Ahluwalia Contracts (india) LimitedNSE: AHLUCONT

Annual Secretarial Compliance Report 2025-26. click here more details

· Issued by Ahluwalia Contracts (India) Limited

CS SANTOSH KUMAR PRADHAN

COMPANY SECRETARIES

Secretarial Compliance Report Of Ahluwalia Contracts (India) Limited (CIN: L45101DL1979PLC009654) For the Financial Year Ended 31st March, 2026

I have conducted the review of the compliance of the applicable statutory provisions and the adherence to good corporate practices by Ahluwalia Contracts (India) Limited (CIN: L45101DL1979PLC009654) (hereinafter referred to as the Listed Entity), having its Registered Office A-177, Okhla Industrial Area, Phase-I, New Delhi-110020. Secretarial Review was conducted in a manner that provided us a reasonable basis for evaluating the corporate conducts/statutory compliances and to provide our observation thereon.

Based on our verification of the listed entity's books, paper, minutes books, forms and returns filed and other records maintained by the listed entity and also the information provided by the listed entity, its officers, agents and authorized representatives during the conduct of Secretarial Review, I hereby report that the listed entity has, during the review period covering the financial year ended on 31st March, 2026 complied with the statutory provisions listed hereunder in the manner and subject to the reporting made hereinafter:

I, Santosh Kumar Pradhan, Company Secretary in Practice, have examined:

  1. All the documents and records made available to me and explanation provided by Ahluwalia Contracts (India) Limited (CIN: L45101DL1979PLC009654) (hereinafter referred to as the Listed Entity).

  2. The filling/ submissions made by the Listed Entity to the Stock Exchanges,

  3. Website of the Listed Entity,

  4. Any other document/ filling, as may be relevant, which has been relied upon to make this report for the Financial Year ended 31st March, 2026 ("Review Period") in respect of Compliance of the Provisions of:

    1. The Securities and Exchange Board of India Act, 1992 ("SEBI Act") and the Regulation, Circulars, Guidelines issued thereunder; and

    2. The Securities Contracts (Regulation) Act, 1956 ("SCRA"), rules made thereunder and the Regulations, Circulars, Guidelines issued thereunder by the Securities and Exchange Board of India ("SEBI");

The specific Regulations, who's Provisions and the Circulars/Guidelines issued thereunder, have been examined, include:-

  1. Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015;

  2. Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018:-

    Not applicable during the Review period.

    Page 1 of 5

    706, 8th Floor, K.M. Trade Tower, Hotel Radisson Blu,

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    Tel.: +91-9810278845, e-mail: pradhansantosh2006@yahoo.co.in

  3. Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;

  4. Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018:- Not applicable during the Review period.

  5. Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021:- Not applicable during the Review period.

  6. Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021:-

    Not applicable during the Review period.

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

  8. Securities and Exchange Board of India (Depositories and Participants) Regulations, 2018;

    and circulars/ guidelines issued thereunder and based on the above examination, I hereby report that, during the Review Period:

    1. (a) The Listed Entity has complied with the provisions of the above Regulations and the Circulars/Guidelines issued thereunder;

      The Listed Entity has received Letters, clarifications and E-mails from the Stock Exchanges, which were duly replied by the Company during the Review period.

      (b) The listed entity was not required to take any action to comply with the observations made in previous reports as there were no observation in the previous report.

    2. The provisions of Para 6 of Circulars no. CIR/CFD/CMD1/114/2019 issued by SEBI on 18th October, 2019 in terms of resignation of Statutory Auditors are not applicable on the Listed Entity during the Review Period as there was no change in Auditors of the Company during the Review Period.

    3. I further report that during the review period, the compliance status of the Listed entity as required under NSE Circular Ref No: NSE/CML/2023/21 dated 16th March, 2023 & NSE/CML/2023/30 dated 10th April, 2023 and the BSE Circular No. 20230316-14 dated 16th March, 2023 & 20230410-41 dated 10th April, 2023, are annexed as Annexure-A to the report.

      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 nor 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 24A (2) of the SEBI (Listing Obligations and Disclosure Requirements) 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.

For Santosh Kumar Pradhan Place: Angul, Odisha Company Secretaries

Santosh Kumar

Date: 25.05.2026

Digitally signed by Santosh Kumar Pradhan

Pradhan

Date: 2026.05.25

22:39:44 +05'30'

Santosh Kumar Pradhan Proprietor C. P. No. : 7647 FCS No. F6973 P.R. No. 1388/2021 UDIN: F006973H000458512

ANNEXURE-A

I hereby report that, during the Review Period the compliance status of the listed entity is appended as below:

Sr.

No.

Particulars

Complia nce Status (Yes/No

/NA)

Observat ions

/Remark by PCS

1.

Secretarial Standard:

The compliances of listed entity are in accordance with the applicable Secretarial Standard (SS) issued by the Institute of Company Secretaries India (ICSI), as notified by the Central Government under section 118(10) of the Companies Act,2013 and mandatorily applicable.

Yes

Nil

2.

Adoption and timely Updation of 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/circular/ guidelines issued by SEBI.

Yes

Nil

3.

Maintenance and disclosure 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 re-directs to the relevant document(s)/section of the website.

Yes

Nil

4.

Disqualification of Director:

None of the Director of the Company are disqualified under section 164 of the companies Act, 2013 as confirmed by the listed entity.

Yes

Nil

5.

Details related to subsidiaries of listed entities have been examined w.r.t.:

  1. Identification of material subsidiary companies.

  2. Disclosure requirement of material as well as other subsidiaries.

Yes

The Company does not have any material subsidiar y during the review period.

6.

Preservation of Documents:

The listed entity is preserving and maintaining records as prescribed under SEBI Regulations and disposal of records as per Policy of Preservation of Documents and Archival Policy prescribed under SEBI LODR regulations, 2015.

Yes

Nil

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

Nil

8.

Related party Transactions:

  1. The listed entity has obtained prior approval of Audit Committee for all related party transactions; or

  2. The listed entity has provide detailed reasons along with confirmation whether the transactions were subsequently approved/ratified/rejected by the Audit Committee, in case no prior approval has been obtained.

Yes

Nil

9.

Disclosure of events or information:

The listed entity has provided all the required disclosure(s) under Regulation 30 along with Schedule III of SEBI LODR Regulation, 2015 within the time limits prescribed thereunder.

Yes

Nil

10.

Prohibitions of insider Trading:

The listed entity is in compliance with Regulation 3(5) & 3(6) SEBI (Prohibition of Insider Trading) Regulations, 2015.

Yes

Nil

11.

Actions taken by SEBI or Stock Exchange(s), if any:

No Action has been 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) under SEBI Regulations and circulars/guidelines issued thereunder except as provided under separate paragraph herein.

Yes

Nil

12.

Additional Non- compliance, if any:

Yes

Nil

No additional non-compliance regulation/circular/guidance note etc.

observed

for

any

SEBI

For Santosh Kumar Pradhan

Santosh Kumar

Place: Angul, Odisha Company Secretaries Date: 25.05.2026

Digitally signed by Santosh Kumar Pradhan

Pradhan

Date: 2026.05.25

22:40:21 +05'30'

Santosh Kumar Pradhan Proprietor C. P. No. : 7647 FCS No. F6973 P.R. No. 1388/2021 UDIN: F006973H000458512

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