ASM Technologies Ltd. — Regulatory Filings 2026

May 11, 2026

BMP & Co.
COMPANY SECRETARIES
BENGALURU | MUMBAI | DEEHINCK

SECRETARIAL COMPLIANCE REPORT OF ASM TECHNOLOGIES LIMITED FOR THE FINANCIAL YEAR ENDED 31ST MARCH 2026

[Pursuant to Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements), Regulations, 2015]

To,

The Members,

ASM Technologies Limited

CIN: L85110KA1992PLC013421

Registered Address: 80/2, Lusanne Court,
Richmond Road, Bangalore – 560025.

We have conducted the review of the compliance of the applicable statutory provisions and the adherence to good corporate practices of ASM Technologies Limited (CIN: L85110KA1992PLC013421) (hereinafter referred as ‘the Listed Entity’ or ‘Company’), having its registered office at 80/2, Lusanne Court, Richmond Road, Bangalore – 560025. The Secretarial Review was conducted in a manner that provided us with a reasonable basis for evaluating the corporate conducts/statutory compliances and expressing our opinion thereon.

Based on our verification of the Listed Entity’s books, papers, 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, we 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 and also that the Listed Entity has proper Board processes and compliance mechanism in place to the extent, in the manner and subject to the reporting made hereinafter:

We, BMP & Co. LLP, Practicing Company Secretaries, have examined:

(a) all the documents and records made available to us and explanation provided by the Listed Entity,
(b) the filings/ submissions made by the Listed Entity to the stock exchange,
(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 31st March 2026 (“Review Period”) in respect of compliance with the provisions of:
(i) the Securities and Exchange Board of India Act, 1992 (“SEBI Act”) and the Regulations, circulars, guidelines issued thereunder; and
(ii) 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”);

BMP & Co. LLP
4th Floor, Aishwarya Sampurna, No. 79/1, Vani Vilas Road, Basavanagudi, Bengaluru - 560 004, Karnataka.
+91 99009 01974 info@bmpandco.com www.bmpandco.com LLPIN: AAI-4194

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BMP & Co.
COMPANY SECRETARIES
BENGALURU | NUMERI | DELHI NER

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 (“SEBI LODR Regulations, 2015”) to the extent applicable;
(b) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 to the extent applicable;
(c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 to the extent applicable;
(d) Securities and Exchange Board of India (Buy-back of Securities) Regulations, 2018: - Not Applicable during the year under review;
(e) The Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021: - Not applicable during the year under review;
(f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021: - Not applicable during the year under review;
(g) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“PIT Regulations”) to the extent applicable;
(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: - Not applicable as the Company is not registered as Registrar to an Issue and Share Transfer Agent during the year under review; and
(i) Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2021: - Not applicable as the Company has not delisted its equity shares from any stock exchange during the year under review; and circulars/ guidelines issued thereunder; and based on the above examination, we 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: -

BMP & Co. LLP
4th Floor, Aishwarya Sampurna, No. 79/1, Vani Vilas Road, Basavanagudi, Bengaluru - 560 004, Karnataka.
+91 99009 01974 info@bmpandco.com www.bmpandco.com LLPIN: AAI-4194

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BMP & Co.
COMPANY SECRETARIES
BENGALURU | MUNDAI | BELGIUM

Sr. no.	Compliance Requirement (Regulations/circulars/guidelines including specific clause)	Regulation/Circular No.	Deviations	Actions taken by	Type of Action	Details of violation	Fine amount	Observations/Remarks of the Practicing Company Secretary	Management Response	Remarks
1	Schedule XIX Para 2 of SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018	SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018	Non-compliance with the requirement to make an application to the Exchange for listing of Equity shares upon conversion of warrants within 20 days from the date of allotment.	BSE Limited	Monetary - Imposition of fine	Non-compliance with the requirement to make an application to the Exchange for listing of Equity shares upon conversion of warrants within 20 days from the date of allotment.	Rs. 25,40,000/- (excl. of GST)	The Company has delayed filing the application with the Stock Exchange for listing of equity shares allotted pursuant to conversion of warrants, beyond the timeline prescribed under Schedule XIX Para 2 of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018. Consequently, BSE Limited imposed a monetary fine of Rs. 25,40,000/- (excluding GST) on the Company for the said non-compliance.	The non-compliance is of a technical nature and was unintentional, with no willful disregard for the applicable provisions of the law.	-

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

BMP & Co. LLP
4th Floor, Aishwarya Sampurna, No. 79/1, Vani Vilas Road, Basavanagudi, Bengaluru - 560 004, Karnataka.
+91 99009 01974
info@bmpandco.com
www.bmpandco.com LLPIN: AAI-4194

