type of Securities	Number of securities held as on ______	Number of securities bought during the year ______	Number of securities sold during the year ______	Number of securities held as on ______	DP. ID & Client ID
Equity

Details of my immediate relatives are as under. “immediate relative” means a spouse of a person, and includes parent, sibling, and child of such person or of the spouse, any of whom is either dependent financially on such person, or consults such person in taking decisions relating to trading in securities.

Sr. No.	Name of Relative	PAN	DP ID & Client ID


Disclosure of Securities by Immediate Relative of Director and Designated Persons
---	---	---	---
Name(s) of Immediate Relatives	Type of Securities	Number of securities held as on ______	Number of securities Bought during The year ______
	Equity

I hereby declare that the above details are complete and correct. I further declare that I have complied with the provisions of Code. I am fully aware about consequences in case of any non-compliance by me and shall be responsible for any action/inaction.

Full Name:

Designation:

Department:

Signature:

Mobile No.:

Emp. Code or DIN:

Ramsons Projects Limited

PART-B

CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION

To adhere the principles as mentioned in Schedule A to the SEBI PIT Regulations, ensure timely and adequate disclosure of unpublished price sensitive information, following norms shall be followed by the Company:

The Company shall promptly make public disclosure of Unpublished Price Sensitive Information that would impact price discovery. Such disclosure are made no sooner than credible and concrete information comes into being in order to make such information generally available.
In order to avoid misquoting or misrepresentation, it is desirable that at least two Company representatives be present at meetings with analysts, brokers or institutional investors and discussion should preferably be recorded.
The Company shall disseminate the Unpublished Price Sensitive Information, as and when disclosed, in a universal and uniform manner, through forums like widely circulated media and/or through stock exchanges where its Securities are listed. Selective disclosure of Unpublished Price Sensitive Information is to be avoided. As an exception to the general rule, the Unpublished Price Sensitive Information can be shared by an Insider for "legitimate purposes", as determined in accordance with the provisions of Annexure A hereto.
The Compliance Officer or any other person as may be appointed by the Board as Chief Investor Relations Officer shall deal with the dissemination of information and disclosures of Unpublished Price Sensitive Information.
The Chief Investor Relations Officer shall be responsible for ensuring that the Company complies with disclosure requirements, overseeing and co-ordinating disclosure of Unpublished Price Sensitive Information to stock exchanges, analysts, shareholders and media, and educating staff on disclosure policies and procedure.
Information disclosure/dissemination may normally be governed in advance by official designated for the purpose. If information is accidentally disclosed without prior approval, the person responsible may inform the designated officer immediately, even if information is not considered as unpublished price sensitive.
The Company shall promptly disseminate the Unpublished Price Sensitive Information that gets disclosed selectively, inadvertently or otherwise if at all, to make such information generally available.
The Company shall provide appropriate and fair response to queries on news reports and requests for verification of market rumours by regulatory authorities.
The Company shall ensure that information shared with analysts and research personnel is not Unpublished Price Sensitive Information.

Ramsons Projects Limited

The Company shall publish proceedings of meetings with analysts and of other investor relations conferences hosted or organised by the Company on its official websites at https://ramsonsprojects.com/ to ensure official confirmation and documentation of disclosures made therein.
The Company should be careful when dealing with analysts questions that raise issue outside the intended scope of discussion. Unanticipated questions may be taken on notice and a considered response given later. If the answer includes price sensitive information, a public announcement should be made before responding.
All Unpublished Price Sensitive Information shall be handled on a need-to-know basis only, i.e. in furtherance of performance of duties or discharge of legal obligations or for other legitimate purposes.

Ramsons Projects Limited

Annexure A

Legitimate Purposes: For the purposes of this policy, “legitimate purposes” may include:

a. Sharing of Unpublished Price Sensitive Information, by an Insider, in the ordinary course of business, with any person, provided that such sharing has not been carried out to evade or circumvent the prohibitions of the Regulations.

b. Without prejudice to the provisions of sub-para (a) above, “legitimate purposes” for which Unpublished Price Sensitive Information can be shared by an Insider, shall include the following:

