MDN/CS/SE/COMPLIANCE/SCR/21

To,

BSE Limited,P.i. Towers, V~ Floor,Dalal Street

Mumbai- 400001

National Stock Exchange of India Limited,Exchange Plaza, C/i, G BlockBandra Kurla Complex, Bandra (East),Mumbai —400051

Scrip Code: 541195 Trading Symbol: MIDHANI

Sub: Submission Annual Secretarial Compliance Report in compliance of Regulation 24A 0the Securities and Exchange Board of India (Usting Obligations and DisclosureRequirements) Regulations, 2015 (“SEBI LODR”)

Dear Sir/Madam,

In terms of SEBI Circular bearing no. CIR/CFD/CMD1/27/20i9 dated 8th February, 2019and Regulation 24A of the SEBI LODR, please find enclosed Annual Secretarial ComplianceReport of Mishra Dhatu Nigam Limited for the financial year ended 3l~ March, 2021.

This is for your information and records.

Thanking You,

Encl:a/a

Yours Faithfully,ishra Dha

ul Anto

Compart~5 cretary & Compliance Officere-mail: company.secretary@midhani-india.in

jtfar tT9 f~’m r~r~3 MISHRA DHATU NIGAM LIMITED(‘ma ~n wi ~m) (A Govt. of India Enterprise)

*kl~a ~i4ig: taft. ~ ~q~igig, ~iiy.ii -500058 Registered Office: RO. Kanchanbagh, Hyderabad, Telangana-500058q~p~ Telephone: 040-24184000, ~ Fax: 040-24340039

rtim~ qnm t CIN: L14292TG1973G01001660~gtii~e Website: www.midhani-india.in

I

June 28, 2021

R&A Assocletes T 202, Technopolls, 1 10-74/B

Ld Above Ratnede -1074/B

Chlikoti Garde e Market Hyderabad. 500014 +91 40-4003 2244.47

info@RnACs.com www.RnA-cs.com Hyderabud i GMOon ChennaiI MumbalAmarovol

Secretarial Compliance Report of Mishra Dhatu Nigam 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 MISHRA DHATU NIGAM 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 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 there under; and

b) the Securities Contracts (Regulation) Act, 1956 ("SCRA"), rules made there under and the Regulations, circulars, guidelines issued thereunder by the Securities and Exchange Board of India ("SEBI");

The speciic Regulations, whose provisions and the circulars/ guidelines issued there under, have been examined, include:

(a) Securities and Exchange Board of India (Listing Obligations and DisclosureRequirements) Regulations, 2015, as amended;

(b) Securities and Exchange Board of India (Issue of Capital and Disclosureequirements) Regulations, 2018; (Not Applicable to the Company during the

review period)

(c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 as amended;

(d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (Not Applicable to the Company during the review period)

(eSecurities and Exchange Board of India (Share Based Employee Benefits) Regulations,2014; (Not Applicable to the Company during the review period)

Hyd-16 Cretarie Secte mpany

R&A AssoclatesT 202, Technopolls, 1 10 74/8

Above Ratnadoep Super Market Chikotl Gardens, BegumpetHyderabad 500016. Indla

+91 40-4003 2244 . 47 Info@RnA-cs.com I www.RnA-cs.com Hyderstad iGugnon Chenat Mumbai I Amoravati

( Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008; (Not Applicable to the Company during the review period)

(g) Securities and Exchange Board of India (lssue and Listing of Non- Convertible and

Redeemable Preference Shares) Regulations, 2013; (Not Applicable to the Company during the review period)

(h) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations,

2015, as amended;

() Securities and Exchange Board of India (Depositories and Participants) Regulations,2018;

G) Securities and Exchange Board of India (Debenture Trustee) Regulations, 1993; (Not Applicable to the Company during the review period);

circulars/ guidelines issued thereunder;

And based on the above examination and considering the relaxations granted by the Ministry of Corporate Affairs and Securities and Exchange Board of India warranted due to the spreadof the COVID-19 pandemic, 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:

Deviations Compliance Requirement (Regulations/ Circulars/Guidelines

including Specific Clause)

Observations/ Remarks of the Practicing Company

Secretary

Sr. No.

