Disa India Ltd — Updates, 27-05-2025: Company Update

Ref: DIL/SEC/2025-26

May 27, 2025

The Listing Manager

BSE Limited

Phiroze Jeejeebhoy Towers

Dalal Street, Mumbai -400001

Scrip Code- 500068

Name of the Company - DISA India Limited

Dear Sir,

Sub: Annual Secretarial Compliance Report for the year ended March 31, 2025.

Pursuant to Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements)

Regulations, 2015, read with relevant SEBI Circulars issued from time to time, please find

attached the Annual Secretarial Compliance Report issued by Mr. Vijayakrishna K T,

Practicing Company Secretary, for the Financial Year ended March 31, 2025.

This is for your information and records.

Yours sincerely,

For DISA India Limited,

Shrithee M S

Company Secretary & Compliance Officer

Encl: As above

DISA India Limited

Registered & Corporate Office: 6th Floor, S-604, World Trade Center (WTC), Brigade Gateway Campus, 26/1,

Dr Rajkumar Road, Malleswaram-Rajajinagar, Bangalore-560 055, Karnataka, India

T: +9180 2249 6700-03 I F: +91 80 2249 6750 I E: bangalore@noricangroup.com W: www.noricangroup.com ON: L8S110KA1984PLC006116 I GST: 29AAACG5030f1ZY

We are Norican : DISA I ltalPresseGauss I Monitizer I Simpson

Regional Sales:

New Delhi: delhi@noricangroup.com

Kolkata: kolkata@noricangroup.com Pune: pune@noricangroup.com

Parts & Services: cdc.india@noricangroup.com

I StrikoWestofen I Wheelabrator

Norican Group

Shaping Industry

Manufacturing Facility: Tumkur: No. 28·32, Satyamangala Industrial Area,

Tumkur-572104, Karnataka, India. T: +91816 6602000/01

E: tumkur@noricangroup.com

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VIJAYAKRISHNA KT # 496/4, II Floor, 10th Cross

Near Bashyam Circle, Sadashivanagar,

Bangalore -560 080, INDIA BBM, LLB, FCS, ACMA Company Secretary

Tel : +91 80 23610847, Mob.: 9448481544

e-mail : vijaykt@vjkt.in

SECRETARIAL COMPLIANCE REPORT OF

DISA INDIA LIMITED

CIN: L85110KA1984PLC006116

ktvijaykrishna@gmail .corn

FOR THE FINANCIAL YEAR ENDED 315T MARCH, 2025

I, Vijayakrishna KT, Practising Company Secretary, have examined:

(a) all the documents and records made available to us and explanation provided

by Disa India Limited ("the listed entity"),

(b) the filings/ submissions made by the listed entity to the Stock Exchanges

(c) website of the listed entity,

(d) any other document/ filing, as may be relevant, which has been relied upon to

make this Report.

for the financial year ended 31st March, 2025 ("Review Period") in respect of

compliance with the provisions of:

(a) the Securities and Exchange Board of India Act, 1992 ("SEBI Act") and the

regulations, circulars, guidelines issued thereunder; and

(b) the Securities Contracts (Regulation) Act, 1956 ("SCRA"), rules made

thereunder and the regulations, circulars, guidelines issued thereunder by the

SEBI;

The specific Regulations, whose provIsIons and the circulars/ guidelines issued

thereunder, have been examined, include: -

(a) Securities and Exchange Board of India (LODR) Regulations, 2015;

(b) Securities and Exchange Board of India (Issue of Capital and Disclosure

Re uirements) Regulations, 2018;

nd Exchange Board of India (Substantial Acquisition of Shares and

Regulations, 2011;

. 66, Sathyanarayana Layout, West of Chord Road, III Stage, Bangalore -560 079, INDIA

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(d) Securities and Exchange Board of India (Buyback of Securities) Regulations,

2018;

(e) Securities and Exchange Board of India (Share Based Employee Benefits and

Sweat Equity) Regulations, 2021;

(f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible

Securities) Regulations, 2021

(g) Securities and Exchange Board of India (Prohibition of Insider Trading)

Regulations, 2015;

(h) other regulations as applicable.

and circulars/ guidelines issued thereunder;

and based on the above examination, I hereby report that, during the Review Period:

(a) (**) The listed entity has complied with the provisions of the above Regulations and

circulars/ guidelines issued thereunder, except in respect of matters specified below:

Sr. Compl Regul Deviatio Acti Type Details Fine Observ Mana Re-

No iance ation/ ns on of of Amou ations geme mar

Requir Circul Take Action Violati nt /Remar nt ks

ement ar No. n by on ks Resp

(Regul of the onse

ations/ Practici

circula ng

rs/ Compa

guideli ny

nes

includi Secreta

ng ry

specifi (PCS)

C

clause

NIL

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(b) The listed entity has taken the following actions to comply with the observations

made in previous reports:

Sr. Observation Observation Compliance Details of Remedi Comment

No s/ Remarks s made in Requiremen violation/ al s of the .

of the the t Deviation actions, PCS

Practicing Secretarial (Regulation sand if any, on the

Company Compliance sf actions taken by actions

Secretary report for circulars/ taken the taken by

(PCS) in the the year guidelines /penalty listed the listed

previous ended including imposed, entity entity

reports) specific if any, on

clause) the listed

..... (The entity

years are to

be

mentioned)

NIL

(Note:

1. Provide the list of all the observations in the repo11 for the previous year along

with the actions taken by the listed entity on those observations.

