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MODULEX CONSTRUCTION TECHNOLOGIES LIMITED Regulatory Filings 2025

May 28, 2025

62866_rns_2025-05-28_2926d4c6-a683-43ac-a475-48fe1e06c6f3.pdf

Regulatory Filings

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28[th] May, 2025 Ref.: MCTL/2025-26/BSE-009

The Manager Department of Corporate Services BSE Limited Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai - 400 001.

Security ID: MODULEX

Scrip Code: 504273

Sub: Annual Secretarial Compliance Report for the Financial Year ended 31[st] March, 2025 as per Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Dear Sir/Madam,

Pursuant to Regulation 24A of SEBI (Listing Obligations and Disclosure Requirement) Regulations, 2015, Please find enclosed herewith the Annual Secretarial Compliance Report from Practicing Company Secretary for the Financial Year ended 31[st] March, 2025.

Please take the same on your record.

Thanking you,

Yours faithfully,

For Modulex Construction Technologies Limited

Digitally signed Bhoomi by Bhoomi Mewada Mewada Date: 2025.05.28 10:10:55 +05'30'

Bhoomi Mewada Company Secretary and Compliance Officer

Encl: As above

Modulex Construction Technologies Limited t/a Modulex CIN: L25999PN1973PLC182679 Registered Office: A-82, MIDC Industrial Estate, Indapur – 413 132, Maharashtra BSE Security Code: 504273 BSE Security ID: MODULEX

Website - www.modulex.in Email - [email protected] Contact - Tel: +91 2111 299 061

CS HITESH J. GUPTA B.Com, ACS

PRACTICING COMPANY SECRETARY

Mobile: +91 9619454784

Email: [email protected]

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Secretarial Compliance Report of Modulex Construction Technologies Limited (CIN: L25999PN1973PLC182679) for the financial year ended as on 31[st] March, 2025

I, Hitesh J. Gupta, Practicing Company Secretary have examined:

  • a) all the documents and record made available to us and explanation provided by Modulex Construction Technologies Limited (hereinafter referred ‘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 Report.

for the financial year ended as on 31[st] March, 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 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 as the Company has not bought back/proposed to buy-back any of its securities during the financial year ended 31[st] March, 2025 under review ;

  • e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021; Not applicable as the Company has not issued shares to the employee during the financial year ended 31[st] March, 2025 under review;

Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067

HITESH Digitally signed by HITESH JAGDAMKUMAR JAGDAMKUMAR GUPTA Date: 2025.05.27 22:48:19 +05'30' GUPTA

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CS HITESH J. GUPTA B.Com, ACS

PRACTICING COMPANY SECRETARY

Mobile: +91 9619454784

Email: [email protected]

  • f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021 - Not Applicable as the Company has not issued or listed any NonConvertible Securities during the financial year ended as on 31[st] March, 2025 under review;

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

  • h) Other Regulations as applicable.

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/
guidelines
including
specific
clause)
Regul
ation/
Circul
ar No.
Deviations Action
Taken
by
Type of
Action
Detail
s of
Violati
on
Fine
Amount
Observati
ons/
Remarks
of the
Practicing
Company
Secretary
Manageme
nt
Response
Remarks
1. Regulation 33
of SEBI LODR
Reg-33 Late
submission
March 2024
BSE
levied
SOP
Fines
Impositio
n of SOP
Fine
Late
submi
ssion
of
report
by
36
days
Rs.
1,80,000/
-
Late
submissio
n of report
by 36 days
Delay
in
submission
of
the
results
happened
due
to
unavoidable
circumstanc
es
,
Managemen
t has taken
necessary
actions
to
submit
the
compliance
s in a timely
manner
Company
has duly
paid
the
fine
imposed
by BSE.

HITESH Digitally signed by HITESH JAGDAMKUMAR JAGDAMKU GUPTA Date: 2025.05.27 MAR GUPTA 22:48:43 +05'30'

Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067

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CS HITESH J. GUPTA B.Com, ACS

PRACTICING COMPANY SECRETARY

Mobile: +91 9619454784

Email: [email protected]

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

Sr.
No.
Observations/
Remarks of the
Practicing
Company
Secretary (PCS)
in the previous
reports)
Observations
made in the
Secretarial
Compliance
report for the
year
ended
March 31, 2024
Compliance
Requirement
(Regulations/
circulars/
guidelines
including
specific
clause)
Details of violation /
Deviations
and
actions
taken
/penalty
imposed, if any, on
the listed entity
Remedial actions, if
any, taken by the
listed entity
Comments
of
the
PCS on the actions
taken by the listed
entity
1. Late submission
of report by 85
days
Late submission
of report by 85
days
Reg - 33 Late submission of
report by 85 days
June- 23
BSE levied SOP Fines
Rs. 4,25,000/-
The Company has
submitted
all
the
results
on
time
expect the Q4 as on
31stMarch, 2024.
Comp any has
duly paid the fine
imposed by BSE.
2. Late submission
of report by 21
days
Late submission
of report by 21
days
Reg - 33 Late submission of
report by 21 days
September-23
BSE levied SOP Fines
Rs. 1,05,000/-
The Company has
submitted
all
the
results
on
time
expect the Q4 as on
31stMarch, 2024.
Company has
Duly paid the fine
imposed by BSE.

