BlueWave Pharmaceuticals Ltd., a listed company, has a robust internal policy to prevent insider trading in line with SEBI (Prohibition of Insider Trading) Regulations, 2015. The Company's compliance officer maintains a

Regulation 9A of the SEBI (Prohibition of Insider Trading) Regulations, 2015 dealing with Institutional Mechanism for Prevention of Insider trading. It provides that the Chief Executive Officer, Managing Director or such other analogous person of a listed company, intermediary or fiduciary shall put in place adequate and effective system of internal controls to ensure compliance with the requirements given in these regulations to prevent insider trading. The internal controls shall include the following: all employees who have access to unpublished price sensitive information are identified as designated person; all the unpublished price sensitive information shall be identified and its confidentiality shall be maintained as per the requirements of these regulations; adequate restrictions shall be placed on communication or procurement of unpublished price sensitive information as required by these regulations; lists of all employees and other persons with whom unpublished price sensitive information is shared shall be maintained and confidentiality agreements shall be signed or notice shall be served to all such employees and persons; all other relevant requirements specified under these regulations shall be complied with; periodic process review to evaluate effectiveness of such internal controls. BlueWave Pharmaceutical Ltd. must implement a multi-layered framework of preventive and detective internal controls. This system is designed to safeguard Unpublished Price Sensitive Information (UPSI) and govern trading activities. The first line of defence is the strict control over UPSI itself. Access to sensitive information must be governed by a "need-to-know" principle, enforced through a digital permissions system. This system should maintain a chronological log of all individuals who access specific UPSI, creating an audit trail with timestamps and purposes. All designated persons must execute legally binding confidentiality agreements, and the sharing of any UPSI must be mandated through secure, encrypted channels to prevent leaks. The second critical layer involves governing trading behaviour. No insider shall trade in securities when in possession of unpublished price sensitive information.