Date: 06-08-2025 To, BSE Limited, 20th Floor, P.J.

Towers, Dalal Street, Mumbai - 400001. BSE Scrip Code: 544452 Subject: Intimation under Regulation 8(2) of the Securities Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Dear Sir, Pursuant to Regulation 8(2) of the Securities Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (‘SEBI PIT Regulations’), please find attached herewith the Code of Fair Disclosure of Unpublished Price Sensitive Information framed under Regulation 8 (1) of SEBI PIT Regulations.

We request you to kindly take the above on record.

Your faithfully, For SWASTIKA CASTAL LTD. Varun Sharda Managing Director DIN: 01571483 ----------------Page (0) Break---------------- CODE OF CONDUCT FOR REGULATING, MONITORING & REPORTING OF TRADES AND PREVENTION OF INSIDER TRADING Pursuant to Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended.

1. INTRODUCTION The Securities and Exchange Board of India (“SEBI”) has notified the SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended (“PIT Regulations”), which governs the law relating to insider trading of listed entities in India.

Regulation 9 of the PIT Regulations requires, inter alia, the board of directors of every listed company to ensure that the chief executive officer or managing director shall formulate a code of conduct, with their approval, to regulate, monitor and report trading by its designated persons and immediate relatives of designated persons towards achieving compliance with these regulations and enforce a code of internal procedures and conduct based on the Model Code in accordance with the PIT Regulations.

Further, Regulation 7 of the PIT Regulations requires every Connected Persons including promoter, member of the promoter group, key managerial personnel, directors and employee of listed companies to disclose their shareholdings and changes to such shareholding to the respective companies.

In compliance with the above requirements, the Company has introduced a code for prohibition of Insider Trading (hereinafter referred to as the “Code”). 2. OBJECTIVE Swastika Castal Limited (hereinafter referred to as the “Company”) endeavors to preserve the confidentiality of Unpublished Price Sensitive Information (“UPSI”) and to prevent misuse of such information.

The Company is committed to transparency and fairness in dealing with all stakeholders and in ensuring adherence to all laws and regulations.

Every designated person of the Company has a duty to safeguard the confidentiality of all such information obtained in the course of his or her work at the Company.

No designated person shall use his or her position or knowledge of the Company to derive personal benefit or to provide or cause to provide benefit to any third party.

Further, the PIT Regulations state that unless required, sharing of information by designated persons of the Company, even when the same is not misused shall be considered a violation unless required.

Thus, information needs to be shared only on a need-to-know basis and such persons are prohibited from communicating / or counselling others with respect to the securities of the Company.

Such persons should also refrain from profiteering by misusing the UPSI and thereby enabling the Company to retain investor confidence.

Any subsequent modification and / or amendments to the Regulations shall automatically apply to this Code.

The objective of this Code is to lay down guidance for designated persons on the policy, preclearance/disclosure procedures to be followed at the time of trading in the Securities of the Company.

The Board at its meeting held on 20th December 2024 had approved this Code of Conduct to regulate, monitor and report trading in securities and handling of UPSI.

The effective date of this Code shall be the date of listing of Company’s equity shares on Stock exchanges. ----------------Page (1) Break---------------- 3. DEFINITION OF TERMS 3.1 “Act” means the Securities and Exchange Board of India Act, 1992 as amended from time to time.

3.2 “Audit Committee” means the audit committee constituted pursuant to Section 177 of the Companies Act, 2013 as amended and Regulation 18 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended.

3.3 “Board” or “Board of Directors” means the board of directors of the Company.

3.4 “Code” or “Code of Conduct” means this Code of Conduct to regulate, monitor and report trading by Insiders in securities of the Company as amended from time to time.

3.5 “Chief Investor Relations Officer” means a senior officer who has been designated as the chief investor relations officer to deal with dissemination of information and disclosure of unpublished price sensitive information.

3.6 “Company” means Swastika Castal Limited 3.7 “Compliance Officer” means the Company Secretary of the Company.

3.8 “Connected Person” means the persons so defined in Regulation 2(d) of the PIT Regulations.

3.9 “Generally Available” 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.

3.10 “Immediate Relative” shall have the meaning ascribed to it under Regulation 2(f) of the PIT Regulations.

3.11 “Insider” shall have the meaning ascribed to it under 2 (g) of the PIT Regulations.