2. /\dd the list of all observations in the reports pertaining to the periods prior to the

previous year in case the entity has not taken sufficient steps to address the

concerns raised/ observations.

I. I hereby report that, during the review period the compliance status of the listed entity

with the following requirements:

Sr.

No

1.

Particula

rs

Secretarial Standards:

The compliances of the listed entity are in

accordance with the applicable Secretarial

ndards (SS) issued by the Institute of

Company Secretaries of India (ICSI).

Complian

ce

Status(Ye

s/No/NA)

YES

Observations

/Remarks by

PCS*

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4

2.

3.

4.

5.

6.

Adoption and timely updation of the

Policies:

• All applicable policies under SEBI

Regulations are adopted with the approval

of Board of Directors of the listed entities.

• All the policies are in conformity with SEBI

Regulations and have been reviewed &

updated on time, as per the regulations/

circulars/guidelines issued by SEBI.

Maintenance and disclosures on Website:

• The listed entity is maintaining a functional

website.

• Timely dissemination of the documents/

information under a separate section on

the website.

• Web-links provided in annual corporate

governance reports under Regulation

27(2) are accurate and specific which

redirects to the relevant

document(s)/section of the website.

Disqualification of Director(s):

None of the Director(s) of the listed entity is/

are disqualified under Section 164 of

Companies Act, 2013 as confirmed by the

listed entity.

Details related to subsidiaries of listed

entities have been examined w.r.t.:

(a) Identification of material subsidiary

companies.

(b) Disclosure requirement of material as well

as other subsidiaries.

Preservation of Documents:

The listed entity is preserving and maintaining

.. records as prescribed under SEBI

..... ions and disposal of records as per

/..:::.::-/ :: poli~~ preservation of documents and

YES

YES

YES

YES

YES

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7.

8.

9.

10.

11.

archival policy prescribed under SEBI LODR

Regulations, 2015.

Performance Evaluation:

The listed entity has conducted performance

evaluation of the Board, Independent

Directors and the Committees at the start of

every financial year/during the financial year

as prescribed in SEBI Regulations.

Related Party Transactions:

(a) The listed entity has obtained prior

approval of audit committee for all related

party transactions;

(b) In case no prior approval obtained, the

listed entity shall provide detailed reasons

along with confirmation whether the

transactions were subsequently

approved/ratified/rejected by the audit

committee.

Disclosure of events or information:

The listed entity has provided all the required

disclosure(s) under Regulation 30 along with

Schedule Ill of SEBI LODR Regulations, 2015

within the time limits prescribed thereunder.

Prohibition of Insider Trading:

The listed entity is in compliance with

Regulation 3(5) & 3(6) SEBI (Prohibition of

Insider Trading) Regulations, 2015.

Actions taken by SEBI or Stock

Exchange(s), if any:

No action(s) has been taken against the listed

entity/ its promoters/ directors/ subsidiaries

either by SEBI or by Stock Exchanges

(i eluding under the Standard Operating

rocedures issued by SEBI through various

__,.,--i..;.,.rtulars) under SEBI Regulations and

rs/ guidelines issued thereunder (or)

YES

YES

YES

YES

YES

YES

Certain

ransactions were

ratified and

approved

subsequently.

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12.

13.

The actions taken against the listed entity/ its

promoters/ directors/ subsidiaries either by

SEBI or by Stock Exchanges are specified in

the last column.

Resignation of statutory auditors from the

listed entity or its material subsidiaries:

In case of resignation of statutory auditor from

the listed entity or any of its material

subsidiaries during the financial year, the

listed entity and / or its material

subsidiary(ies) has / have complied with

paragraph 6.1 and 6.2 of section V-D of

chapter V of the Master Circular on

compliance with the provisions of the LODR

Regulations by listed entities.

Additional Non-Compliances, if any:

No additional non-compliances obseNed for

any SEBI regulation/circular/guidance note

etc. except as reported above.

NA

NA

During the review

period, there has

been no change in

he Statutory

Auditors.

During the review

period, no

additional non -

compliance was

obseNed.

ObseNations/Remarks by PCS are mandatory if the compliance status is provided as

'No' or 'NA'

We further, report that the listed entity is in compliance/ not in compliance with the

disclosure requirements of Employee Benefit Scheme Documents in terms of

regulation 46(2) (za) of the LODR Regulations. Not Applicable

(Note: In case of non-compliance, details of such non-compliance need to be

mentioned)

Assumptions & limitation of scope and review:

1. Compliance of the applicable laws and ensuring the authenticity of documents

and information furnished, are the responsibilities of the management of the

listed entity.

2. responsibility is to report based upon our examination of relevant

nd information. This is neither an audit nor an expression of

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opinion.

3. We have not verified the correctness and appropriateness of financial records

and books of account of the listed entity.

4. This report is solely for the intended purpose of compliance in terms of

Regulation 24A (2) of the SEBI (LODR) Regulations, 2015 and is neither an

assurance as to the future viability of the listed entity nor of the efficacy or

effectiveness with which the management has conducted the affairs of the listed

entity.

Place: Bengaluru

Date: 21st May, 2025

retary

: 8 CP: 980

7

: F001788G000403365

Peer Review Certificate No. 1883/2022

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