Miven Machine Tools Ltd. — Regulatory Filings 2021

Jun 27, 2021

==> picture [458 x 111] intentionally omitted <==

June 27, 2021 BSE Limited 24th Floor, P J Towers, Dalal Street, Fort Mumbai-400001

Submitted electronically through BSE Listing Centre

Dear Sir,

Sub: Submission of Annual Secretarial Compliance Report for the Financial Year 202021

Ref: Scrip Code: 522306

As you are aware all listed entities on an annual basis are required to arrange to conduct a verification by a Practicing Company Secretary(“PCS”) on compliance of all applicable SEBI Regulations and circulars/ issued thereunder, consequent to which, the PCS shall submit the Annual Secretarial Compliance Report (“ASCR”) in the manner and format specified in the SEBI circular mentioned above. The listed entity shall submit the ASCR to the stock exchanges within 60 days of the end of the financial year in the manner specified in the SEBI circular mentioned above. The due date for submission for the financial year 2020-21 has been extended to June 30, 2021 by SEBI on account of continuing COVID 19 pandemic.

Accordingly, we wish to inform you that the Company has received the Annual Secretarial Compliance Report (“ASCR”) for the Financial Year 2020-21 from Mr. Umesh P Maskeri, Practicing Company Secretary in the format stipulated in the Circular issued by SEBI referred to Above.

We are submitting the said ASCR dated June 27, 2021 which was placed and approved by the Board of Directors at the meeting held on June 24, 2021.

Yours faithfully For Miven Machine Tools Limited,

Digitally signed ARPITA by ARPITA RAHUL RAHUL DHAKANE DHAKANE Date: 2021.06.27 20:17:49 +05'30'

Arpita Dhakane Company Secretary and Compliance Officer

2

Umesh P. Maskeri Practicing Company Secretary

==> picture [57 x 59] intentionally omitted <==

No 304, Geetanjali Heights, Plot No.77, Sector 27 Near Presentation Convent School, Nerul East, Navi Mumbai–400 706 Tele 022 -27716919; Mobile: 09930178352; Email: umeshmaskeri@gmail.com

ANNUAL SECRETARIAL COMPLIANCE REPORT For the Financial Year ended March 31, 2021 Pursuant to Circular No CIR/CFD/CMD1/27/2019 dated February 8, 2019 Issued by the Securities and Exchange Board of India

To

The Board of Directors Miven Machine Tools Limited Registered Office, Tarihal Industrial Area, Tarihal HUBLI-580026

Dear Sir,

• I, Mr. Umesh P Maskeri, Practicing Company Secretary, have examined:

• a) All the documents and records made available to me and explanation provided by Miven Machine Tools 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

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 there under; and

• b) the Securities Contract (Regulation) Act, 1956 (“SCRA”), rules made thereunder and the Regulations, Circulars, guidelines issued thereunder by the Securities and Exchange Board of India (“SEBI”);

The specified 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;

1

Umesh P. Maskeri Practicing Company Secretary

==> picture [58 x 61] intentionally omitted <==

• (e) Securities and Exchange Board of India (Share Based Employees Benefits) Regulations, 2014;

• (f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008;

• (g) Securities and Exchange Board of India (Issue and Listing of Non-convertible and Redeemable Preference Shares) Regulations, 2013;

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

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

And circulars/guidelines issued thereunder;

And based on the above information, 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 the following matters;.

Sl No	Compliance requirement (Regulations/Circulars/guidelines including specific clause)	Deviations	Observations/ Remarks of the Practicing Company Secretary
NIL

• (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 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 Instructions issued by SEBI through various circulars) under the aforesaid Acts/Regulations and circulars/guidelines issued thereunder:

Sl. 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
No such action was taken against the listed entity / its promoters/ directors/material subsidiaries either by SEBI or by Stock Exchanges by SEBI

2

Umesh P. Maskeri Practicing Company Secretary

==> picture [58 x 61] intentionally omitted <==

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

Sl No	Observations of the Practicing Company Secretary in the previous reports	Observations made in the secretarial compliance report for the year ended March 31, 2019 and March 31, 2020	Action taken by the listed entity, if any	Comments of the Practicing Company Secretary on the actions taken by the listed entity
There were no adverse observations and hence no action was warranted by the listed entity

UMESH Digitally signed by UMESH PARAMES PARAMESHWAR HWAR MASKERI Date: 2021.06.27 MASKERI 19:47:17 +05'30'

UMESH P MASKERI PRACTICING COMPANY SECRETARY FCS No 4831 COP No. 12704 ICSI UDIN F004831C000523371 (This document has been digitally signed)

Place: Mumbai Da te : June 27, 2021

==> picture [82 x 79] intentionally omitted <==

Note:

This report is to be read with my letter of even date which is annexed as ANNEXURE I and forms an integral part of this report .

3

Umesh P. Maskeri Practicing Company Secretary

==> picture [58 x 61] intentionally omitted <==

ANNEXURE I

To The Members of : Miven Machine Tools Limited Registered Office, Tarihal Industrial Area, Tarihal HUBLI-580026

Our report of even date is to be read along with this letter:

1. Compliance with the provisions of SEBI (Listing Obligations and disclosure Requirements) Regulations, 2015 and the SEBI regulations and Circulars is the responsibility of the management of the Company. My responsibility is to express an opinion on these compliances based on our audit.

2. I have followed the audit practices and processes as were appropriate to obtain reasonable assurance about the correctness of the contents of the compliance of SEBI LODR, SEBI regulations and SEBI Circulars. The verification was done on test basis to ensure that correct facts are reflected in the compliance records. I believe that the processes and practices, we followed provide a reasonable basis for our opinion.

3. I have not verified the correctness and appropriateness of financial records and Books of Accounts of the Company.

4. Wherever required, I have obtained the management representation about the compliance of laws, rules and regulations and happening of events etc.

5. The compliance of the provisions of corporate and other applicable laws, rules, regulations, standards is the responsibility of management. My examination was limited to the verification of SEBI LODR and other SEBI regulations on test basis.

6. The Secretarial Compliance Report is neither an assurance as to the future viability of the Company nor of the efficacy or effectiveness with which the management has conducted the affairs of the Company.

UMESH Digitally signed by UMESH PARAMES PARAMESHWAR HWAR MASKERI Date: 2021.06.27 MASKERI 19:47:42 +05'30'

UMESH P MASKERI PRACTICING COMPANY SECRETARY FCS No 4831 COP No. 12704

(This document has been digitally signed)

==> picture [72 x 69] intentionally omitted <==

Place: Mumbai Date : June 27, 2021

4