Provided that any person in receipt of UPSI 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.

3.12 “Key Managerial Personnel” means person as defined in Section 2(51) of the Companies Act, 2013. 3.13 “PIT Regulations” means Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 as amended from time to time.

3.14 “Pre-Clearance of Trade” means prior approval for trading / dealing in the securities of the Company.

3.15 “Promoter” shall have the meaning assigned to it under the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018, as amended and any modifications thereof.

3.16 “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, as amended and any modifications thereof. ----------------Page (2) Break---------------- 3.17 “Securities” shall have the meaning assigned to it under Section 2(h) of the Securities Contracts Regulation Act, 1956 or any modification thereof except units of a mutual fund.

3.18 “Trading” means and includes subscribing, buying, selling, dealing or agreeing to subscribe, buy, sell, deal in securities and ‘trade’ shall be construed accordingly, and shall be construed to include pledging when in possession of UPSI.

3.19 “Trading Day” means a day on which recognized stock exchanges are open for trading.

3.20 Unpublished Price Sensitive Information / UPSI” shall have the meaning ascribed to it under Regulation 2(n) of the PIT Regulations 3.21 “Trading Window” refers to the period during which the Company’s securities can be traded by the Designated Person as provided in this Code.

Words and expressions used and not defined in this Code but defined in SEBI Act, 1992, the SCRA Act, 1956, the Depositories Act, 1996, SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 or Companies Act, 2013 and Rules and Regulations thereunder shall have the meanings respectively assigned to them in those legislations.

4. APPLICABILITY OF THE CODE The Code is applicable to Insiders including Connected Persons and Designated Persons, i.e.: a) Promoters and Promoter Group of the Company; b) Directors of the Company; c) Key Managerial Personnel (“KMP”) of the Company; d) The office of Chief Executive Officer(s) and employees upto two levels below Chief Executive Officer e) All employees of secretarial team, corporate finance, accounts and tax team, IT, marketing, sales team, human resources and corporate communication; f) Any other employee of the Company which in the opinion of the Compliance Officer of the Company needs to be included in the category of Designated Employee.

Such inclusion shall be done after approval of the Chief Financial Officer/Chief Executive Officer/Whole-Time Director/Managing Director of the Company; g) Immediate Relatives of these persons listed under (a) to (f) For the purpose of this Code, the declaration given by a Designated Person of an Immediate Relative who is either dependent financially on the person or who consults such person in taking decisions relating to trading in securities will be considered.

5. COMPLIANCE OFFICER 5.1. The Board of Directors of the Company has appointed Company Secretary, as Compliance Officer for the purposes of this Code.

5.2. The Compliance Officer shall be responsible for setting forth procedures, monitoring adherence to the rules for the preservation of ‘UPSI’, policies, procedures, maintenance of records, pre- clearing of Designated Persons, monitoring of trades and the implementation of the Code of Conduct under the overall supervision of the Board of Directors. ----------------Page (3) Break---------------- 5.3. The Compliance Officer shall maintain a record of the Designated Person and any changes therein along with the declarations submitted in the appropriate form given by the Designated Persons.

5.4. The Compliance Officer shall assist all the Designated Employees in addressing any clarifications regarding the PIT Regulations and the Company’s Code of Conduct.

5.5. Monitor and administer this Code.

5.6. Process the pre-clearance of trade as per approval matrix.

5.7. Maintain, update and preserve records, as per PIT Regulations.

5.8. Clarify issues regarding the Code and redress the grievances of the Designated Persons.

5.9. Decide and notify the ‘No-Trading Period’ for Designated Persons / select persons or specific departments, as deemed necessary.

5.10. Identify and notify the list of Designated Persons on the basis of specific transactions, as required under the Code.

5.11. Notify the trading plan to the stock exchanges where the securities are listed, on approval of the plan.

5.12. Compliance Officer shall provide reports to the Chairman of the Audit Committee or the Board of Directors (“Board”) at such frequency as decided by the Board, but not less than one year.

6. HUMAN RESOURCE DEPARTMENT The Head-Human Resources shall ensure the following: a) Obtain initial disclosures from Designated Persons; and b) Provide an updated list of Designated Persons to the Compliance Officer from time to time.

7. ROLE OF CHIEF INVESTOR RELATIONS OFFICER The Chief Investor Relations Officer/Compliance Officer shall deal with dissemination of information and disclosure of UPSI.