Regulation 17(1)(a) of the SEBI

(Listing Obligations and Disclosure Requirements) Regulations, 2015:

As on 31st March, 2021,the Board of Directors

As on 31st March, 2021, the

Listed Entity is not meeting the requirement specified under Regulation 17(1)(a) of SEBI (ListingObligations and Disclosure

Requirements) Regulations, 2015.

1

of the Listed Entity does not have at least Board of Directors shall have an one Woman Directoroptimum combination of executive

and non-executive Directors with at on their Board and the Composition of the Board of Directors does

least One Woman Director and not less than 50% of the Board of Directors shall comprise of Non- Executive directors.

not comprise of at least 50% of the Directors as Non-Executive Directors.

Proviso to Regulation 17(1)(a) of the SEBI (Listing Obligations and Disclosure Requirements)

The Listed Entity being one of the top 500

Listed Entity does not

2. As on 31st March, 2021, the Listed Entity is not meeting the requirement

Hyd16 Cretari

any o

R &A Assoclates

T202, Technopolis, 1-10-74/B ADOve Ratnadeep Super Market

Chlko Gardens, Begumpet Hyderabad- 500016. Indla

+91 40-4003 2244 47 Hyderatbad non Chonnei i Mumb 1 Anaravat ntooRnA-cs.com www.RnA-cs.com

Sr. Compliance Requirement (Regulations/ Circulars/ Guidelines

including Specific Clause)

Deviations Observations/ Remarks of the Practicing Company

Secretary No.

Regulations, 2015: have at least one specified under proviso to Regulation 17(1)(a) to of the SEBI (Listing Obligations and Disclosure

Requirements) Regulations, 2015..

The Board of Directors of the top 500 listed entities shall have at least one

Independent WomanDirector on the Board.

Independent Woman Director by April 1, 2019 and the Board of Directors of the top 1000 listed entities shall have at least one

Independent Woman Director by April 1, 2020.

3. Regulation 17(1)(b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

Since, the Chairman of the Listed Entity is an Executive Director, the

As required underRegulation 17(1)(b) of the SEBI (Listing Obligations and Disclosure Where the listed entity does not have

a regular Non Executive Chairperson at least half of the Board of Directors

Listed entity shall have at least have at least Requirements)

Regulations, 2015, the Listed Entity does not have at least half of the

half of the Board of Directors as shall comprise of Independent

Directors. Independent Directors. Board of Directors as

However, as on 31st March, 2021 the Listed Entity does not have

any Independent Directors on their

Board.

Independent Directors.

Regulation 17(1)(c) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

As on 31st March, 2021

the Listed Entity have only 3 Directors on their Board.

As required under

Regulation 17(1)(©) of the SEBI (Listing Obligations and Disclosure

The Board of Directors of the top 1000 listed entities (with effect from April 1, 2019) shall comprise of not less than 6 Directors.

Requirements)Regulations, 2015, the Listed Entity does not have at least 6 Directors on their Board.

5. Regulation 17 (2A) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015: The quorum for every meeting of the

The Listed Entity has As on 31st March, 2021 the Listed Entity does not have any

convened the Board Meetings held on 11th

1A Hyte Tetaries

Secrepany

R&A Assoclates

d T 202, Technopolls, 1-10 74/B

Above Ratnadeep Super Market

Chikoti Gardens, Begumpet Hyderabad 500016. Indla

+91 40-4003 2244-47 Info@RnAcs.com I www.RnA-cs.com Hyderabnd Gurgeon I Chernoi 1 Mumbal Amaravoti

Observation/ Remarks of the Practicing Company

Secretaryy

Deviations Compliance Requirement (Regulations/Circulars/ Guidelines

including Specific Clause)

Sr. No.

board of directors of the top 1000

listed entities with effect from April1, 2019 and of the top 2000 listed entities with effect from April 1, 2020 shall be one-third of its total strength or three directors, whichever is

Independent Director on their Board.

