Balurghat Technologies Ltd. — Audit Report / Information 2021

Jun 28, 2021

Date: 28-06-2021

The Deputy General Manager The Bombay Stock Exchange Ltd P. J. Towers, 25th Floor Dalal Street. Mumbai-400001

Dear Sir.

Re: Script Code: 520127

SUB: Annual Secretarial Compliance Report for the year ended March 31, 2021

Pursuant to SEBI Circular No. CIR/CFD/CMDI/27/2019 dated February 8, 2019 please find enclosed the Annual Secretarial Compliance Report of the Company for the Financial Year March 31, 2021 issued by Kanchan Maheswari, Company Secretary.

This is for your information & records.

Thanking You,

For Balurghat Technologies Ltd

(Arti Dugar) Company Secretary ACS: 55175

BALURGHAT TECHNOLOGIES LTD. (Formerly: Balurghat Transport Co. Ltd.) 170/2C, Acharya Jagadish Ch. Bose Road, Kolkata - 700 014 Phone: (033)-2286-6404, Fax: (033) 2284 2084, E-mail: kolkata@balurghat.co.in

KANCHAN MAHESWARI 122/2, B. B. Street, S. R. Villa COMPANY SECRETARY Bhadrakali, Hooghly – 712232 M o b i l e : 8 4 2 0 8 2 1 1 5 3

Email: kanchan8211@gmail.com

Secretarial Compliance Report of M/s Balurghat Technologies Limited for the year ended 31st March, 2021

[Pursuant to Circular CIR/CFD/CMD1/27/2019 dated February 08, 2019 for the purpose of compliance with Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015]

To,

The Members of Balurghat Technologies Limited 170/2C, A.J.C. Bose Road Kolkata-700014

CIN: L60210WB1993PLC059296 Authorised Capital: Rs. 30,00,00,000/-

I have conducted the Secretarial Compliance Audit of the applicable SEBI (Securities and Exchange Board of India) Regulations and the circulars/ guidelines issued thereunder for the Financial Year ended 31st March 2021 for M/s BALURGHAT TECHNOLOGIES LIMITED ("the listed entity"). The audit was conducted in a manner that provided me a reasonable basis for evaluating the statutory compliances and expressing my opinion thereon.

I have examined:

• (a) all the documents and records made available to me and explanation provided by 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 31st March, 2021 ("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 India ("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 were not applicable 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 were not applicable during the review period;;

• (e) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014 were not applicable during the review period;;

• (f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008 were not applicable during the review period;;

• (g) Securities and Exchange Board of India(Issue and Listing of Non Convertible and Redeemable Preference Shares) Regulations,2013 were not applicable during the review period;;
• (h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
• (i) The provisions of the Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 1993;
• (j) The provisions of Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2009 were not applicable during the review period;

And circulars/ guidelines issued thereunder;

Based on my examination and verification of the documents and records produced to me and according to the information and explanations given to me by the listed entity, I report that: -

• (a) The listed entity has complied with the provisions of the above Regulations and circulars/ guidelines issued thereunder.
• (b) The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder insofar as it appears from my examination of those records.
• (c) There were no actions taken against the listed entity/ its promoters/ directors/ material subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under the aforesaid Acts/ Regulations and circulars/ guidelines issued thereunder:
• (d) There are no observations made in previous report, hence action taken from listed entity was not required.

Place: Kolkata	Signature	: Digitally signed by Kanchan Kanchan Maheswari Date: 2021.06.28 Maheswari 17:41:10 +05'30'
		Name of the Company Secretary : KANCHAN MAHESWARI
Date : 28/06/2021	ACS Number	: 55837
	CP Number	: 20877
UDIN - A055837C000531092

Note: In view of the second wave of the COVID19 pandemic and as per the guidance issued by the Institute of Company Secretaries of India (ICSI) for carrying out professional assignments, the Secretarial Compliance Report in term of Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 was conducted by using appropriate Information Technology tools by virtual data sharing to access and examine relevant documents for completion of the audit.