8. PROHIBITION ON DEALING, COMMUNICATING OR COUNSELLING ON MATTERS RELATING TO INSIDER TRADING.

No insider shall:- (i) either on his own behalf, or on behalf of any other person, deal in securities of the Company when in the possession of any UPSI; (ii) communicate, provide, or allow access to any unpublished price sensitive information, relating to a company or securities listed or proposed to be listed, to any person including other insiders except where such communication is in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

Explanation: the term “legitimate purpose” shall include sharing of UPSI 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 the PIT Regulations.

The policy on determination of “legitimate purposes” is annexed to this Policy as ‘Annexure A’. (iii) When a person who has traded in securities has been in possession of UPSI, his trades would be presumed to have been motivated by the knowledge and awareness of such information in his possession. ----------------Page (4) Break---------------- 9. PRESERVATION OF UNPUBLISHED PRICE SENSITIVE INFORMATION (‘UPSI’) Designated Persons shall maintain the confidentiality of all UPSI.

Designated Persons shall not pass on such information to any person directly or indirectly by way of making a recommendation for the purchase or sale of Securities.

Communication or procurement of UPSI: a. The Designated Employee shall maintain confidentiality of all UPSI and no Designated Employee shall communicate, provide, or allow access to any UPSI, relating to the Company or securities listed or proposed to be listed, to any person including other Designated Employees except where such communication is in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

Further the Designated Employee shall not pass on the UPSI to any person directly or indirectly whether to make a recommendation for the purchase or sale of securities of the Company or otherwise. b. No person shall procure from or cause the communication by any Designated Employee of UPSI, relating to the Company or securities listed or proposed to be listed except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations. c. No Designated Employee shall Trade in securities that are listed or proposed to be listed on a stock exchange when in possession of UPSI. d. Notwithstanding anything contained in the PIT Regulations, the UPSI may be communicated, provided, allowed access to or procured, in connection with a transaction that would: i. entail an obligation to make an open offer under the Takeover Regulations where the Board is of informed opinion that the proposed transaction is in the best interest of the Company; ii. not attract the obligation to make an open offer under the Takeover Regulations but where the Board is of informed opinion that the proposed transaction/sharing of such information is in the best interests of the Company and the information that constitute UPSI 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.. e. It is clarified that no communication of UPSI as contemplated under Clause 9(d) above shall occur unless the Board has passed a resolution authorizing such communication.

For purposes of Clause 9(d), the Board shall require the parties to 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 Clause 9(d) and shall not otherwise Trade in securities of the Company when in possession of UPSI.

Following practices should be followed in this regard: 9.1. Need to know UPSI is to be handled on a ‘need to know’ basis i.e., UPSI should be disclosed only to those within the Company who need the information to discharge their duty and whose possession of such information will not give rise to a conflict of interest or appearance of misuse of information. ----------------Page (5) Break---------------- 9.2. Limited access to confidential information Files containing confidential information shall be kept secure.

Computer files must have adequate security of login and password, etc. Files containing confidential information should be deleted / destroyed after its use.

Shredders should be used for the destruction of physical files.

Further, no Designated Person shall procure from or cause the communication by any Insider, of UPSI, relating to the Company or its Securities, either directly or indirectly except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations.

10. TRADING PLANS a) An Insider who may be/are perpetually in possession of UPSI is entitled to formulate a trading plan (“Trading Plan”), enabling him/her to trade in securities in a compliant manner, and present it to the Compliance Officer for approval and public disclosure pursuant to which trades may be carried out.

The Compliance Officer is required to review the trading plan to assess whether the plan potentially violates the PIT Regulations and to approve and monitor the implementation of the Trading Plan.

The Trading Plan approved by the Compliance Officer should be notified to the stock exchanges where the securities are listed. b) The Trading Plan shall: (i) Not entail commencement of trading on behalf of the Insider earlier than six months from the public disclosure of the plan; (ii) Not entail trading for the period between twentieth trading day prior to the last day of any financial period for which results are required to be announced, by the Company and the second trading day after the disclosure of such financial results; (iii) Entail trading for a period of not less than twelve months; (iv) Not entail overlap of any period for which another trading plan is already in existence; (v) Set out either the value of trades to be effected or the number of securities to be traded along with the nature of the trade and the intervals at, or dates on which such trades shall be effected; and (vi) Not entail trading in securities for market abuse. c) The Compliance Officer may seek express undertakings necessary for the assessment, approval and implementation of the trading plan. d) The Trading Plan once approved shall be irrevocable and the Designated Employee shall mandatorily have to implement the Trading Plan, without being entitled to either deviate from it or to execute any Trade in the securities outside the scope of the Trading Plan.

