[Framed under regulation 8(1) of the SEBI (Prohibition of Insider Trading) Regulations, 2015]

Kothari Phytochemicals & Industries Limited ("Company") will adhere to the followings so as to ensure fair disclosure of events and occurrence that could impact price of its securities in the market:

1. Company will promptly make public disclosures of unpublished price sensitive information that would impact price discovery as soon the information or the decisions are approved by the Board. It will inform the stock exchange and simultaneously upload such information on Company's website www.kothariphyto.com in order to make such information generally available to Investors and Members of the Company.

2. Company shall make uniform and universal dissemination of unpublished price sensitive information to avoid selective disclosure by making simultaneous disclosure to stock exchanges where the shares of the Company are listed and also at the website of the Company.

3. Mr. Madan Lal Daga, Company Secretary, is designated as Chief Investor Relations Officer to take all required action for dissemination of information and disclosure of unpublished price sensitive information indiscriminately.

4. In the event of inadvertent selective disclosures of unpublished price sensitive information, prompt action shall be taken by Chief Investor Relations Officer to ensure such information is generally available to Investors and Members of the Company. Company shall take all reasonable steps, to make generally available any discussion on unpublished price sensitive information at the meeting of analyst or investor relations through the official website to ensure official confirmation and public disclosure.

5. Chief Investor Relations Officer shall provide appropriate assistance and fair response to Regulatory Authorities for verification of news reports or market rumors.

6. Chief Investor Relations Officer shall further ensure that information shared with analysts and research personnel is not unpublished information of price sensitive nature.

7. Unpublished Price Sensitive Information shall be handled on a "need to know" basis i.e. unpublished price sensitive information shall be disclosed only to those who need the information by virtue of statutory requirement, contractual obligation to discharge their duties / obligations etc. in the interest of the Company.