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BMP & Co.
COMPANY SECRETARIES
BENGALURU | MUMBAI | BELGIUM

Sr. no.	Observations/ Remarks of the Practicing Company Secretary in the previous reports	Observations made in the secretarial compliance report for the year ended 31st March 2025	Compliance Requirement (Regulations/circulars/ guidelines including specific clause)	Details of violation / deviations and actions taken / penalty imposed, if any, on the listed entity	Remedial actions, if any, taken by the listed entity	Comments of the PCS on the actions taken by the listed entity
Not applicable

(c) We hereby report that, during the Review Period the compliance status of the Listed Entity with the following requirements is appended as below:

Sr. No.	Particulars	Compliance Status (Yes/No/ NA)	Observations/ Remarks from 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 India (ICSI).	Yes	-
2.	Adoption and timely update of the Policies:
• All applicable policies under SEBI Regulations are adopted with the approval of board of directors of the Listed Entity.
• All the policies are in conformity with SEBI Regulations and has been reviewed & updated on time, as per the regulations/circulars/ guidelines issued by SEBI.	Yes	-
3.	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 re-directs to	Yes	-

BMP & Co. LLP
4th Floor, Aishwarya Sampurna, No. 79/1, Vani Vilas Road, Basavanagudi, Bengaluru - 560 004, Karnataka.
+91 99009 01974
info@bmpandco.com
www.bmpandco.com LLPIN: AAI-4194

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BMP & Co.
COMPANY SECRETARIES
BENGALURU | MUMBAI | DESIGNER

	the relevant document(s)/ section of the website.
4.	Disqualification of Directors:
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.	NA	None of the directors were disqualified, during the period under review.
5.	Details related to Subsidiaries of listed entities have been examined w.r.t.:
(a) Identification of material subsidiary 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 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	-
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 LODR Regulations, 2015.	Yes	-
8.	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 has been obtained, the Listed Entity shall provide detailed reasons along with confirmation whether the transactions were subsequently approved/ratified/rejected by the Audit Committee.	Yes	-
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 Regulations, 2015 within the time limits prescribed thereunder.	Yes	-
10.	Prohibition of Insider Trading:	Yes	-

BMP & Co. LLP
4th Floor, Aishwarya Sampurna, No. 79/1, Vani Vilas Road, Basavanagudi, Bengaluru - 560 004, Karnataka.
+91 99009 01974 info@bmpandco.com www.bmpandco.com LLPIN: AAI-4194
5

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BMP & Co.
COMPANY SECRETARIES
BENGALURU | MUMARI | BELMINGR

	The Listed Entity is in compliance with Regulation 3(5) & 3(6) SEBI (Prohibition of Insider Trading) Regulations, 2015
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) under SEBI Regulations and circulars/ guidelines issued thereunder.	Yes	BSE Limited had imposed a monetary fine of Rs. 25,40,000/- (excluding GST) on the Company for non-compliance with Schedule XIX Para 2 of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018, pertaining to delay in making the application for listing of equity shares allotted upon conversion of warrants within the prescribed timeline.
Other than the aforesaid action, no actions were taken against the Listed Entity/ its promoters/ directors/ subsidiaries either by SEBI or by the Stock Exchanges under SEBI Regulations and circulars/ guidelines issued thereunder.
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 SEBI LODR Regulations, 2015 by listed entities.	NA	The Auditor has not resigned during the review period.
13.	No additional non-compliances observed:	NA	No additional non-compliance was observed for SEBI regulation/

BMP & Co. LLP
4th Floor, Aishwarya Sampurna, No. 79/1, Vani Vilas Road, Basavanagudi, Bengaluru - 560 004, Karnataka.
+91 99009 01974
info@bmpandco.com
www.bmpandco.com LLPIN: AAI-4194
6

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BMP & Co.
COMPANY SECRETARIES
BENGALURU | MUMBAI | DELHI NEX

	No additional non-compliance observed for any of the SEBI regulation/ circular/guidance note etc. except as reported above.		circular/guidance note during the year under review.

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 certify 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 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 BMP & Co. LLP,
Company Secretaries

Place: Bengaluru
Date: May 11, 2026
UDIN: F007834H000328264

CS Pramod S M
Partner
FCS No: 7834 CP No: 13784
Peer Review Certificate No. 6387/2025
Firm Registration Number: L2017KR003200

BMP & Co. LLP
4th Floor, Aishwarya Sampurna, No. 79/1, Vani Vilas Road, Basavanagudi, Bengaluru - 560 004, Karnataka.
+91 99009 01974
info@bmpandco.com
www.bmpandco.com LLPIN: AAI-4194
7