Such Designated Person who opts for trading plan route shall not be allowed to trade through the Pre-clearance Route during currency / pendency of a Trading Plan Provided that the implementation of the Trading Plan shall not be commenced if any UPSI is in possession of the Designated Employee at the time of formulation of the Trading Plan has not become Generally Available at the time of the commencement of implementation and in such event the Compliance Officer shall confirm that the commencement shall be deferred until such UPSI becomes Generally Available to the public so as to avoid a violation of Regulation 4(1) of the Regulations.

Further, the Designated Employee shall also not be allowed to Trade in securities of the Company, if the date of Trading in securities of the Company, as per the approved Trading Plan, coincides with the date of closure of Trading Window announced by the Compliance Officer. ----------------Page (6) Break---------------- 11. PREVENTION OF MISUSE OF UPSI All Designated Employees shall be subject to certain Trading restrictions as enumerated below: 11.1 Trading Window and Window Closure: a. The Company shall have a designated a Trading Window period being the period during which transactions in the securities of the Company can be effected by the Designated Employee (hereinafter referred to as ‘Trading Window’) for Trading in the Company’s securities; b. The Trading Window shall remain closed from the date mentioned in the notice given to the stock exchanges for convening the meeting of the Board to consider items of UPSI and shall be re-opened as per Clause 11.1(d) below; c. Designated Employees shall not Trade in the Company’s securities during the period when the Trading Window is closed and will have to forego the opportunity to Trade in the Company’s securities during such period; The timing for re-opening of the Trading Window shall be determined by the Compliance Officer taking into account various factors including the UPSI in question becoming Generally Available and being capable of assimilation by the market, which in any event shall not be earlier than forty-eight hours after the UPSI becomes Generally Available; and All Designated Employees and their immediate relatives shall conduct all their Trading in the securities of the Company only in a valid Trading Window and shall not Trade in the Company’s securities during the periods when Trading Window is closed or during any other period as may be specified by the Compliance Officer from time to time.

11.2 The Trading Window shall be closed when the Compliance Officer determines that a Designated Employee or class of Designated Employees can reasonably be expected to have possession of UPSI.

Such closure shall be imposed in relation to such securities to which such UPSI relates.

Designated Employees shall not Trade in securities when the Trading Window is closed.

12. TRADING RESTRICTIONS All Designated Persons shall conduct all their dealings in the securities of the Company only in a valid trading window after obtaining pre-clearance from the Compliance Officer and shall not enter into any transaction in the Company’s Securities during the ‘Close Period’. 13. PRE-CLEARANCE OF TRANSACTIONS a. All Designated Employees, who intend to Trade in the securities of the Company when the Trading Window is open whether in one transaction or a series of transactions over any calendar quarter, for an aggregated trade value in excess of ₹ 10,00,000/- (Rupees Ten Lakh), shall get the transactions pre- cleared.

Provided that pre-clearance of trades shall not be required for a trade executed as per an approved Trading Plan.

Provided further that trading window norms and restrictions on contra trade shall not be applicable for trades carried out in accordance with an approved trading plan ----------------Page (7) Break---------------- b. An application in the form attached hereto as Annexure I shall be made to the Compliance Officer by the Designated Employee indicating the estimated number of securities that such person intends to trade in, details of depository and such other information as may be prescribed by the Company.

The matrix for obtaining pre-clearance is as under: Dealing by Clearance by All Designated Employees except Compliance Officer Compliance Officer Compliance Officer Managing Director c. In case the Designated Person procures or comes in possession of UPSI before execution of the trade during the subsistence of the pre-clearance sought, he shall refrain from executing the trades. d. Before a Trade is executed, the Designated Employee shall execute an Undertaking in the form annexed hereto as Annexure II in favour of the Company. e. The Compliance Officer shall accord his approval within two Trading Days of the receipt of application for pre-clearance in the format attached hereto as Annexure III. f. All Designated Employees shall execute their Trades in respect of securities of the Company within seven Trading Days after the approval of pre-clearance is given.

