Dynamic Portfolio Management & Services Ltd — Updates, 30-05-2025: Company Update

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Secretarial Compliance Report of

Dynamic Portfolio Management Services Limited

For the year ended March 31, 2025

I M/s Dinesh Sharma, Company Secretaries have examined:

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

Portfolio Management Services Limited (CIN: L74140DL1994PLC304881) ("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

certification,

for the year ended March 31, 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 Securities and Exchange Board

of lndia ("SEBI");

The specific Regulations, whose provisions and the circulars/ guidelines issued thereunder,

have been examined, include:

(a) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements)

Regulations, 2015;

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

Regulations, 2018 (Not applicable to the listed entity during the Review Period);

(c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers)

Regulations, 2011;

(d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018 (Not

applicable to the listed entity during the Review Period);

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

Regulations, 2021 (Not applicable to the listed entity during the Review Period);

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

Regulations, 2021 (Not applicable to the listed entity during the Review Period);

(g) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;

(h) Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents)

Regulations, 1993 regarding the Companies Act and dealing with client.

(i) Securities and Exchange Board of India (Depositories and Participants) Regulations, 2018

and circulars/ guidelines issued thereunder; and based on the above examination, we

hereby report that, during the Review Period:

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

circulars/guidelines issued thereunder.

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

in previous reports: Not Applicable, as there being no observation in previous reports:

(c) We hereby report that, during the Review Period the compliance status of the listed

entity with the following requirements:

Sr. No Particulars Compliance

status (Yes/

No/ NA)

Observations/

Remarks by

PCS

1. Secretarial Standards:

The compliances of the listed entity are in

accordance with the applicable Secretarial

Standards (SS) issued by the Institute of

Company Secretaries of India (ICSI).

Yes ------

2. Adoption and timely updation of the

Policies:

(a) All applicable policies under SEBI

Regulations are adopted with the approval of

board of directors of the listed entity;

(b) All the policies are in conformity with SEBI

Regulations and have been reviewed & timely

updated as per the regulations/ circulars/

guidelines issued by SEBI

Yes

-------

3. Maintenance and disclosures on Website:

(a) The Listed entity is maintaining a

functional website;

(b) Timely dissemination of the documents/

information under a separate section on the

website;

(c) Web-links provided in annual corporate

governance reports under Regulation 27(2)

are accurate and specific which re-directs to

the relevant document(s)/ section of the

website

Yes -------

4. Disqualification of Director:

None of the Directors of the listed entity are

disqualified under Section 164 of Companies

Act, 2013.

Yes ------

5. Details related to Subsidiaries of listed

entities:

(a) Identification of material companies;

(b) Requirements with respect to

disclosure of material as well as other

subsidiaries

Yes ------

6. Preservation of Documents:

The listed entity is preserving and maintaining

Yes -----

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records as prescribed under SEBI Regulations

and disposal of records as per Policy of

Preservation of Documents and Archival

policy prescribed under the LODR Regulations.

7. Performance Evaluation: The listed entity has

conducted performance evaluation of the

Board, Independent Directors and the

Committees at the start of every financial year

as prescribed in SEBI Regulations

Yes -----

8. Related Party Transaction.

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.

Yes

N.A.

The Listed

Entity has

obtained the

prior approval

of Audit

Committee for

all Related

transactions

9. Disclosure of events or information:

The listed entity has provided all the required

disclosure(s) under Regulation 30 along with

Schedule III of the LODR Regulations within

the time limits prescribed thereunder.

Yes -----

10. Prohibition of Insider Trading:

The listed entity is in compliance with

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

Insider Trading) Regulations, 2015

Yes -----

11. Actions taken by SEBI or Stock

Exchange(s), if any:

No actions taken against the listed entity/ its

promoters/directors/ subsidiaries either by

SEBI or by Stock Exchanges (including under

the Standard Operating Procedures issued by

SEBI through various circulars) SEBI

Regulations and circulars/ guidelines issued

thereunder.

Yes The DEMAT

Account of

Promoter R K

Newatia is

blocked as an

action of stock

exchange in

relation to Non

Payment of

Dues.

12. 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.

NA There was no

resignation of

statutory

auditors in the

Listed entity

during the

review NA

period. Further

the Listed Entity

does not have

any material

subsidiary.

13. No additional non-compliances observed: NA There are no

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No additional non-compliance observed for

any of the SEBI regulation/ circular/guidance

note etc. except as reported above

non-

compliances

observed in the

listed entity

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. Our responsibility is to report based upon our examination of relevant documents and

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

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

accounts of the listed entity.

4. This report is solely for the intended purpose of compliance in terms of Regulation 24 A(2)

of the LODR Regulations 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: Jaipur For Dinesh Sharma

Date: 29/05/2025 (Company Secretaries)

(ICSI Unique Code I2022RJ324423700

PR 6796/2025)

CS Dinesh Sharma

ACS: 44736

CP: 26246

UDIN: A044736G000497760

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