NEELKANTH LIMITED — Audit Report / Information 2021

Jun 30, 2021

RT EXPORTS

Date: 30^th June, 2021

To, The Secretary, Listing Department, BSE Limited Mumbai

Scrip Code: 512565

Sub: - Compliance under Regulation 24(A) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Dear Sir,

Pursuant to Regulation 24(A) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, please find enclosed copy of Annual Secretarial Compliance Report for the financial year ended 31^st March, 2021.

Kindly take the same on record.

Thanking you,

Yours truly,

For R.T. Exports Bhavik Bhimjyant ED Chairman & Managing Director DIN: 00160121

Encl: As above

R T EXPORTS LIMITED

508, Dalamal House, Jamnalal Bajaj Marg, Nariman Point, Mumbai 400021. T: 022 408 13000 Email: headoffice@neelkanthrealty.com CIN: L51900MH1980PLC022582

To, The Board of Directors R T Exports Limited CIN: L51900MH1980PLC022582 508, Dalamal House, Nariman Point, Mumbai 400021

Sir / Madam,

Annual Secretarial Compliance Report for the Financial Year 2020-21

We have been engaged by R T Exports Limited (hereinafter referred to as 'the Company) bearing CIN: L51900MH1980PLC022582 whose Equity Shares are listed on BSE Limited 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 08/02/2019 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.

Due to the pandemic caused by COVID-19 and prevailing lockdowns/ restrictions on movement of people imposed by the Government, for the purpose of issuing this report we have conducted our audit remotely based on the records and information made available to us by the Company electronically.

Annual Secretarial Compliance Report is enclosed

For Rohit S Karulkar & Associates

Proprietor FCS: 7155; CoP No. 18601 ROHIT SHRIPAD KARULKAR Digitally signed by ROHIT SHRIPAD KARULKAR Date: 2021.06.30 18:39:33 +05'30'

Dated: 30/06/2021

Place: Thane

SECRETARIAL COMPLAINCE REPORT OF

R T EXPORTS LIMITED

FOR THE YEAR ENDED 31ST MARCH 2021

To, The Members R T Exports Limited

• 1. We, M/s. Rohit S Karulkar & Associates, Company Secretaries, having our office at 102, Tushar Apartment, Sane Guruji Path, Naupada, Thane West – 400602 have examined:
• (a) all the documents and records made available to us and explanation provided by R T Exports 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 documents / filing, as may be relevant, which has been relied upon to make this certification

for the year ended 31st 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 Contract (Regulations) 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 as there were no events occurred requiring company to comply under the stated provisions during the period under review.

(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 there were no events occurred requiring company to comply under the stated provisions during the period under review.

(e) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014

Not applicable as there were no events occurred requiring company to comply under the stated provisions during the period under review.

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

Not applicable as there were no events occurred requiring company to comply under the stated provisions during the period under review.

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

Not applicable as there were no events occurred requiring company to comply under the stated provisions during the period under review.

• (h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
• (i) Securities and Exchange Board of India (Depository Participants) Regulations, 1996 & 2018.

and circulars/ guidelines issued thereunder and based on the abovementioned examination, We report that, during the Review Period

(a) The listed entity has complied with the provisions of the above Regulations and circulars/ guidelines issued thereunder as applicable to it, except in respect of matters specified below:

Serial No.	Compliance Requirement (Regulations/ circulars/ guidelines including specific clause)	Deviations	Observations/ Remarks of the Practicing Company Secretary
1	Regulation 6(1) of SEBI (LODR) Regulations, 2015 A listed entity shall appoint a qualified company secretary as the compliance officer	The Company Secretary and Compliance Officer of the Company has resigned w.e.f 07/01/2020 and the vacancy has been filled on 16/08/2020.	The company was in process to fill the vacancy of Company Secretary and Compliance Officer for the Company but was unable to find the right candidate due to the ongoing pandemic situation globally.
2	Reg. 46 Website	Website of the company not updated as per the provisions of Reg. 46.	The Company is in the process of updating its website.

• (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 our examination of those records
• (c) No action was required to be 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 or by Stock Exchanges through various circulars) under the aforesaid Acts / Regulations and circulars / guidelines issued thereunder.
• (d) The reporting of actions by the listed entity to comply with the observations made in previous reports does not arise during the review period.

For Rohit S Karulkar & Associates Company Secretaries Rohit Karulkar FCS 7155; CoP: 18601 ROHIT SHRIPAD KARULKAR Digitally signed by ROHIT SHRIPAD KARULKAR Date: 2021.06.30 18:40:11 +05'30'

UDIN: F007155C000555780