DCM Ltd. — Regulatory Filings 2021

Jun 9, 2021

June 09, 2021

BSELimited Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai -400 001 National Stock Exchange of India Ltd. Exchange Plaza, Plot no. C/1, G Block,Bandra-Kurla Complex, Bandra (E),Mumbai - 400051

Scrip Code : 502820jDCM

Sub: Annual Secretarial Compliance Report for the Financial Year 2020-21.

Dear Sirs,

Pursuant to Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to time read with SEBI Circular CIR/CFD/CMD1/27/2019 dated February 8, 2019, please find enclosed the Annual Secretarial Compliance Report of the Company issued by Ms. Pragnya Parimita Pradhan, Proprietor of M/ s Pragnya Pradhan & Associates, Company Secretaries, for the financial year 2020-21.

This is for your information and record.

Thanking you,

For DCM Limited

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Vimal Prasad Gupta Company Secretary & Compliance Officer FCS 6380 ~

Regd. Address: Unit Nos. 2050 to 2052, 2ndFloor, Plaza - II, Central Square, 20, Manohar Lal Khurana Marg, Bara Hindu Rao, Delhi -110006

Email-investors@dcm.in. Ph: 011-41539170 Website: www.dcm.in

Registered Office: Unit Nos. 2050 to 2052, 2nd Floor, Plaza II, Central Square, 20, Manohar Lal Khurana Marg, Bara Hindu Rao, Delhi - 110006. Phone: (011)41539170 CIN: L74899DLl889PLC000004 Website: www.dcm.in Ernail id: dcmltd@dcm.in

PRAGNYA PRADHAN & ASSOCIATES

PRACTICING COMPANY SECRETARIES

:Deliver the liest at tile earliest

Secretarial Compliance Report of DCM LIMITED for the year ended 31.03.2021

I, Pragnya Parimita Pradhan, Proprietor of Pragnya Pradhan & Associates, Company Secretaries have examined:

• (a) all the documents and records made available to us and explanation provided by the DCM Limited ('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 documents/ filings, as may be relevant, which has been relied upon to make this certification.

for the year ended 31.03.2021("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, as amended from time to time;
• (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 (Prohibition of Insider Trading) Regulations, 2015, as amended from time to time;
• (e) Securities and Exchange Board of India (Registrar to an Issue and Share Transfer Agents) Regulations, 1993;
• (f) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018(Not Applicable to the listed entity during the review period);
• (g) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014(Not Applicable to the listed entity during the review period);

46, LGF, JOR BAGH, New Oelhi-J J0003 Mob: 9953457413 Email id:Pragnyap.pradhan@gmail.com

PRAGNYA PRADHAN & ASSOCIATES

PRACTICING COMPANY SECRETARIES

:JJeliver the liest at the earliest

• (h) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008(Not Applicable to the listed entity during the review period);
• (i) Securities and Exchange Board of India(Issue and Listing of Non-Convertible and Redeemable Preference Shares) Regulations,2013(Not Applicable to the listed entity during the review period);
• (j) Securities and Exchange Board of India(Delisting of Equity Shares) Regulations, 2009(Not Applicable to the listed entity during the review period).

and Circulars/ Guidelinesissued thereunder;

and based on the above examination, I 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.No	Compliance Requirement (Regulations/ Circulars / including Guidelines specific clause)	Deviations	Observations! Remarks of Practicing the Company Secretary
	Nil	Nil	Nil

• (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)The following are the details of actions taken against the listed entity/ its promoters/ directors/ material subsidiaries either by SEBI or by Stock Exchanges (inc1udingunder the Standard Operating Procedures issued by SEBI through various circulars)under the aforesaid Acts/Regulations and Circulars/Guidelines issued thereunder:

Sr.No	Action taken by	Details of violation	Details of action taken E.g.fines, warning letter, debarment, etc.	observations/ remarks of the Practicing Company Secretary, if any.
	Nil	Nil	Nil	Nil

46, LGF, JOR BAGH, New Delhi-II 0003 Mob: 9953457413 Email id:Pragnyap.pradhan@gmail.com

us PRAGNYA PRADHAN &ASSOCIATES

PRACTICING COMPANY SECRETARIES

:Deliver the best at the earliest

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

Sr. No.	Observations of the Practicing Company Secretary in the previous reports	Observations made in the Secretarial Compliance Report for the year ended 31.03.2020	Actions taken by the listed entity, if any	Comments of the Practicing Company Secretary on the actions taken by the listed entity
1	After the resignation of Dr. Meenakshi Nayar Independent VVoman Director, Company could not comply the requirement to appoint the new Independent Director within the prescribed time limit of 3 months and there has been procedural delay of 8 days primarily on account of time taken to identify suitable candidate with knowledge and experience for appointment of new Independent Director and conducting the meetings & of Nomination Remuneration Committee and Board of Directors. Further Dr. Kavita A Sharma, Independent VVoman Director was duly appointed on the Board of Company w.e.f. November 14, 2019 and	As specified in column 2 of this table.	Dr. Kavita A Sharma, Independent VVoman Director was duly appointed on the Board of Company w.e.f. November 14,2019.	The delay in the appointment of Independent VVoman Director was complied by DCM Limited and duly intimated to the Stock Exchanges.

PRAGNYA PRADHAN & ASSOCIATES

PRACTICING COMPANY SECRETARIES

:J5eliver tile liest at tile earliest

thereafter the composition
of the Board of Directors
of the Company is as per
the requirement of SEBI
& (Listings Obligations
Disclosure Requirements)
Regulations, 2015, as
amended from time to
time

I, further report that during the year under review Company has appointed M/ s. S S Kothari Mehta and Company, as Statutory Auditors of the Company at the Annual General Meetingof the Company held on September 25, 2020 for a period of 5 (five) years. In this regard, I report that Company has complied with Para 6(A) and 6(B)of the Circular No. CIR/CFD/CMDI/114/2019 dated October 18, 2019.

For Pragnya Pradhan & Associates

PRAGNYA ~i~~~~~'" PARIMITA ~:~~~ PRADHANOa te,2()21.06.07 10:03:24+05')0'

Pragnya Parimita Pradhan (Company Secretary)

Place: New Delhi Date: 07-06-2021

ACS No. -32778 CP No. - 12030 UDIN : A032778C000426644