Indokem Ltd — Audit Report / Information 2021

May 29, 2021

indokem fimittd

(CIN NO.: L31300MH1964PLC013088)

Registered Office : "KHATAU HOUSE", Ground Floor. Mogul Lane, Mahim (West}, Mumt:>ai - 400 016.

Phone :61236767 Fax :61236718 Website : www.indokem.co.in

29th May, 2021

To, The Bombay Stock Exchange Limited, Corporate Relations Department 1st Floor, New Trading Ring, Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai - 400 001

Scrip Code: 504092

Subject: Submission of Annual Secretarial Compliance Report for the year ended 31st March, 2021 under Regulation 24(A) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Respected Sir/ Madam,

Pursuant to Regulation 24(A) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, we send herewith, Annual Secretarial Compliance Report for the year ended 31st March, 2021 issued by Ragini Chokshi & Co., Company Secretaries.

Request you to kindly take the same on records.

Thanking You

Yours Truly,

For INDOKEM LIMITED

Rajesh D. Pisal Company Secretary and Compliance Officer

Encl: a/a

LN Ragini Chokshi & Co. 022-2283 ¹¹³⁴

Company Secretaries

34, Kamer Building, Sth Floor, 38 Cawasji Patel Street, Fort, Mumbai - 400 001. E-mail : sein pith Ory paladin web: csraginichokshi.com

SECRETARIAL COMPLIANCE REPORT OF INDOKEM LIMITED

FOR THE YEAR ENDED MARCH 31, 2021

[Under Regulation 24A of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015]

We have examined:

• (a) all the documents and records made available to us and explanation provided by INDOKEM 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 March 31, 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;

• . Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;(Not Applicable to the Company during the Audit Period)
• . Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
• . Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (Not Applicable to the Company during the Audit Period)
• . Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014; (Not Applicable to the Company during the Audit Period)
• . Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008; (Not Applicable to the Company during the Audit Period)
• . 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 Audit Period)
• . Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
• . Securities and Exchange Board of India (Depositories & Participants) Regulations, 2018. (To the extent applicable);

Regulations, 2014; (Not Applicable to the Company during the Audit Period)
. Securities and Exchange Board of India (Issue and Listing of Debt Securities)
Regulations, 2008; (Not Applicable to the Company during the Audit Period)
. 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 Audit Period)
Exchange Board and (Prohibition . Securities India of	Trading) Insider of
Regulations, 2015;
Securities and Exchange Board of India (Depositories	& Participants)
Regulations, 2018. (To the extent applicable);
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:-
Compliance Deviations Sr.	Observations/ Remarks of the
Requirement	Practicing Company Secretary
No. (Regulations/circular s/guidelines
including specific clause)
1 Regulation 30 The of	disclosures There was a delay of 71 Minutes
outcome Securities and of of and	Minutesin submitting 54
Exchange Board of board India (Listing held on 16% July, meeting held on 16	meeting theoutcome/ disclosure of Board
Obligations and & 12020 25th	July, 2020
August, Disclosure 2020

Requirements) Regulations, 2015 The listed entity shall in delay.	were to stock exchange provided	Company submitted However, the explanation the that happened incidences these at
make disclosures of		the time of lockdown prevailing due to COVID 19 crises where
material events to the
exchange, stock which are specified in		Company and Statutory its working Auditors were from
Part A of Schedule III within 30 minutes of board closure of meeting		different locations resulting into communication gap because of connectivity internet and technical issues.
		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 my/our examination of those records.
promoters/ directors/	material subsidiaries	The following are the details of actions taken against the listed entity /its either by SEBI or by Stock
circulars/ guidelines issued thereunder:		Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under the aforesaid Acts/Regulations and

• 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 my/our examination of those records.
• 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:

exchange, stock which are specified in Part A of Schedule III within 30 minutes of board closure of meeting		Company Auditors internet technical issues.	and Statutory its working were from different locations resulting into communication gap because of connectivity and
promoters/ directors/ circulars/ guidelines issued thereunder:	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 my/our examination of those records. The following are the details of actions taken against the listed entity /its material subsidiaries Exchanges (including under the Standard Operating Procedures issued SEBI through various circulars) under the aforesaid Acts/Regulations and	either by	SEBI or by Stock by
the Practicing Company	Sr.No. Observations of Observations made Actions Comments of the in the secretarial compliance report the listed Secretary in the for the year ended entity, if previous reports (The years are to be mentioned)	taken by any	Practicing Company Secretary on the actions taken by the listed entity
	There are no such matters during the year under review

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 secretarial compliance report for the year ended (The years are to be mentioned)	Actions made in the taken by the listed entity, if any	Comments of the Practicing Company Secretary on the actions taken by the listed entity
		2020	None	None

Place: Mumbai

Date: 21/05/2021 For Ragi i Chokshi & Co. Company Secretaries

CP No: 9031 ACS: 11872

UDIN: A011872C000354711