Sharing the relevant Unpublished Price Sensitive Information with any person, for advice, consultation, valuation, fund raising or other intermediation and approvals, in relation to the subject matter of a proposed deal/assignment/ tie-up/venture/investment/fund raising, resulting into Unpublished Price Sensitive Information itself or otherwise;
Sharing the relevant Unpublished Price Sensitive Information with intermediaries, fiduciaries, merchant bankers, advisors, lawyers, bankers, consultants, valuers, rating agencies, accountants, auditors, insolvency professionals, business support agents, IT tools/system providers/facilitators, transaction processing service providers, in order to avail professional services from them in relation to the subject matter of Unpublished Price Sensitive Information;
Sharing of relevant information with regulators (including any judicial or quasi-judicial body or any governmental authority as a part of litigation or regulatory proceedings);
Sharing the relevant Unpublished Price Sensitive Information for advice, consultation, transaction support, intermediation and approvals on projects relating to enterprise transformation, strategy, change management, analytics, re-organization, operation, improvement, technology and similar domains;
Sharing the relevant Unpublished Price Sensitive Information with business partners and other counter parties, which is essential and necessary to fulfil the terms and conditions of the relevant business arrangement with such partner, counter party, which may include a client, vendor, collaborator or a lender or financier;
Sharing the relevant Unpublished Price Sensitive Information for advice, consultation, transaction support, intermediation and approvals in the process of evaluation of new products or services, business opportunities and new lines of business;
Sharing the relevant Unpublished Price Sensitive Information for statutory consolidation requirements or disclosure obligations;
Sharing the relevant Unpublished Price Sensitive Information for performance monitoring and oversight duties of relevant decision makers;

Ramsons Projects Limited

Sharing the relevant Unpublished Price Sensitive Information with persons engaged or involved in the processes leading to disclosure of events set out in Schedule III to SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015;
Sharing the relevant Unpublished Price Sensitive Information, in case necessary for performance of duties or discharge of legal obligations.

Ramsons Projects Limited

AI assistant

Ramsons Projects Ltd. — Earnings Release 2026

61802_rns_2026-05-19_fe941edd-2402-4ec1-8420-b3b4aa5dac4b.pdf

3. Revision of Insider Trading Codes

4. Place of Maintenance of Books and Registers

INDEPENDENT AUDITOR'S REPORT ON STANDALONE ANNUAL FINANCIAL RESULTS

Opinion

Basis for Opinion

Responsibilities of Management and Those Charged with Governance for the Statement

Auditor's Responsibilities for the Audit of the Statement

Other Matter

RAMSONS PROJECTS LIMITED

RAMSONS PROJECTS LIMITED

RAMSONS PROJECTS LIMITED

Ramsons Projects Limited

Notes to the Audited Financial Results for Q4 & FY ended March 31, 2026

RAMSONS PROJECTS LIMITED

CODE OF CONDUCT TO REGULATE, MONITOR AND REPORT TRADING BY DESIGNATED PERSONS

CODE OF PRACTICE AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION

1. Preamble

Definitions:

Note

"Legitimate Purpose":

"Trading Plans":

PART – A

CODE OF CONDUCT TO REGULATE, MONITOR AND REPORT TRADING BY

DESIGNATED PERSON

1. Roles and Responsibilities of the Compliance Officer

2. Restrictions on communication or procurement of unpublished price sensitive information

3. INSTITUTIONAL MECHANISM FOR PREVENTION OF INSIDER TRADING:

4. Preservation of unpublished price sensitive information

5. Prevention of misuse of Unpublished Price Sensitive Information

A. Trading Plans

Non-Implementation of the trading plan

B. Trading Window

C. Pre-clearance of Trade

6. Dealing in case of suspected leak or leak of Unpublished Price Sensitive Information

(a) Inquiry for Leakage of Unpublished Price Sensitive Information

(b) Process for inquiry

(c) Report to Audit Committee for appropriate action:

7. Reporting Requirements

8. Maintenance of Structured Digital Database

9. Rules regarding Informants

10. Penalty for Contravention

11. Interpretation

12. Amendments

FORM B

FORM C

SEBI (Prohibition of Insider Trading) Regulations, 2015

[Regulation 7 (2) read with Regulation 6(2) – Continual disclosure]

FORM D (Indicative format)

Form E

Sub: Pre-clearance of Trades

Undertaking

Form F

Sub: Pre-clearance of Trades

Undertaking

FORM G

Annual Disclosure of Securities held by Promoter, Key Managerial Personnel, Director and Designated Persons and Immediate Relatives

PART-B

CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF UNPUBLISHED PRICE SENSITIVE INFORMATION

Annexure A

More from Ramsons Projects Ltd.

Ramsons Projects Ltd. Earnings Release 2026