Nitco Ltd. — Regulatory Filings 2026

May 21, 2026

NITCO
TILES MARBLE MOSAICO
NITCO/SE/2026-27/12
May 21, 2026

To,

Corporate Service Department	The Listing Department
BSE Limited	National Stock Exchange of India Limited
Jeejeebhoy Towers	Exchange Plaza, Bandra Kurla Complex, Bandra (E),
Dalal Street,	Mumbai – 400 051
Mumbai – 400 001	Script code: NITCO
Script code: 532722

Dear Sir/Madam,

Sub: Annual Secretarial Compliance Report for the Financial Year ended March 31, 2026

Ref: Intimation under Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015

Pursuant to Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, read with SEBI Master Circular H0/49/14/14(7)2025-CFD-POD2/1/3762/2026 dated January 30, 2026, as amended, please find enclosed herewith the Annual Secretarial Compliance Report of NITCO Limited for the financial year ended March 31, 2026, issued by M/s. Mihen Halani & Associates, Practicing Company Secretaries, Mumbai.

Kindly take the above report on your records.

Thanking You,

Yours faithfully,

For Nitco Limited

RUPALI Digitally signed by
RUPALI DANIEL
SWAMI KAMBLI
KAMBLI DIAN ZOJHJOL21
KAMBLI HI ELAN +07:07

Rupali Kambli
Company Secretary & Compliance Officer

Encl.: As above

Registered Office: NITCO Limited, 3/A, Recondo Compound, Sudam Kalu Ahire Marg, Glaxo, Worli Colony, Mumbai, Maharashtra, India, 400 030. Tel.: 91-22-25772800 | 25772790. CIN: L26920MH1966PLC016547.
Email: investorgrievances@nitco.in Website: www. nitco.in
TUV NORD
TUV NORD
World Health Organization

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MIHEN HALANI & ASSOCIATES

Practicing Company Secretaries

312, Kalpataru Avenue CHS LTD, Opp. Employees State Insurance Scheme Hospital, Akurli Road, Kandivali (East), Mumbai - 400 101, ☎: 022 - 4516 5109 ✉: mihenhalani@mha-cs.com

Annual Secretarial Compliance Report of NITCO Limited for the year ended March 31, 2026

To,

The Board of Directors,

NITCO LIMITED

CIN: L26920MH1966PLC016547

3/A, Recondo Compound, Sudam Kalu Ahire Marg, Glaxo,

Worli Colony, Mumbai -400030, MH, IN

BSE Scrip Code: 532722 / NSE Symbol: NITCO / ISIN: INE858F01012

We, M/s. Mihen Halani & Associates have examined:

a) all the documents and records made available to us and explanation provided by Nitco 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, 2026 ("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) The Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;
c) The Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
d) The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021;
f) The Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021- (Not applicable during the period under review);
g) The Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 1993 regarding the Companies Act and dealing with client;
h) The Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2021 - Not Applicable to the listed entity during the period under review;
i) The Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018 - Not Applicable to the listed entity during the period under review, and
j) The Securities and Exchange Board of India (Depositories and Participants) Regulations, 2018.

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MIHEN HALANI & ASSOCIATES

Practicing Company Secretaries

and circulars / guidelines issued thereunder; and based on the above examination, we hereby report that, during the Review Period:

1. 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)	Regulations / Circular No	Deviations	Action taken by	Type of action	Details of Violation	Fine Amount	Observations / remarks of the Practicing Company Secretary	Management Response	Remarks
1.	100% Dematerialization of Promoters Holding	Regulation 31(2) of SEBI (LODR) Regulations, 2015	Non-Compliance of Regulation 31(2) of SEBI (LODR) Regulations, 2015	-	-	-	-	Out of total shareholding of promoter and promoter group, 4,242 Equity shares i.e. 0.01% of the total shareholding of promoter category is not in dematerialized form as required under Regulation 31(2) of SEBI (LODR) Regulations, 2015.	The Company along with promoters is taking appropriate steps for dematerialization of 4,242 Equity Shares held by promoter group. Please note that certain promoter entities holding shares in physical form were established decades ago. In one instance, the founding senior member of such an entity passed away, and	-

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MIHEN HALANI & ASSOCIATES

Practicing Company Secretaries

									their PAN Details were not available. The same resulted in non-conversion of physical shares into demat form.

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

Sr. No	Observations / Remarks of the Practicing Company Secretary in the previous reports	Observations made in the secretarial compliance report for the year ended	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.	100% Dematerialization of Promoters Holding	Regulation 31(2) of SEBI (LODR) Regulations, 2015	Non-Compliance of Regulation 31(2) of SEBI(LODR) Regulations, 2015	-	-	-

c) we 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 the Practicing Company Secretary
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	NONE
2.	Adoption and timely updating of the Policies:
• All applicable policies under SEBI Regulations are adopted with the approval of board of directors of the listed entities;	YES	NONE

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MIHEN HALANI & ASSOCIATES

Practicing Company Secretaries

	• All the policies are in conformity with SEBI Regulations and has been reviewed & updated as per the regulations / circulars / guidelines issued by SEBI.
3.	Maintenance and disclosures on Website:
• The Listed entity is maintaining a functional website;
• Timely dissemination of the documents / information under a 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 document(s) / section of the website.	YES	NONE
4.	Disqualification of Director:
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	NONE
5.	Details related to Subsidiaries of listed entities:
(a) Identification of material subsidiary companies;
(b) Disclosure requirement of material as well as other subsidiaries.	NA	NONE
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	NONE
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 as prescribed in SEBI Regulations.	YES	NONE
8.	Related Party Transactions:
(a) The listed entity has obtained prior approval of Audit Committee for all Related party transactions;
(b) The listed entity has provided detailed reasons along with confirmation	YES
NA	NONE

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MIHEN HALANI & ASSOCIATES

Practicing Company Secretaries

	whether the transactions were subsequently approved / ratified / rejected by the Audit Committee, in case no prior approval has been obtained.
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.	YES	NONE
10.	Prohibition of Insider Trading:
The listed entity is in compliance with Regulation 3(5) & 3(6)SEBI (Prohibition of Insider Trading) Regulations, 2015.	YES	NONE
11.	Actions taken by SEBI or Stock Exchange(s), if any:
No Actions taken against the listed entity / its promoters / directors / subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under SEBI Regulations and circulars / guidelines issued thereunder.	YES	NONE
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) have / 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 by listed entities.	NA	No such event occurred during the reporting period. Hence, the same is not applicable
13.	Additional non-compliances, if any:
No additional non-compliance observed for all SEBIregulation / circular / guidance note etc. except as reported above.	NO	NONE

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. Our responsibility is to report based upon our examination of relevant documents and information. This is neither an audit nor an expression of opinion.
3. We have not verified the correctness and appropriateness of the financial Records and Books of Accounts of the listed entity.

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MIHEN HALANI & ASSOCIATES

Practicing Company Secretaries

1. This Report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the SEBI (Listing Obligations and Disclosure Requirements) 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.

For MIHEN HALANI & ASSOCIATES

Practicing Company Secretaries

Date: May 13, 2026

Place: Mumbai

UDIN: F009926H000354732

MIHEN

JYOTINDRA

HALANI

Mihen Halani

(Proprietor)

CP No: 12015

FCS No: 9926

PR No. 6925/2025