Fine-line Circuits Ltd. — Audit Report / Information 2020

Jun 27, 2020

PARIKH & ASSOCIATES Office

COMPANY SECRETARIES 111, 11[th ] Floor, Sai-Dwar CHS Ltd

Sab TV Lane, Opp Laxmi Industrial Estate, Off Link Road, Above Shabari Restaurant, Andheri (W), Mumbai : 400053 Tel No 26301232 / 26301233 / 26301240 Email : cs@parikhassociates.com parikh.associates@rediffmail.com

Secretarial Compliance Report of Fine-Line Circuits Limited for the year ended 31[st] March, 2020

To,

Fine-Line Circuits Limited 145, SDF-V, SEEPZ-SEZ, Andheri (East), Mumbai - 400096

We Parikh & Associates have examined:

• a) all the documents and records made available to us and explanation provided by Fine-Line Circuits 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 document/ filing, as may be relevant, which has been relied upon to make this certification,

for the year ended 31[st] March, 2020 (“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; (Not applicable to the Company 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; (Not applicable to the Company during the Review Period)

• e) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014; (Not applicable to the Company during the Review Period)

Parikh & Associates

Continuation Sheet

• f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008; (Not applicable to the Company during the Review Period)

• g) Securities and Exchange Board of India (Issue and Listing of Non-Convertible and Redeemable Preference Shares) Regulations, 2013; (Not applicable to the Company during the Review Period);

• h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;

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

and circulars/ guidelines issued thereunder;

and based on the above examination and considering the relaxations granted by the Ministry of Corporate Affairs and Securities and Exchange Board of India warranted due to the spread of the COVID-19 pandemic, 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. No.	Compliance Requirement (Regulations / circulars/ guidelines including specific clause)	Deviations	Observations/ Remarks of the Practicing Company Secretary
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• 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 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:

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. **
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Parikh & Associates

Continuation Sheet

• 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 ………. (The years are to be mentioned)	Actions taken by the listed entity, if any	Comments of the Practicing Company Secretary on the actions taken by the listed entity
Not Applicable

For Parikh & Associates

Digitally signed by Shalini Mohan Bhat Shalini DN: c=IN, o=Personal, postalCode=400066, st=Maharashtra, Place: Mumbai 2.5.4.20=afbb8b62a3fc7a6f597b838a41 e67b3f35671152f52a906871805154262 Mohan 7645b, Date: June 26, 2020 serialNumber=21ba97b2a337fa1d970ec0d9862b9ad295014e36d0ed3b79c9e21 6d2fa8d5a22, cn=Shalini Mohan Bhat Bhat Date: 2020.06.26 16:43:21 +05'30' Signature: Shalini Bhat

Partner

FCS No: 6484 CP No: 6994 UDIN: F006484B000385588