Kinetic Engineering Ltd. — Regulatory Filings 2021

Jun 30, 2021

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30[th] June, 2021

To The Manager - Corporate Relationship Department BSE Limited,

1st Floor, Phiroze Jeejeebhoy Towers, Fort, Mumbai- 400 001 Maharashtra, India

Scrip Code: 500240

Subject: Annual Secretarial Compliance Report for the financial year ended 31[st] March, 2021.

Reference Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015

Pursuant to the Regulation 24A of the SEBI (LODR) Regulations, 2015 read with the SEBI Circular No. CIR/CFD/CMD1/27/2019 dated February 08, 2019; please find enclosed the Annual Secretarial Compliance Report issued by Dinesh Birla & Associates, Company Secretaries, for the Financial Year ended 31[st] March, 2021.

This is for your information and records.

Thanking you, Yours sincerely,

For Kinetic Engineering Limited

AJINKYA Digitally signed by AJINKYA ARUNKUMAR FIRODIA DN: c=IN, o=Personal, 2.5.4.20=7bc23aea316b7516bdf3c6a696b0b56 e5ac3f7cb3b1bcb046b0412fdf98a9733, ARUNKUMA postalCode=411016, st=MAHARASHTRA, serialNumber=cbda1bee872ecc2356b1a03a95 8170c9d15ec3fad1cdcb53c501d47ebcaa03ab, R FIRODIA cn=AJINKYA ARUNKUMAR FIRODIA Date: 2021.06.30 12:49:11 +05'30'

Ajinkya A. Firodia Managing Director & CFO DIN:00332204

Encl: As above.

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M-504, MSR Queenstown, Opp. Chinchwad Station, Near Lokmanya Hospital, Udyog Nagar, Chinchwad, Pune - 411033. Mob. No. 9766693603 /7768893344 Email : csdineshbirla@gmail.com

DINESH BIRLA & ASSOCIATES COMPANY SECRETARIES

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To, The Board of Directors Kinetic Engineering Limited D 1 Block, Plot No. 18/2 Chinchwad, Pune 411019.

Sir/ Madam,

Annual Secretarial Compliance Report for the Financial Year 2020-21

We have been engaged by Kinetic Engineering Limited (hereinafter referred to as 'the Company') bearing CIN: L35912MH1970PLC014819 whose equity shares are listed on BSE Limited (Security Code: 500240) to conduct an audit in terms of Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended read with SEBI’s Circular No. CIR/CFD/CMD1/27/2019 dated 8[th] February, 2019 and to issue the Annual Secretarial Compliance Report thereon.

It is the responsibility of the management of the Company to maintain records, devise proper systems to ensure compliance with provisions of all applicable SEBI Regulations and circulars/ guidelines issued there under from time to time and to ensure that the systems are adequate and are operating effectively.

Our responsibility is to verify compliances by the Company with provisions of all applicable SEBI Regulations and circulars/ guidelines issued there under from time to time and issue a report thereon.

Our audit was conducted in accordance with Guidance Note on Annual Secretarial Compliance Report issued by the Institute of Company Secretaries of India and in a manner which involved such examinations and verifications as considered necessary and adequate for the said purpose. Annual Secretarial Compliance Report is enclosed.

For Dinesh Birla & Associates

Company Secretaries

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Dinesh Birla

Proprietor FCS: 7658, CP No. : 13029 UDIN: F007658C000545349

Place: Pune Date: 30.06.2021

M-504, MSR Queenstown, Opp. Chinchwad Station, Near Lokmanya Hospital, Udyog Nagar, Chinchwad, Pune - 411033. Mob. No. 9766693603 /7768893344 Email : csdineshbirla@gmail.com

DINESH BIRLA & ASSOCIATES COMPANY SECRETARIES

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Secretarial Compliance Report of Kinetic Engineering Limited for the year ended 31[st] March, 2021

I, Dinesh Shivnarayan Birla have examined:

• (a) all the documents and records made available to us by way of email in view of the prevailing pandemic situation of COVID-19 and explanation provided by Kinetic Engineering 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, 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;

• (b) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;

• (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 during the review period

M-504, MSR Queenstown, Opp. Chinchwad Station, Near Lokmanya Hospital, Udyog Nagar, Chinchwad, Pune - 411033. Mob. No. 9766693603 /7768893344 Email : csdineshbirla@gmail.com

DINESH BIRLA & ASSOCIATES COMPANY SECRETARIES

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• (e) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014; - Not applicable during the review period

• (f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008; - Not applicable 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 during the review period

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

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 matter referred below :

S.N.	Compliance Requirement (Regulations / circulars /guidelines including specific clause)	Detail of Deviations	Observations/ Remarks of the Practicing 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 (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.	Observation/ remarks of the Practicing Company Secretary, if any.
NIL	NIL	NIL	NIL	NIL

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

DINESH BIRLA & ASSOCIATES COMPANY SECRETARIES

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M-504, MSR Queenstown, Opp. Chinchwad Station, Near Lokmanya Hospital, Udyog Nagar, Chinchwad, Pune - 411033. Mob. No. 9766693603 /7768893344 Email : csdineshbirla@gmail.com

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
1.	As per Regulation 30 of the SEBI (LODR), Regulations, 2015 the intimation of the material events need to be given Stock Exchange within 24 hours but Company made delay of 14 days in Intimation of cessation of two Independent Directors due to end of their term of 5 years on 31stMarch, 2019.	31stMarch, 2020	The Company has, thereafter complied with this requirement within the timeline.

For Dinesh Birla & Associates Company Secretaries

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Dinesh Birla Proprietor FCS: 7658, CP No. : 13029 UDIN: F007658C000545349

Place: Pune Date: 30.06.2021