November 2020, 17th December 2020, 12th February 2021 and 15th March 2021 without the presence of Independent

Directors as the Listed Entity does not have any Independent Directors on their Board with effect

higher, including at least oneIndependent Director.

from 08th October, 2020.

Regulation 18(1)(a) &(b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

As on 31st March, 2021,the Listed Entity does not have any Independent Director

As on 31st March, 2021, Audit Committee of the

6.

listed entity is not meeting with the requirements specified under

Regulation 18(1)(a) and (b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Every listed entity shall constitute Independent Audit Committee with minimum 3 Directors as its members

on their Board.

and with Two-thirds of its membersas the Independent Directors.

Regulation 18(2) (a) &(b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

7. The audit committee As required under Regulation 18(2) (a) of the SEBI (Listing Obligations and Disclosure

didn't meet atleast four times in a year and the quorum for such Meetings did not comprise of at least two Independent Directors.

The audit committee shall meet at least four times in a year and not more than one hundred and

Requirements) Regulations, 2015, the Audit Committee of the

twenty days shall elapse between two meetings.

Listed Entity has not met at least four times in a year and the quorum for the Audit Committee

The quorum for audit committee meeting shall either be two members or one third of the members of the audit committee,whichever is greater, with at least two independent directors.

Meetings held on 30th June 2020 and 11h September, 2020 is not in line with Regulation 18(2) (b) of the SEBI (Listing Obligationsand Disclosure

CIA Requirements)Regulations.

Hd-16

mpany eCretari

R&A Assoclates T 202. Technopolis, 1-10-74/B

Above Ratnadeep Super Marke Chikot Gardens, BegumpetHyderabad 500016. Indla

+91 40-4003 2244 - 47

Info@RnA-cs.com I www.RnA-cs.com Hyderabnd 1 Gurgaon ChenmaiIMumbal1 Amaravati

DeviationsCompliance Requirement(Regulations/Circulars/ Guidelines

including Specific Clause)

Observations/ Remarks of the Practicing Company

Secretary

Sr. No.

Regulation 19(1)(a) & (b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

As on 31st March, 2021, the Listed Entity has only 1 Non-Executive Director and no

8. As on 31st March, 2021, the NRC of the Listed Entity is not meeting with

requirements specified under Regulation 19(1)(a) and (b) of the SEBI

(Listing Obligations and Disclosure Requirements) Regulations, 2015.

The Board of Directors shall Independent Director on their Board. constitute the Nomination &

Remuneration Committee (NRC) comprising minimum 3 Directors and all of them shall be non-executive

directors.

9 Regulation 19(1)(¢) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

As on 31st March, 2021, the Listed Entity does not have any Independent Directoron their Board.

As on 31st March, 2021, the NRC of the Listed Entity is not meeting with

requirements specified under Regulation 19(1)(©)of the SEBI (Listing

Obligations and Disclosure Requirements) Regulations, 2015.

The Nomination & Remuneration

Committee shall have at least 50% of the Directors as Independent Directors.

Regulation 19 (3A) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

10. During the periodunder review, there

As required under

Regulation 19 (3A) of the SEBI (Listing Obligations and Disclosure

was no Nomination &

Remuneration Committee Meeting(s) Requirements)

Regulations, 2015, the NRC has not met at least

The Nomination & Remuneration held. Committee shall meet at least once in

a year.

once in a year.

Regulation 20 (2A) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

As on 31st March, 2021, the Listed Entity does not have any Independent Director on their Board.

11. As on 31st March, 2021, the

Stakeholders Relationship Committee of the Listed

The Stakeholders Relationship

Committee shall comprise of at least three directors, with at least one being an independent Director.

Entity does not meet with the requirement specified

under Regulation 20 (2A) of the SEBI (Listing Obligations and Disclosure Requirements)Regulations, 2015. OC

Hyd-16

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Compliance Requirement(Reguiations/Circulars/Guidelines

including Specific Clause)

Deviations Observations/ Remarks of the Practicing Company

Secretary No.

