DCM Ltd. — Regulatory Filings 2025

May 13, 2025

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LIMITED

May 13, 2025

BSE Limited 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 – 400 051

Scrip Code: 502820 Scrip Code: DCM ISIN: INE498A01018

Sub: Annual Secretarial Compliance Report for the financial year ended

March 31, 2025

Dear Sir/Madam,

In compliance with the provisions of Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended, read with SEBI’s Master Circular No. SEBI/HO/CFD/PoD2/CIR/P/0155 dated November 11, 2024, please find enclosed herewith the Annual Secretarial Compliance Report for the financial year ended March 31, 2025, issued by Ms. Pragnya Parimita Pradhan, Proprietor of M/s. Pragnya Pradhan & Associates, Company Secretaries.

This disclosure will also be hosted on the Company's website i.e. https://www.dcm.in.

You are hereby requested to take the above information on record.

Thanking You,

Yours truly,

For DCM Limited

Arjit Digitally signed by Arjit Gupta Date: 2025.05.13 Gupta 13:03:21 +05'30' Arjit Gupta Company Secretary

Registered office:

Unit Nos. 2050 to 2052, Plaza - II, 2[nd] Floor, Central Square, 20, Manohar Lal Khurana Marg, Bara Hindu Rao, Delhi – 110006. Phone: (011) 41539170 CIN: L74899DL1889PLC000004, Website: www.dcm.in, Email Id: investors@dcm.in

PRACTICING COMPANY SECRETARIES

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PRAGNYA PRADHAN & ASSOCIATES

Annual Secretarial Compliance Report of DCM LIMITED for the financial year ended 31.03.2025

[Under Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 read with SEBI Circular No. CIR/CFD/CMD1/27/2019 dated February 8, 2019]

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 financial year ended 31.03.2025 (“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; (‘SEBI LODR’)

• (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 and Sweat Equity) Regulations, 2021 (Not Applicable to the listed entity during the review period);

• (h) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021; (Not Applicable to the listed entity during the review period);

• (i) Securities and Exchange Board of India (Depositories and Participant) Regulation, 2018;

46, LGF, JOR BAGH, New Delhi-110003

Mob: 9953457413 Email id: Pragnyap.pradhan@gmail.com

PRACTICING COMPANY SECRETARIES

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PRAGNYA PRADHAN & ASSOCIATES

and Circulars/Guidelines issued 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/ guid elines including specific clause) Regulation / Circular No. Deviati -ons Action Taken by Type of Action Advisory/Clarifica tion / Fine/ Show Cause Notice/ Warning, etc. Details of Violation Fine Amou nt Observations / Remarks of the Practicing Company Secretary Manage -ment Response Rema rks NIL	Compliance Requirement (Regulations/ circulars/ guid elines including specific clause)	Regulation / Circular No.	Deviati -ons	Action Taken by	Type of Action Advisory/Clarifica tion / Fine/ Show Cause Notice/ Warning, etc.	Details of Violation	Fine Amou nt	Observations / Remarks of the Practicing Company Secretary	Manage -ment Response	Rema rks

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

Sr. No	Compliance Requirement (Regulations/ circulars / Guidelines including Specific clause)	Regulatio n / Circular No.	Deviations	Action Taken by	Type of Action Advisory/Clarifica tion / Fine/Show Cause Notice/ Warning, etc.	Details of Violation	Fine Amount	Observations / Remarks of the Practicing Company Secretary	Managem ent Response	Remar ks
Not Applicable

Mob: 9953457413 Email id: Pragnyap.pradhan@gmail.com

46, LGF, JOR BAGH, New Delhi-110003

PRAGNYA PRADHAN & ASSOCIATES PRACTICING COMPANY SECRETARIES

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(c ) I hereby report that, during the review period the compliance status of the listed entity with the following requirements:

Sr. No.	Particulars	Particulars	Compliance Status (Yes/No/NA)	Observations/ Remarks by 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	NA
2		Adoption and timely updation of the 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 has been reviewed & timely updated as per the regulations/circulars/ guidelines issued by SEBI	Yes	NA
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 the relevant document(s)/ section of the website.	Yes	NA
4		Disqualification of Director: None of the Director of the Company are disqualified under Section 164 of Companies Act, 2013	Yes	NA
5		To examine details related to Subsidiaries of listed entities: (a) Identification of material subsidiary companies (b) Requirements with respect to disclosure of material as well as other subsidiaries	Yes	NA

46, LGF, JOR BAGH, New Delhi-110003

Mob: 9953457413 Email id: Pragnyap.pradhan@gmail.com

PRACTICING COMPANY SECRETARIES

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PRAGNYA PRADHAN & ASSOCIATES

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	NA
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	As per SEBI LODR and the Companies Act, 2013 the Board Evaluation is required to be done once in a year. Formal process of Performance Evaluation was carried out in the Month of February, 2025 for FY 2024- 25.
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 obtained, the listed entity shall provide detailed reasons along with confirmation whether the transactions were subsequently approved / ratified/ rejected by the Audit committee.	Yes	NA
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	NA
10		Prohibition of Insider Trading: The listed entity is in compliance with Regulation 3(5) & 3(6) SEBI (Prohibition of Insider Trading) Regulations, 2015.	Yes	NA
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.	NA	No Actions were taken against the listed entity.

46, LGF, JOR BAGH, New Delhi-110003 Mob: 9953457413 Email id: Pragnyap.pradhan@gmail.com

PRACTICING COMPANY SECRETARIES

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PRAGNYA PRADHAN & ASSOCIATES

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 LODR Regulations by listed entities.	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 LODR Regulations by listed entities.	NA	No Resignation by Auditors in the listed entity or its material subsidiary.
13		Additional Non-compliances, if any: No any additional non-compliance observed for all SEBI regulation/circular/guidance note etc.	NA	NA

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 not verified the correctness and appropriateness of financial records and books of account of the listed entity.

4. This report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the SEBI (LODR) 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.

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For Pragnya Pradhan & Associates Place: New Delhi Company Secretaries Date: 13-05-2025 PRAGNYA Digitally signed by PRAGNYA PARIMITA PARIMITA PRADHAN UDIN:A032778G000325576 Date: 2025.05.13 PRADHAN 11:27:35 +05'30' (Pragnya Parimita Pradhan) ACS No. 32778 C P No.: 12030 Peer Review No: 1564/2021

46, LGF, JOR BAGH, New Delhi-110003 Mob: 9953457413 Email id: Pragnyap.pradhan@gmail.com