The Designated Employee shall file within two Trading Days of the execution of the Trade, the details of such Trade with the Compliance Officer in the form attached as Annexure IV.

In case the transaction is not undertaken, a report to that effect shall be filed within two trading days of expiry of pre-clearance approval in the format attached as Annexure IV. g. If the Trade is not executed within seven Trading Days after the approval is given, the Designated Employee must obtain a fresh pre-clearance. h. All Designated Employees who buy or sell any number of securities of the Company shall not enter into any contra trade/opposite trade i.e., sell or buy any number of securities during the next six months following the prior transaction for purchase or sale of securities, as the case maybe.

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

This provision shall not be applicable for trades pursuant to the exercise of employee stock option.

Provided that this shall not be applicable to trades executed pursuant to exercise of stock options. i. The Compliance Officer may grant relaxation from strict application of such restriction in the Code above for reasons to be recorded in writing provided that such relaxation does not violate the PIT Regulations. j. All Designated Employees shall take pre-clearance from the Compliance Officer before creating, revoking or invoking lien/pledge on securities of the Company for such value as prescribed in this clause.

14. OTHER RESTRICTIONS / GENERAL PROVISIONS 14.1 The disclosure to be made by any person under this Code shall include those relating to Trading by such person’s Immediate Relatives, and by any other person for whom such person takes trading decisions. ----------------Page (8) Break---------------- 14.2 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 the purpose of this Code.

Provided that trading in derivatives of securities is permitted by any law for the time being in force.

14.3 All supporting documents for compliances made under this Code shall be maintained by the Company, for a minimum period of five years, in such a form as may be prescribed by the Compliance Officer or by the Board.

14.4 Trade in Securities of the Company directly or indirectly, either on his / her own behalf, or on behalf of any other person, when in possession of UPSI, except in compliance with the provisions of this Code and the PIT Regulations.

Provided that exercise of stock options under the Company’s Employee Stock Option Purchase Scheme (“ESOP”) shall not be considered as trading / purchase of the Securities of the Company except for disclosure requirements as stipulated under this Code.

14.5 The board of directors shall ensure that a structured digital database is maintained containing the names of such persons or entities as the case may be with whom information is shared under this regulation along with the Permanent Account Number (“PAN”) or any other identifier authorized by law where PAN is not available.

Such databases shall be maintained with adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering of the database.

14.6 The senior management shall have a process for how and when people are brought ‘inside’ on sensitive transactions.

Individuals will be made aware of the duties and responsibilities attached to the receipt of Inside Information, and the liability that attaches to misuse or unwarranted use of such information.

15. REPORTING REQUIREMENTS FOR TRANSACTIONS IN SECURITIES 15.1 Initial disclosures a. Every person on appointment as a Key Managerial Personnel or a Director 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 in the format attached as Annexure V. 15.2 Continual disclosures a. Every Promoter, member of the Promoter Group, Designated Person 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 ten lakh rupees or such other value as may be specified, in the format attached as Annexure VI. b. The Company shall notify the particulars of such Trading to the stock exchanges on which the securities are listed within two Trading Days of receipt of the continual disclosure or from becoming aware of such information. ----------------Page (9) Break---------------- Explanation – It is clarified for the avoidance of doubts that the disclosure of the Incremental transactions after any disclosure under this sub-regulation, shall be made when the transactions effected after the prior disclosure cross the threshold specified in clause (a) of sub-regulation (2). c. Off-market trades shall be reported by the insiders to the company within two working days.

Every company shall notify the particulars of such trades to the stock exchange on which the securities are listed within two trading days from receipt of the disclosure or from becoming aware of such information." 15.3 Designated Persons shall provide an annual confirmation as of 31st March, by 15th April of each year in the format attached as Annexure VII.

Audit Committee at its discretion may extend / waive the aforesaid period.

Designated persons shall be required to disclose names and PAN or any other identifier authorized by law of the following persons to the company on an annual basis and as and when the information changes: (a) immediate relatives (b) persons with whom such designated person(s) shares a material financial relationship (c) Phone, mobile and cell numbers which are used by them.

In addition, the names of educational institutions from which designated persons have graduated and names of their past employers shall also be disclosed on a one-time basis in the format attached as Annexure VIII.

