SRF Ltd. — Regulatory Filings 2021

May 19, 2021

The BSE Limited. BSE Corporate Relationship Department 1 st Floor, New Trading Ring, Rotunda Building, P.J. Towers, Dalal Street, Fort, Mumbai 400 001

National Stock Exchange of India Limited "Exchange Plaza" Bandra-Kurla Complex, Bandra (E ) Mumbai 400 051

Scrip Code- 503806 Scrip Code-SRF

SRF/SEC 19.05.2021

Annual Secretarial Compliance Report

Dear Sir,

In compliance with SEBl Circular No. ClR/CFD/CMD1/27/2019 dated February 8, 2019, We are submitting the Annual Secretarial Compliance Report dated May 19, 2021 for the year ended March 31, 2021.

Kindly take the same on record and acknowledge.

Thanking you,

Yours faithfully,

For SRF Limited

Rajat Lakhanpal Vice President (Corporate Compliance) & Company Secretary

Encl : A/a

SRF LIMITED Block-C Sector'45 Gurugram 122 003 Haryana lndia Tel: +91-124—4354400 Fax: +91-124—4354500 E-mail: info@srf.com Website : www.srf.com Regd. Office: Unit No. 236 Sr 237, 2nd Floor DLF Galleria, Mayur Plate Noida Link Road Mayur Vihar Phase 1 Extension Delhi 110091

Corporate identity No. L181010L1970PLC005197

SANJAY GROVER & ASSOCIATES

COMPANY SECRETARIES

B-88, 1^st Floor, Defence Colony, New Delhi - 110 024 Tel.: (011) 4679 0000, Fax: (011) 4679 0012 e-mail: contact@cssanjaygrover.in Website: www.cssanjaygrover.in

Annual Secretarial Compliance Report of SRF LIMITED for the year ended 31 March, 2021

I, Devesh Kumar Vasisht, Partner of Sanjay Grover & Associates have examined:

• all the documents and records made available to me and explanation provided (a) by SRF Limited ("the listed entity")
• the filings/ submissions made by the listed entity to the stock exchanges, $(b)$
• website of the listed entity, (c)
• any other document/ filing, as may be relevant, which has been relied upon to $(d)$ make this certification,

for the year ended 31 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 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) Requlations, 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, $2018;$
• (e) Securities and Exchange Board of India (Share Based Employee 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;

*No event took place under these regulations during the review period.

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/ quidelines issued thereunder, except in respect of matters specified below:-

Sr.	Compliance Requirement Deviations		Observations/
No	(Regulations/ circulars		Remarks	the οf
	guidelines including		Practicing Company
	specific clause)		Secretary
		None

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

Sr. No.	Action taken by	Details violation	of	Details action taken fines, warning letter, debarment, etc.	E.g.	of Observations/ remarks of the Practicing Company Secretary, if any.
				None

d) The listed entity has taken the following actions to comply with the observations made in previous reports: There was no observation made in previous report for year ended March 31, 2020.

I, further, report that there was no event of appointment/ re-appointment/ resignation of statutory auditor of the Company during the review period and the Company has modified the terms of appointment of its existing auditor. In this regard, I report that the Company has complied with Para 6(A) and 6(B) of Circular No. CIR/CFD/CMD1/114/2019 dated October 18, 2019.

For Sanjay Grover & Associates Company Secretaries Firm Registration No.: P2001DE052900

bergh

Devesh Kumar Vasisht Partner CP No.: 13700, FCS No. F8488 UDIN: F008488C000343121

New Delhi May 19, 2021