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

Sr.
No
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 of India
(ICSI).
Yes NA

Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067

HITESH JAGDAMKUMAR Digitally signed by HITESH JAGDAMKUMAR GUPTA GUPTA Date: 2025.05.27 22:48:58 +05'30'

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CS HITESH J. GUPTA B.Com, ACS

PRACTICING COMPANY SECRETARY

Mobile: +91 9619454784

Email: [email protected]

Sr.
No
Particulars Compliance
Status
(Yes/
No/ NA)
Observations/ Remarks
by PCS*
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 have
been reviewed & updated on
time, 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
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
documents(s)/section
of
the
website
Yes NA
4. Disqualification of Director(s):
None of the director(s) of the listed entity
is/ are disqualified under Section 164 of
Companies Act, 2013 as confirmed by
the listed entity.
Yes NA
5. Details related to subsidiaries of listed
entities have been examined w.r.t.:
(a) Identification of material subsidiary
companies
(b) Disclosure requirement of material as
well as other subsidiaries.
Yes NA

Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067

HITESH Digitally signed by HITESH JAGDAMKUMAR JAGDAMKUMAR GUPTA Date: 2025.05.27 22:49:15 GUPTA +05'30'

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CS HITESH J. GUPTA B.Com, ACS

PRACTICING COMPANY SECRETARY

Mobile: +91 9619454784

Email: [email protected]

Sr.
No
Particulars Compliance
Status
(Yes/
No/ NA)
Observations/ Remarks
by PCS*
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/during
the
financial
year
as
prescribed in SEBI Regulations.
Yes NA
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.
No 1. The
disclosure
regarding
appointment of
Mr. Jayesh Sheth
(DIN: 03506031)
as an Additional
Director
(Non-
Executive
Independent
Director) of the
Company
effective July 25,
2024 was made

Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067

Digitally signed by HITESH HITESH JAGDAMKUMAR JAGDAMKUMAR GUPTA GUPTA Date: 2025.05.27 22:49:32 +05'30'

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CS HITESH J. GUPTA B.Com, ACS

PRACTICING COMPANY SECRETARY

Mobile: +91 9619454784

Email: [email protected]

Sr.
No
Particulars Compliance
Status
(Yes/
No/ NA)
Observations/ Remarks
by PCS*
after a delay of 12
hours, exceeding
the
timeline
prescribed under
the
applicable
regulation.
2. The
disclosure
regarding
the
change
in
designation
of
Mr. Aditya Vikram
Kanoria
(DIN:
07002410) from
Non-Executive
Independent
Director to Non-
Executive
Non-
Independent
Director of the
Company
effective July 25,
2024 was made
after a delay of 12
hours, exceeding
the
timeline
prescribed under
the
applicable
regulation.
10. Prohibition of Insider Trading:
The listed entity is in compliance with
Regulation 3(5) & 3(6) of SEBI (Prohibition
of Insider Trading) Regulations, 2015
Yes NA
11. Actions taken by SEBI or Stock Exchange
(s). if any:
No action(s) has been taken against the
listed entity/ its promoters/ directors/
subsidiaries either bySEBI or byStock
Yes NA

Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067

Digitally signed by HITESH JAGDAMKUMAR GUPTA Date: 2025.05.27 22:49:50 +05'30'

HITESH JAGDAMKUMAR GUPTA

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CS HITESH J. GUPTA B.Com, ACS

PRACTICING COMPANY SECRETARY

Mobile: +91 9619454784

Email: [email protected]

Sr.
No
Particulars Compliance
Status
(Yes/
No/ NA)
Observations/ Remarks
by PCS*
Exchanges (including under the Standard
Operating Procedures issued by SEBI
through various circulars) under SEBI
Regulations and circulars/ guidelines
issued thereunder (or)
The actions taken against the listed
entity/
its
promoters/
directors/
subsidiaries either by SEBI or by Stock
Exchanges are specified in the last
column.
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 bylisted entities.
N.A. There were no instances
of
resignation
of
statutory auditors of the
Company
and/or
its
subsidiaries during the
Review Period /No such
instance was reported
during the review period
13. Additional Non-compliances, if any:
No additional non-compliances
observed for any SEBI
regulation/circular/guidance note etc.
except as reported above.
N.A. NA

*Observations /Remarks by PCS are mandatory if the Compliance status is provided as ‘No’ or ‘NA’

I further, report that the listed entity is in compliance/ not in compliance with the disclosure requirements of Employee Benefit Scheme Documents in terms of regulation 46(2) (za) of the LODR Regulations – N.A.

HITESH Digitally signed by HITESH JAGDAMKUMAR JAGDAMKUM GUPTA Date: 2025.05.27 AR GUPTA 22:50:05 +05'30'

Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067

PRACTICING COMPANY SECRETARY

Mobile: +91 9619454784

Email: [email protected]

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CS HITESH J. GUPTA B.Com, ACS

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. My responsibility is to report based upon our examination of relevant documents and information. This is neither an audit nor an expression of opinion.

  3. I 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.

Place: Mumbai Date: May 27, 2025

HITESH Digitally signed by HITESH JAGDAMKUMAR GUPTA JAGDAMKUMAR Date: 2025.05.27 22:50:23 GUPTA +05'30'

Hitesh J. Gupta M No. A33684 CP No.12722 UDIN: A033684G000461001 PR No.: 1874/2022

Regd. Off. – B/701, Astor Place Building, Sector No. 3, Charkop, Kandivali West, Mumbai – 400067