Explanation–The term “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 during the immediately preceding twelve months, equivalent to at least 25% of such payer’s annual income but shall exclude relationships in which the payment is based on arm’s length transactions 15.4 All disclosures must be made in the prescribed formats and must be sent to the Compliance Officer at: Registered office of the company The original disclosures must be sent at the following address: Company Secretary and Compliance Officer Swastika Castal Limited Address : 306 Tower-A Mayfair Corporate park, Behind Delhi Public School Kalali, Kalali, Vadodara, Vadodara, Gujarat, India, 390012 16. PENALTY FOR CONTRAVENTION OF CODE OF CONDUCT a) Every Designated Employee shall be individually responsible for complying with the provisions of this Code (including to the extent the provisions hereof are applicable to his/her Immediate Relatives). b) Designated Persons who trade in Securities or communicates any information for trading in Securities in contravention of the Code may be penalized and appropriate action may be taken by the Company; c) Designated Employees who violate the Code shall also be subject to disciplinary actions including wage freeze, suspension, recovery, claw back, etc. that may be imposed, by the Board.

Any penalty amount collected under this clause shall be remitted to SEBI for credit to the Investor Protection and Education Fund administered by the Securities and Exchange Board of India under the SEBI Act. ----------------Page (10) Break---------------- d) The action by the Company shall not preclude SEBI from taking any action in case of violation of the Regulations.

17. INTIMATION TO AUDIT COMMITTEE / BOARD/ SEBI INCASE OF VIOLATION a) The Compliance Officer shall inform the chairman of the Audit Committee, or to the Chairman of the Board, cases of any violation of the PIT Regulations / Code so that appropriate action may be taken. b) The Company shall also intimate to SEBI any violation of the Regulations. c) The Compliance Officer shall report to the Board and in particular, shall provide reports to the Chairman of the Audit Committee, if any, or to the Chairman of the Board at such frequency as may be stipulated by the Board but not less than once in a year.

18. MISCELLANEOUS a) The Chief Financial Officer and the Compliance Officer are jointly authorised to amend the Code to give effect to any changes/amendments notified by the Ministry of Corporate Affairs or SEBI.

The amended policy shall be placed before the Board for noting and ratification. b) Any person, to whom this Code applies, and who has any doubt as to interpretation of any clause of the Code, should at all times consult the Compliance Officer.

All communications under this Code should be addressed to the Compliance Officer or to the designated e-mail: compliance@aluminiumcasting.net c) All connected persons as defined under the PIT regulations shall when in possession of UPSI not communicate, provide access to or trade in the securities of the company. d) The Compliance Officer may require any other Connected Person or class of Connected Persons, not being presently covered as a Designated Person under this Code, to disclose holding and trading in the Securities of the Company, as and when deemed necessary, to monitor compliance with this Code and PIT Regulations. e) The Compliance Officer shall be authorized to seek any such information / documents from the Connected Persons and/or their Immediate Relatives, as the case may be, for ensuring compliance with the PIT Regulations.

19. APPENDIX SEBI (Prohibition of Insider Trading) Regulations, 2015 (as amended) and requisite Forms are enclosed.

20. COMMUNICATION This Code (along with code of fair disclosure) will be uploaded on the website of the Company.

The Code will be disseminated to all Designated Persons who shall abide by the same.

The responsibility for complying with the provisions of the PIT Regulations shall vest with each Designated Person including any violation by their immediate relatives. ---xxxxx--- ----------------Page (11) Break---------------- ANNEXURE-I SPECIMEN OF APPLICATION FOR PRE-DEALING APPROVAL Date To, The Compliance Officer, Swastika Castal Limited [●] Dear Sir/Madam, Application for Pre-dealing approval in securities of the Company Pursuant to the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended and the Company’s Internal Code of Conduct for Regulating, Monitoring and Reporting of Trades by Insiders under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“Code”), I seek approval to Trade in securities of the Company as per details given below: 1. Name of the applicant 2. Designation 3. Nature of the securities and the number of securities held as on date 4. Application for 5. Relation with Employee 6. PAN 7. Folio No. / DP ID / Client ID No.) 8. The proposal is for i. Purchase of securities ii.

Subscription to securities iii.

