Prime Securities Ltd. — Regulatory Filings 2021

Jun 30, 2021

30,2021 Limited Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai 40000 I

Dear Sir I Madam,

National Stock Exchange oflndia Limited Exchange Plaza, 5th Floor, Plot No. CII, G Block, Bandra Kurla Complex, Bandra (East), Mumbai 400051

• Su b: Regulation 24A of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("Listing Regulations")
• Re: Stock Code: 500337 (BSE) I PRIMESECU (NSE)

Pursuant to the provisions of Regulation 24A of Listing Regulations read with SEBI Circular CIRJCFD/CMDl12712019 dated February 8, 2019, we are enclosing herewith the Annual Secretarial Compliance Report dated June 24, 2021 , of the Company for the Year ended March 3 I , 2021 , issued by MIs. Pramod Shah & Associates, Practising Company Secretaries.

This is for your information and records.

Thanking you,

Yours faithfully,

For Prime Securities Limited

Prime Securities Limited 1109 / 1110, Maker Chambers V, Nariman Point, Mumbai 400 02l. CIN: L67120MH1982PLC026724 Website: www.primesec.com

Tel: +91-22-6184 2525 Fax: +91-22-2497 0777 •

•

Pramod S. Shah & Associates Practising Company Secretaries 3rd Floor, LA-SHEWA Bldg., Next to Fedex, 233, P.D, Mello Road, Opp. St. George Hospital, Near CST, Mumbai - 400001. TeI.: 91-22-2271 7700/ 91-22-22701040 * Email: saurabhshah@psaprofessionals.com*Website:cspsa.co.in

Secretarial compliance report of Prime Securities Limited for the year ended 31st March, 2021

We have examined:

• a) all the documents and records made available to us and explanation provided by Prime Securities Limited (the Company");
• L) LIlt.! flling.':!/ ,IjUbl'I'dt-blull::' Hlddlo! LI)' LiLt:! l1sll:'d ertHty to th~ !;t()ck exchanges;
• c) website of the Company;
• d) any other document/ 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 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 c.irculars/ guidelines issued thereunder, have been examined, include:-

• a) Securities and Exchange Board of India (Listinij Obligations and Disclosure RPwquinnnnntr.) Rogulationo, 2015;
• b) Sl!LUl iLil!ti IlIld 1-'>"-,, '11 I1ng"= BCICln.:l 01 Illdld (l~ ~;Ull ()I ( ::lpH:.l.l Gild Dhclosnre Requirements) Regulations, 201 11;
• c) The t;ecuriLies allll Exdlangp. KO(lrn ot fndiCl (Merchant Bankers) l<.eguiations, 1992 and amendments made from time to time;

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Pramod S. Shah & Associates Practising Company Secretaries

3rd Floor, LA-SHEWA Bldg., Next to Fedex, 233, P.D, Mello Road, Opp. St. George Hospital, Near CST, Mumbai - 400001. Tel.: 91-22-2271 7700/ 91-22-22701040 * Email: saurabhshah@psaprofessionais.com*Website:cspsa.co.in

• d) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
• e) Securitiec and Exchange Board of India (Buyback of Securities) Regulations, 2018 Not Applicable to the Company dunng the l{eview Ferl0d;
• t) SecuritiQc ;1nd E)(chan8c Boord of Tndin (F";hnl'{l Bn,g.?d Umpk'yee Dellefib) Regulations, 2014;
• g) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008 - Not Applicable to the Company during the Review Period;
• h) Securities and Exchange Board of India (Issue and Listing of Non- Convertible and Redeemable Preference Shares) Regulations, 2013 - Not Applicable to the Company during the Reviev\T Pedod;
• i) Securities and Exchange Board ot India (Prohibition of Insider Trading) Regulations, 2015;
• j) any other regulations and circulars/ guidelines issued thereunder; as may be applicable to the Company.

and based on the above examination, we hereby report that, during the Review Period:

a) The Company has complied with the provisions of the above Regulations and circulars/ guidelines issued therew1Cler, except in respect of matters specified below:-

Serial	Compliance Requirement	Deviations	Observations/ Remarks of
No.	(Regulations/ Circulars/ Guidelines		the Company Practising
	including specific clause		Secretary
. ~ -~ . Not Applicable

b) The listed entity has maintained proper records under the provisions of the above R~):',LllaLiullS aIllI clreulal's/ gUidelines issued thereunder insofar as It appears from our QAilnun.:ttion of lho:Jc l'cCUI'lb.

Pramod S. Shah & Associates Practising Company Secretaries 3rd Floor, LA-SHEWA Bldg., Next to Fedex, 233, P.D, Mello Road, Opp. St. George Hospital, Near CST, Mumbai - 400001. Tel.: 91-22-2271 7700/91-22-22701040 * Email: saurabhshah@psaprofessionals.com*Website:cspsa.co.in

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:

Serial	Action	Details of	Details of action taken	Observations/ r.emarks of
No.	tJ.ken by	vlolalioll	wanllng E.g. fiIle~,	Practicing Company the
			letter, debarment, etc.	Secretary
Not Applicable

rl) Thp li"tprl pnnty n~ tahn thQ following :nctiOl1fj' to comply ·with tho obcorviAtionc made in previous reports:

Serial	Observations of	the	Observations	Actions taken by	Comments of the
No.	Practicing	Company	made in the	the listed entity,	Practicing
	Secretary in the previous		secretarial	if any	Company
	reports		compliance		on the Secretary
			report for the		taken by actions
			year ended		the listed entity
			years (The
			be are to
			mentioned)
Not Applicable

M/ s. ramod S. Shah & AssodaLes Practising Company Secretary

Pramod S. Shah & Associates Practising Company Secretaries

3rd Floor, LA-SHEWA Bldg., Next to Fedex, 233, P.D, Mello Road, Opp. St. George Hospital, Near CST, Mumbai - 400001. Tel.: 91-22-2271 7700/91-22-22701040 * Email: saurabhshah@psaprofessionals.com*Website:cspsa.co.in

FCS No.: 334 C P No.: 3804

UUIN: F000334C000510140

Date: 24th June, 2021 Place: Mumbai