12 Regulation 20(3A) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

During the review period, there was no Stakeholders

As required underRegulation 20 (3A) of the SEBI (Listing Obligations

Relationship Committee Meeting(s)

and Disclosure The Stakeholders Relationship Committee shali meet at least once in

Requirements) Regulations. 2015, the

Stakeholders Relationship Committee has not met at

held.a year.

least once in a year.

13. Regulation 21(2) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

As on 31st March 2021, the As on 31 March, 2021,

the Risk Management Committee does not

Risk Management Committee does not meet the requirement specified under Regulation 21 (2) of the SEBI (ListingObligations and Disclosure Requirements)

Regulations, 2015

have majority of its members as membersThe majority of members of Risk

Management Committee shall consist of members of the Board of Directors

of Board of Directors.

Regulation 25 (3) and (4) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

The Independent Directors of the

listed entity shall hold at least one

meeting ina year, without the presence of non-independent directors and members of the

14. As on 31st March, 2021,the Listed Entity does not have any

Independent Director on their Board and

As required under Regulation 25 (3) and (4) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, there was no separate Meetingof Independent Directors was held during the year and there was no review

there was separateMeeting of Independent Directors was held. management

The Independent Directors in such meeting shall inter alia review the performance of the non-

Independent Directors, Chairperson and the Board of Directors as whole and assess the

of performance of the

Non-Independent Directors, Chairperson and the Board of Directors as whole.

quality and quantity and timeliness of flow of information between management and the Board.

ASSO

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Compllanee Requlrement (Negulatlona/Clreularm/ Guldellnen

tneludng Spelfle Clause)

Devlation Observation Remarks of the Practicing Company

Secretaryy No

Regulatlon 2(6) of the SBI (LUstlng Obligatlona and Diuclosure Requlrementa) Regulations, 201:

As on 31 March, 2021 the Company is yet to replace New

Independent Directorfrom the date of

As required under Regulation 25 (6) of the SEBI (Listing Obligations and Disclosure

An ndependent Director who resigns (r) is renmoved from the Noand of Directors of the listed enttyshall be rplaced by a new Independent Director by listed entity at the earliest but not later than the

Requirements) Regulations, 2015, the vacancy caused upon completion of tenure of 1 Independent Directors on 08th October, 2020 was not

vacancy i.e. October 8, 2020.

filled within a period of 3 immediate next meeting of the Boardof Directors or three months from the months.

datr of such vacaney, whichever is

later

(b) The listed entity has maintained proper records under the provisions of the aboveRegulations and circulars/ guidelines issued there under in so far as it appears fromn our examination of those records

()The following are the action taken against the listed entity its-premeters/ direetorstmateriat-subsidiaries-either-by-SEBl-er by the Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under the aforesaid Acts/ Regulations and circulars/ guidelines issued there under:

Sr. taken by

Details of violation Action Details of action taken Observations remarks of the warning Practicing Company Secretary, if No E.g

letter, debarment, etc. Fine of Rs. 1,01,480 including GST imposed Stock exchanges on the said matter on the Company for the | stating that the Company is a

quarter ended 31st March, 2020 vide email

fines, any.

BSE Reg 19(1)/ 19(2) Non- compliance with the constitution of Nomination

Listed Entity had replied to the Limited

&RemunerationCommittee. Defence Public Sector Unit (DPSU) under the administrative control of

dated 08th July, 2020. Ministry of Defence, Department of Defence Production,

Regulation 17(1) Non compliance with the requirement pertaining to the composition of the Board | quarter ended31

including failure to appoint

Fine of Rs. 2,64,320 including GST imposed on the Company for the Since, the listed entity is a DPSU

Government of India.

AS SOC EHy 16

the appointments of Directors on March, 2020 vide email the Board are taken care by

Cretar Secte

R&A Assoclates 202. Technopoiis, 1-1074/8 Above Ratradeep Super Market

Chiko Garders. Begumpet

Hyderabad-500016. Indis 404003 22A4 - 47

irlo@RrACs.comi www.RNACS.com Hyaernbod Gurgaon Chenisi1 Aumpni Arnarwti

dated 08th September, Ministry of Defence (MoD) Department of Defence Production

woman director.