Sale of securities 9. Proposed date of trading in securities 10. Estimated number of securities proposed to be acquired/subscribed/sold, etc. 11. Price at which the transaction is proposed 12. Current market price (as on date of application) 13. Whether the proposed transaction will be through stock exchange or off-market deal 14. Folio No. / DP ID / Client ID No. where the securities will be credited / debited I enclose herewith the undertaking signed by me as per the requirements of the Code.

All capitalized terms used herein but not defined shall have the same meaning as has been assigned to the terms in the Code.

Yours faithfully, Signature Name Designation Department ----------------Page (12) Break---------------- ANNEXURE II FORMAT OF UNDERTAKING TO BE ACCOMPANIED WITH THE APPLICATION FOR PRE-CLEARANCE UNDERTAKING Date To The Compliance Officer SWASTIKA CASTAL LIMITED [●] Pursuant to the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended and the Company’s Internal Code of Conduct for Regulating, Monitoring and Reporting of Trades by Insiders under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“Code”), I, , of the Company residing at , am desirous of Trading in securities of the Company as mentioned in my application dated for pre-clearance of the transaction.

I am issuing this undertaking pursuant to Clause 13 (f) of the Code.

I hereby confirm and undertake: a. that I do not possess any Unpublished Price Sensitive Information; b. not to pass on confidential information of the Company to any person directly or indirectly; c. to report to the Compliance Officer, any non-public information that may be received by me; d. that in case I have access to or receive ‘Unpublished Price Sensitive Information’ after the signing of this undertaking but before the execution of the Trade, I shall inform the Compliance Officer of the same and I shall completely refrain from Trading in the securities of the Company till such time the Unpublished Price Sensitive Information becomes public; e. that I have not contravened the Code as notified by the Company from time to time; f. all disclosures made by me in this letter are true and complete; and g. That I shall execute my Trade in respect of securities of Swastika Castal Limited within seven Trading Days after the pre‐clearance is given.

If the Trade is not executed within seven Trading Days after the approval is given, I shall obtain pre‐clearance for the Trade again.

All capitalized terms used herein but not defined shall have the same meaning as has been assigned to the terms in the Code.

Name: Signature: ----------------Page (13) Break---------------- ANNEXURE-III FORMAT FOR PRE-CLEARANCE ORDER To Name Designation: Place: Sub: Pre-Clearance of transaction in Company’s Securities Ref: Your application dated , 20 for pre-clearance of transaction for securities of the Company in your name / in the names of . This is pursuant to the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 and the Company’s Internal Code of Conduct for Regulating, Monitoring and Reporting of Trades by Insiders under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“Code”). With reference to your above application seeking pre-clearance of your transaction in securities of the Company, we hereby accord our approval to the proposed transaction.

You may kindly note that pursuant to provisions of the Code, the aforesaid transaction shall be executed within seven Trading Days from the date of receipt of this letter, failing which, an application seeking pre-clearance to the proposed transaction together with undertaking in the prescribed format, shall be made afresh.

In case you do not execute the approved transaction on or before the aforesaid date you would have to seek fresh pre-clearance before executing any transaction in the securities of the Company.

Further, you are required to file the details of the executed transactions in the attached format within 2 days from the date of transaction.

In case the transaction is not undertaken a ‘Nil’ report shall be filed within 2 trading days of expiry of Pre-clearance approval.

You shall not enter into any contra trade within 6 months of such Trade.

All capitalized terms used herein but not defined shall have the same meaning as has been assigned to the terms in the Code.

Yours faithfully, For SWASTIKA CASTAL LIMITED COMPLIANCE OFFICER Date: Encl: Format for submission of details of transaction ----------------Page (14) Break---------------- ANNEXURE-V FORMAT FOR DISCLOSURE OF TRANSACTIONS (To be submitted within 2 days of transaction / dealing in securities of the Company) To The Compliance Officer SWASTIKA CASTAL LIMITED [●] Sub: Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended and the Company’s Internal Code of Conduct for Regulating, Monitoring and Reporting of Trades by Insiders under the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“Code”). I hereby inform that I • have not Traded in any security of the Company: • have Traded securities as mentioned below on (date) Name of holder Nature of the Securities and the No. of securities dealt with Bought/sold/subscribed/others DP ID/Client ID / Folio No Price (Rs.) In connection with the aforesaid transaction(s), I hereby undertake to preserve, for a period of 3 years and produce to the Compliance Officer / SEBI any of the following documents: 1. Broker’s contract note.

