Trident Ltd — Regulatory Filings 2024

May 27, 2024

TRIDENT/CS/2024 May 27, 2024

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Na�onal Stock Exchange of India Limited

Exchange Plaza, Plot No. C/1, G Block Bandra Kurla Complex, Bandra (E), Mumbai – 400 051 Scrip Code: TRIDENT

BSE Limited

Phiroze Jeejeebhoy Towers Dalal Street, Mumbai – 400 001 Scrip Code: 521064

Sub: Annual Secretarial Compliance Report pursuant to Regula�on 24A of SEBI (Lis�ng Obliga�ons and Disclosure Requirements) Regula�ons, 2015

Dear Sir/Madam

Pursuant to Regula�on 24A of the SEBI (Lis�ng Obliga�ons and Disclosure Requirements) Regula�ons, 2015, we hereby submit Annual Secretarial Compliance Report, issued by M/s. Chandrasekaran Associates, Prac�cing Company Secretaries for the financial year ended March 31, 2024.

This is for your reference and records please.

Thanking you

Yours faithfully,

For Trident Limited

MATTA ARAVIND KUMAR Digitally signed by MATTA ARAVIND KUMAR DN: c=IN, postalCode=520001, st=ANDHRA PRADESH, street=KRISHNA, l=KRISHNA, o=Personal, serialNumber=0d1902fec4816d6c6383a8465faa915e4ce73e9f6aa6a29dc213f3f2022a0b33, pseudonym=fbd57b2e43914a3a9d9b195238650c13, 2.5.4.20=dca1cd9f837af755c4beb695043838e594c3c1ee3bcc5f6a7441fec41f7e9619, email=ARAVINDMATTA@TRIDENTINDIA.COM, cn=MATTA ARAVIND KUMAR Date: 2024.05.27 17:52:57 +05'30' (Ma�a Aravind Kumar) Company Secretary

Encl: As above

Disclaimer :- The details of the authorised signatories are uploaded on the official website of the Company. You may authenticate the authority of the signatory before relying upon the contents of this communication by visiting https://www.tridentindia.com/authority-matrix/ or may write to us on corp@tridentindia.com.

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27/05/2024

TL/2024/048378

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SECRETARIAL COMPLIANCE REPORT OF TRIDENT LIMITED FOR THE FINANCIAL YEAR ENDED MARCH 31, 2024

[Pursuant to Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015]

To,

The Board of Directors Trident Limited

Trident Group, Sanghera, Barnala, Punjab- 148101, India

We have conducted the review of the compliance of the applicable statutory provisions and the adherence to good corporate practices by Trident Limited (hereinafter referred as ‘ the listed entity ’), having its Registered Office at Trident Group, Sanghera, Barnala, Punjab- 148101, Secretarial Review was conducted in a manner that provided us with a reasonable basis for evaluating the corporate conducts/ statutory compliances and expressing our opinion thereon.

Based on our verification of the listed entity’s books, papers, minutes books, forms and returns filed and other records maintained by the listed entity and also the information provided by the listed entity, its officers, agents and authorized representatives during the conduct of Secretarial Review, we hereby report that in our opinion, the listed entity has, during the review period covering the financial year ended on March 31, 2024, complied with the statutory provisions listed hereunder and also that the listed entity has proper Board processes and compliance mechanism in place to the extent, in the manner and subject to the reporting made hereinafter:

• We, Chandrasekaran Associates, Company Secretaries have examined:

• (a) all the documents and records made available to us and explanation provided by 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 March 31, 2024 (“ 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 and include: -

• (a) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI LODR Regulations 2015”) ; Digitally signed by ROOPA AGRAWAL

ROOPA Digitally signed by ROOPA AGRAWAL AGRAWAL Date: 2024.05.15 13:30:52 +05'30'

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• (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 during the review period

• (e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 to the extent applicable;

• (f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021; Not Applicable during the review period

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

• (h) The Depositories Act, 1996 and the Regulations and Bye-laws framed thereunder to the extent of Regulation 76 of Securities and Exchange Board of India (Depositories and Participants) Regulations, 2018;

• (i) The Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 1993 regarding the Companies Act, 2013 and dealing with client to the extent of securities issued;

• (j) The Securities and Exchange Board of India (Investor Protection and Education Fund) Regulations, 2009;

and circulars/guidelines issued thereunder and based on the above examination, we 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/ Circular/ guidelines including specific clause)	Regulation / Circular No.	Deviations	Action Taken by Type of Action	Details of Violati on	Fine Amount	Observ ations/ Re- marks of the Practici ng Compa ny Secreta ry	Manag ement Respo nse	Remarks
				Not Applicable

ROOPA Digitally signed by ROOPA AGRAWAL AGRAWAL Date: 2024.05.15 13:31:07 +05'30'

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

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Sr. Observations Observation Compliance Details of Remedia Comments of
No. / Remarks of s made in Requirement violations/devi l the
the Practicing the (Regulations/ ations and actions, practicing
Company Secretarial circulars/ actions if any, Company
Secretary in Compliance guidelines taken/penalty taken by Secretary on
the previous Report for including imposed, if the the action
reports the year specific clause) any, on the listed taken by the
ended. listed entity entity listed entity.
Not Applicable
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We hereby report that during the review period the compliance status of the listed entity with the following requirements:

Sr. No.	Particulars	Complianc	Observations/
		e Status	Remarks by
		(Yes/No/	PCS
		NA)
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 India (ICSI) as notified by the Central Government under section 118 (10) of the Companies Act, 2013 and mandatorily applicable.	Yes	The minutes of the two previous meetings of the Board and Committee were signed in the subsequent meetings held after the immediate next Board and Committee meetings, respectively. Further, in one instance, the resolution passed by circulation was noted in the subsequent Board meeting held after the immediate next board meeting as required by Section 175 of the Act.
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 entity. � All the policies are in conformity with SEBI Regulations and have been reviewed &	Yes

Digitally signed by ROOPA ROOPA AGRAWAL AGRAWAL Date: 2024.05.15 13:31:23 +05'30' Page 3 of 7

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updated on time, as per the
regulations/circulars/guidelines issued by SEBI
3. Maintenance and disclosures on Website: Yes
� 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
4. Disqualification of Director: Yes Based on the
confirmation
None of the Director(s) of the Company is/ are received from
disqualified under Section 164 of Companies Act, the Directors of
2013 the Listed
Company.
5. Details related to Subsidiaries of listed entity NA The
have been examined w.r.t.: management
had identified
(a) Identification of material subsidiary companies that during the
period under
review, there
were no Material
Subsidiary
Company.
(b) Requirements with respect to disclosure of Yes
material as well as other subsidiaries
6. Preservation of Documents: Yes
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.
7. Performance Evaluation: Yes
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
Digitally signed by ROOPA
ROOPA AGRAWAL AGRAWAL
Date: 2024.05.15 13:31:36 +05'30' 4 of
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Regulations.
8. Related Party Transactions: Yes
(a) The listed entity has obtained prior approval of
Audit Committee for all related party
transactions; or
(b) The listed entity has provided detailed reasons NA The Company is
along with confirmation whether the transactions required to
strengthen its
were subsequently approved/ratified/rejected by
process with
the Audit Committee, in case no prior approval
respect to the
has been obtained.
related party
transactions
including but not
limited to the
extent of
obtaining of
omnibus
approval in
accordance with
Listing
Regulations and
SEBI circular(s),
the review of the
status of long-
term or
recurring related
party
transactions on
an annual basis
and approval
taken for
unforeseen
transactions up
to the prescribed
limit.
9. Disclosure of events or information: Yes
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.
10. Prohibition of Insider Trading: Yes
The listed entity is in compliance with Regulation
3(5) & 3(6) of SEBI (Prohibition of Insider Trading)
Regulations, 2015.
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ROOPA Digitally signed by ROOPA AGRAWAL AGRAWAL Date: 2024.05.15 13:31:45 +05'30'

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11.	Actions taken by SEBI or Stock Exchange(s), if any: No action has been 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 with respect to the listed entity.	Yes	No action was 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.
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 by listed entity.	Yes	The Company had appointed joint statutory auditors. During the period, M/s Deloitte Haskins & Sells, one of the Joint Auditor resigned w.e.f. August 07, 2023 and issued the limited review report for June’ 2023 quarter in terms of SEBI Circular CIR/CFD/CMD1/ 114/2019 dated 18thOctober, 2019. Accordingly, the Company is in compliance with provisions of paragraph 6.1 and 6.2 of section V-D of chapter V of the

ROOPA

AGRAWAL Digitally signed by ROOPA AGRAWAL Date: 2024.05.15 13:31:57 +05'30' Page 6 of 7

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master circular
issued by SEBI.
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master circular issued bySEBI.	master circular issued bySEBI.	master circular issued bySEBI.	master circular issued bySEBI.
12.	Additional non-compliances, if any: No additional non-compliance observed for any SEBI regulation/circular/guidance note etc.	Yes	No non- compliance observed for any SEBI regulation/ circular/ guidance note etc.

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 financial Records and Books of Accounts of the listed entity.

4. 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.

5. This Report is limited to the Statutory Compliances on laws/ regulations / guidelines listed in our report which have been complied by the Company up to the date of this Report pertaining to financial year ended March 31, 2024.

6. The compliance of the provisions of Corporate and other applicable laws, rules, regulations, standards is the responsibility of management. Our examination was limited to the verification of procedures on random test basis.

7. We have followed the audit practices and processes as were appropriate to obtain reasonable assurance about the correctness of the contents of the secretarial records. The verification was done on the random test basis to ensure that correct facts are reflected in secretarial records. We believe that the processes and practices, we followed provide a reasonable basis for our opinion.

For Chandrasekaran Associates Company Secretaries FRN: P1988DE002500 Peer Review Certificate No: 4186/2023

Digitally signed by ROOPA ROOPA AGRAWAL AGRAWAL Date: 2024.05.15 13:32:09 +05'30'

Roopa Aggarwal Partner Membership No. A25656 Certificate of Practice No. 11037 UDIN: A025656F000361233

Date: May 15, 2024 Place: Delhi

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