2020. Regulation 18(1) Non- compliance with the constitution of Audit

The term of the 3 independent Directors ie., Shri L. V. Sarma, Dr. Jyoti Mukhopadhyay and Dr. Usha Ramachandra (Woman Independent Director) ended on

Committee.

Regulation 17(1) Non compliance with the requirement pertaining to the composition of the Board| email dated 17th including failure to appoint woman director.

Fine of Rs. 7,59,920

including GST imposed | 30th November, 2019.

on the Company vide Further, the term of the Shri Surendra Sinh, Independent Director was ended on 08th

November, 2020.

October, 2020.Regulation 18(1) Non- compliance with the

constitution of AuditConsequent to aforementioned vacations, the composition of

Listed Entity Board and its

committees is not in line with

applicable provisions SEBI (Listing

Committee.

Reg 19(1)/(2) Non- compliance with the

Exchange constitution of Nomination

&&Remuneration Committee

. National Fine of Rs. 1,01,480

including GST imposed Obligations and Disclosure

on the Company for the | Requirements), 2015 (SEBI Listing

quarter ended 31s*

March, 2020 vide email

dated 02nd July, 2020. Fine of Rs. 7,51,660

Stock

Regulations) Accordingly, the Listed Entity has informed this matter to the

Limited

Regulation 17(1) Non- compliance with the requirement pertaining to the composition of the Board quarter ended 31st including failure to appoint

Administrative Ministry i.e.

including GST imposed Ministry of Defence well in

on the Company for the advance for appointment of

requisite Independent Director on the Board of the Company throughMarch, 2020 vide email

dated 20th August, 2020.

woman director. various correspondences

Regulation 18(1) Non compliance with the

constitution of Audit

The process of appointment of Directors by MoD is followed by multi-level approvals and the Listed Entity has no role apart from timely intimation to MoDp

Committee. Regulation 17(1) Non- compliance with the requirement pertaining to

the composition of the Board including failure to appoint woman director.

Fine of Rs. 2,64,320

including GST imposed regarding vacancies.

on the Company for the quarter ended 31s*

March, 2020 vide email dated 08th September, 2020.

As the Listed Entity is not

responsible for appointment of

directors, it has requested for the

waiver of the penalty imposed by both Stock Exchanges. Regulation 18(1) Non-

compliance with the SSOA

Hyd 16

Ompany retarie

Secre

R&A T 202, Techn clates

Ld 202. Technopolis, 1-10-74/B

Chikoti C uper Market

Hyderabad. 500 et +91 40-4003 2244.47

yderabad 1 Gueeon CheieMumbai 1 Anarovati Info@RnA-cs.com I www.RnA-cs.com

constitution of Audit Accordingly, the said matter was placed before the respective committees of the Stock

Exchanges.

Committee. Regulation 17(1) Non- compliance with the requirement pertaining to the composition of the Board including failure to appoint woman director.

Fine of Rs. 7,59,9200 including GST imposedon the Company for the quarter ended 31st

March, 2020 vide email dated 17th November, Entity's representation is yet to 2020.

The Committees after considering the facts of the case and the Listed

decide on the waiver of the fines Regulation 18(1) Non- compliance with the constitution of Audit

levied for non-compliance under SEBI Listing Regulations.

Committee. | Non Compliance of the

Regulation 17(1), 17 (2A), 18, 19 of the SEBI (ListingObligations and Discdosure Requirements), 2015

Accordingly, National Stock Exchange of India Limited vide in its Letter dated November 13, 2020

Fine of Rs. 10,00,640 including GST imposedon the Company vide email dated 15th

waived off the fine of Rs. 1,48,000/- for non-compliance under Regulation 19(1)/ (2) of SEBI Listing Regulations.

February, 2020.

BSE Limited vide their email dated April 19, 2021 waived off the fine amounting to Rs. 7,59,000/- for the quarter ended September 2020 and has not levied fine for the quarter ended December 2020o.