2. Proof of payment to/from brokers.

3. Extract of bank passbook/statement (to be submitted in case of demat transactions). 4. Copy of Delivery instruction slip (applicable in case of sale transaction). I agree to hold the above securities for a minimum period of six months.

In case there is any urgent need to sell these securities within the said period, I shall approach the Compliance Officer for necessary approval.

I agree not to execute any contra trade transaction for a period of six months from the date of aforesaid transaction in the securities of the Company.

I declare that the above information is correct and that no provisions of the Company’s Code and/or applicable laws/regulations have been contravened for effecting the above said transaction(s). All capitalized terms used herein but not defined shall have the same meaning as has been assigned to the terms in the Code.

Date: Name: Designation: Signature: ----------------Page (15) Break---------------- ANNEXURE-V FORM B SEBI (Prohibition of Insider Trading) Regulations, 2015 [Regulation 7 (1) (b) read with Regulation 6(2) – Disclosure on becoming a director/KMP/Promoter] 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 of a listed company and other such persons as mentioned in Regulation 6(2). Name, PAN, CIN/DIN & Address with contact nos. Category of Person (Promoters/ KMP / Directors/imm Date of appointment of Director /KMP OR Date of Securities held at the time of becoming Promoter/appointment of Director/KMP % of Shareholding ediate relative to/others etc.) becoming Promoter Type of security (For eg. – Shares, Warrants, Convertible Debentures 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 of the company held on appointment of Key Managerial Personnel (KMP) or Director or upon becoming a Promoter of a listed company and other such persons as mentioned in Regulation 6(2). Open Interest of the Future contracts held at the time of becoming Promoter/appointment of Director/KMP Open Interest of the Option Contracts held at the time of becoming Promoter/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 option Name & Signature: Designation ----------------Page (16) Break---------------- ANNEXURE-VI 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, Employee or Director of a listed company and other such persons as mentioned in Regulation 6(2). Name, PAN, CIN/DIN, & address with contact nos. Category of Person (Promoters/ KMP / Director s/immediate relative to/ other s etc.) Securities held prior to acquisition/dispos al 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, ESOPs etc.) Type of No. Type of No. Value Transact Type of No. and % From To security and % security ion security of (For eg. of (For eg.

Type (For eg. sharehol – Shares, share – (Buy/ – Shares, ding Warrants holdin Shares, Sale/ Warrants , g Warrants, Pledge / , Converti Convertible Revoke/ Convertible Ble Debentures Invoke) Debentures Debentur etc.) etc.) es etc.) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Note: “Securities” shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015. ----------------Page (17) Break---------------- Details of trading in derivatives of the company by Promoter, 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) 15 16 17 18 19 20 21 Note: In case of Options, notional value shall be calculated based on Premium plus strike price of options.

Name & Signature: Designation: Date: Place: ----------------Page (18) Break---------------- ANNEXURE- VII ANNUAL DISCLOSURE OF SHARES HELD IN THE COMPANY BY PROMOTER/ENTITY OF PROMOTER GROUP/DIRECTORS/DESIGNATED PERSONS & THEIR IMMEDIATE RELATIVES Name of the Promoter / entity of Promoter Group / Designated Employees; and their Immediate Relatives: Date of appointment: Employee No: Particulars of Individuals No. of shares held on 1/4/20 No. of shares bought during the year No. of shares sold during the year No. of shares held on 31/3/20 Client I.D.

No. Name Relation PAN I/We declare that I/We have complied with the requirement of the minimum holding period of six months with respect to the securities purchased/sold.

I further declare that the above disclosure is true and correct and is in accordance with the Internal Code of Conduct for Regulating, Monitoring and Reporting of Trades by Insiders under the SEBI (Prohibition of Insider Trading) Regulations, 2015. Place: Date: Signature: ----------------Page (19) Break---------------- ANNEXURE-VIII Disclosure Relatives by Designated Person Sr. No. Immediate Relatives Persons with whom Designated Persons share a material financial information Phone/mobile nos. of persons mentioned in (2) & (3) Name of Educational Institution from which Designated Persons have graduated (One time Disclosure) Names of Past Employers (One time Disclosure) (1) (2) (3) (4) (5) (6) ----------------Page (20) Break----------------