Bhansali Engineering Polymers Ltd. — Regulatory Filings 2019

May 30, 2019

~r bHANsAli ENGiNEERiNG polyMERs liMiTEd

CIN : L271OOMH1984PLC032637

Registered Office : 401, 4th Floor, Peninsula Heights, C. D. Barfiwala Road, Andheri (West), Mumbai - 400 058. Tel. : (91-22) 2621 6060/61/62/63/64 ·Fax: (91-22) 2621 6077 ·E-mail: abstron@bhansaliabs.com ·Website: www.bhansaliabs.com

BEPL/SEC/2019/069

Date: May 30, 2019

To	To
The Manager	The National Stock Exchange of
The BSE Limited	India Ltd.
Corporate Relationship Department	Exchange Plaza, C-1, Block G,
Phiroze Jeejeebhoy Towers,	Bandra-Kurla Complex,
Dalal Street;	Sandra (East),
Mumbai 400 001	Mumbai -400 051.
Security ID : BEPL	Symbol : BEPL
Security Code: 500052

Sub: Annual Secretarial Compliance Report for Financial Year ended March 31, 2019.

Dear Sir/ Madam,

Pursuant to Regulation 24A of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulation, 2015 r ead with SEBI Circular No. CIR/CFD/CMDl/27/2019; attached is the Annual Secretarial Compliance Report dated May 30, 2019 for the Financial Year ended March 31, 2019 issued by M/ s Rathi and Associates, Practicing Company Secretaries.

Kindly take the same on records.

Thanking you,

Ashwin M. Patel Company Secretary and GM (Legal)

Encl: As above

!RJithi & !Jlssociates COMPANY SECRETARIES

A-303, Prathamesh, 3rd Floor, Raghuvanshi Mills Compound, 11-12, Senapati Bapat Marg, Lower Parel (W). Mumbai - 400 013. Tel. : 4076 444412491 1222 •Fax : 4076 4466 •E-mail : associates.rathi8@gma1l.com

ANNUAL SECRET ARIAL COMPLIANCE REPORT

(Pursuant to Regulation 24A of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015)

Of

Bhansali Engineering Polymers Limited (;the Company') for the year ended 31st March, 2019

We, Rathi & Associates, have examined:

• (a) all the documents and records made available to us and explanation provided by the Company and its officers;
• (b) the filings/ submissions made by the Company to the BSE Limited and National Stock Exchange of India Limited from time to time;
• ( c) website of the Company; and
• (d) such other documents and filings made by the Company which has been relied upon to make this certification,

for the year ended 31s 1 March, 2019 ("Reporting 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");

Page 1of3

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, as amended;
• (b) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011; and
• (c) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;

and circulars/ guidelines issued thereunder by the concerned authority from time to time 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:-

Sr.	Compliance	Deviations	Observations
No.	Requirement
	(Regulations I circularsI guidelines includingspecific clause)
		Nil

• b) The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder in so far as it appears from our examination of those records.
• c) The following are the details of actions taken against the Company/ 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:

Page 2 of 3

Sr.No.	Actiontaken by	Details of Violation	Detailsofaction taken	Observations
		Nil

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

Sr.	Observationsof	Observations	Actions taken	Commentsof
No.	thePracticing	madeInthe	by the listed	thePracticing
	Company	secretarial	entity, if any	Company
	IntheSecretary	compliance report		Secretary on the
	previous reports	for the year ended		actions taken by
		31st March, 2018		the listed entity
		Not applicable

For RATHI & ASSOCIATES COMPANY SEC ETARIES

HIMANSHU S. KAMDAR PARTNER MEM No. FCS 5171 COP No. 3030

Date: 30th May, 2019 Place: Mumbai