SSOC H16

pany Cretar Secre

R&A Associates T202, Tecmopotis, 1-10 74/B

Above Ratnredeep SupeManet Clo Garders. BeamoeHyderabed 500016 Indie 91 404003 2244 - 47

foRAaom(wa RnA-scomydes atsup Cemraithusb art

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

Sr. Observations of the

No Practicing Company Secretary in the

previous reports

Commentsof the Practicing Company Secretary on the actions taken by the listed

entity

Actions taken by the listed entity, if any

The Company did not have| The Listed Entity is a Defence We were informed that Listed Entity is a Defence Public Sector Unit (DPSU) under the administrative

1

at least one independent woman director on the

Public Sector Unit (DPSU) under the administrative control of Ministry of Defence, Government of India.

Board of Directors as control of Ministry of Defence,Government of India and the

required under proviso to Regulation 17(1)(a) of the

LODR Regulations; appointments of Directors on

the Board are taken care by Govt of India, acting through

Ministry of Defence (MoD) -

Department of Defence

Since, the listed entity is a

DPSU, the appointments of 2 As the Chairman of the Board is an Executive Directors on the Board are Chairman, half of the taken care by Ministry of

Defence (MoD) - Department Production. Board of Directors of the

Company did not comprise of Defence Production.

of Independent Directors, as required underRegulation 17(1)(b) of the

LODR Regulations; The Company beinga Top 1000 Listed Entity, the

Board of Directors of the

The process of appointment of Directors by MoD is followedby multi-level approvals and the Listed Entity has no role apart from timely intimation to

Usha Ramachandra ended on | MoD regarding vacancies.

The term of the 3

Independent Directors i.e.,Shri I. V. Sarma, Dr. Jyoti Mukhopadhyay and Dr.

3.

30th November, 2019.

However, the Listed Entity has been actively pursuing with its Administrative Ministry for the appointment of Directorsso as to ensure compliance with all applicable SEBI

Regulations

Company do not comprise of not less than 6 Directors

Further, the term of the Shri.Surendra Sinh, Independent Director was ended on 08th (ie. it has only 4 Directors)

as required under

Regulation 17(1)(¢) of the

LODR Regulations The Composition of the Audit committee do not

October, 2020.

Consequent to aforementioned vacations,

4. the composition of Listed Entity Board and its committees was not in line

with applicable provisions of SEBI Regulations.

have two-thirds of its

members as Independent Directors as required

under Regulation 18(1)(b) of LODR Regulations;

5. The composition of Accordingly, the Listed Entity has informed this

Hyd16

mpany retarie

Sec

d R&A Aseoclates ..

T202. Technopolis. 110 74/8 Above Ratnedeeo 3uper Maet

Chikot Gardens, Begumpe Hyderabad 500016. Indla

91 40-4003 2244 -47 info@RnA-ca.comn t www.RNA-Cs.com

Nomination and matter to the AdministrativeMinistry I.e. Ministry of Defence well in advance for

Remuneration is not in line with O Regulation 19(1) (b)

LODR Regulations; On resignation of Shri Sanjeev Singhal, Director(Finance) from the Board w.e.f. 07th January, 2020, the majority of members of the Risk Management

Committee as on 31lst

appointment of requisite Independent Director on the Board of the Company through various

correspondences.

The process of appointment of Directors by MoD is followed by multi-level approvals and the Listed Entity has no role apart from timely intimation to MoD regarding vacancies.

March, 2020 do not consist of Board members in terms

of Regulation 21(2) of

LODR Regulations. As required under

Regulation 25 (6) of the LODR Regulations, the vacancy caused upon completion of tenure, of 3 Independent Directors on

30th November, 2019, were

not filled, as per the timelines prescribed underRegulation 25(6) of LODR Regulations i.e. within a

period of 3 Months

The Listed Entity has been actively pursuing with its Administrative Ministry for the appointment of Directors so as to ensure compliance

with all applicable SEBI

Regulations.

For R&A Associates, Company Secretaries

h sAAS ASSC

Hyd-16 CS R Ramakrishna Gupta,

mpanySenior Partner eCretarie

FCS No:#5523 COP No.: #6696

Place: Hyderabad, Date: 26th June, 2021

UDIN: FO05523C000506861