Date: 27th May, 2024

Department of Corporate Services

BSE Limited
The Stock Exchange — Mumbai
Phiroz Jeejeebhoy Towers
Dalal Street,
Mumbai-400 001

Scrip Code: 531201

Dear Sir,

Sub: Submission of Annual Secretarial Complinace Report pursuant to Regulation

24(A) of SEBI (Listing obligantion & Disclosure Requirements) Regulations,
2015 for the year ended 31st March 2024.

We enclose herewith Annual Secretarial Compliance Report dated 23 May, 2024 issued by
Mr. Bhautik Kanasagara, Praticing Company Secretary pursuant to Regulation 24(A) of SEBI
(Listing Obligantion & Disclosure Requirements) Regulations, 2015 for the year ended 31“
March, 2024.

Kinldy acknowledge the receipt.

Thanking you,

For Shilchar Technologies Limited

Mauli Digitally signed
by Mauli Rushil
Rushil Mehta
Date: 2024.05.27
Mehta 09:31:05 +05'30'
Mauli Mehta
Company Secretary & Compliance Officer

NEAR MUVAL SUB STATION, PADRA JAMBUSAR HIGHWAY, GAVASAD, VADODARA – 391430, INDIA.
PHONE: (+91) 7624090901/2 E-MAIL: [email protected] WEBSITE: shilchar.com
CIN:L29308GJ1986PLC008387
 401, Satyam Exotica Resicom, Opp
Bhautik Kanasagara
0s Practicing Company Secretaries
Chhani Lake, Chhani - Dumad
Road, Chhani, Vadodara - 3917 40
(MJ 88666e7366
(8. Com, ACS)
Email : -cs.bhautik.pcs (Ogmail.com

Secretarial Compliance Report of

Shilchar Technologies Limited for the year ended on 31't March ,2024

I have conducted the review of the compliance of the applicable statutory provisions and the
adherence togood corporate practices by Shilchar Technologies Limited (hereinafter refered
as 'the listed entity'), having its Registered Office at Block No. 460, Near Muval Sub-Station,
Padra-Jambusar Highway, Gavasad, Padra, Vadodara, Gujarat, India 39L430. Secretarial
Review was conducted in a manner that provided us a reasonable basis for evaluating the
corporate conducts/statutory compliances and to provide our observations 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, agentsand authorized representatives duringthe conduct of Secretarial
Review, I hereby report that the listedentity has, during the review period covering the
financial year ended on 31't March, 2024 complied with the statutory provisions listed
hereunder in the manner and subject to the reporting made hereinafter :
I have examined:

(a) all the documents and records made available to us and explanation provided by Shilchar
Technologies Limited ["the listed entity"J,
(b) the filings/ submissions made by the listed entity to the stock exchanges,

(c) website of the listed entity,

(d) any other document / frling as may be relevan! which has been relied upon to make this
report,for the financial year ended on 31s March, ZAZ4 {"Review Period"J in respect of
compliance with the provisions of:
(a) the Securities and Exchange Board of India Act, L992 ("SEBI Act"J and the Regulations,
circulars, guidelines issued thereunder; and

(b) the Securities Contracts (Regulation) Act 1956 ["SCRA"J, rules made thereunder and the
Regulations,circulars, guidelines issued thereunder by the Securities and Exchange Board
of India ["SEBI");
The specific Regulations, whose provisions andthe circulars/ guidelines issuedthereunder,have
been examined, include: -

(a) Securities and Exchange Board of India flisting Obligations and Disclosure Requirements)
Regulations,2015;
(b) Securities and Exchange Board of India fissue of Capital and Disclosure RequirementsJ
Regulations, 2018;
(c) Securities and Exchange Board of India (Substantial of Shares and Takeovers)
Regulations,20ll;
q{
u 1+
1.i {r
4 q
 (d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; Not
Applicable to the Company during the review Period;
(e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity]
Regulations,20Z'J.; Not Applicable to the Company during the review Period;
(0 Securities and Exchange Board of India fissue and Listing of Non-Convertible SecuritiesJ
Regulations,202L; Not Applicable to the Company during the review Period;

(g) Securities and Exchange Board of India [Prohibition of Insider Trading) Regulation s,201-5;
and circulars/ guidelines issued thereunder; and based on the above examination, I hereby
report that, during the Review Period:

l. [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. Compliance Regu- Deviati Acti Typ Details of Fin Obser- Man- Re
No Requirement Iation ons on eof Violation e vations/ mar
age-
(Regulations/ / Tak Acti Am Remarks of ment ks
circulars/ Circul en on oun the Prac Re-
guidelines arNo. by t ticing spons
including Company e
specific clause) Secretary

lAs
per the llhe iSE
Clarifi The
lNon- lDue to
lRegulat
lprovisions of lr
on lcornprny td cations
Company lCompliance lsome
lRegulation 30[6] B0r5l lhas has [*ith th" Iechnic
and I

land Schedule III and lsubmitte submitted lRegulation l,r

of SEBI ILODRJ Schedul
I

d Explana financial 30[6] and lglitches

Regulations, 201-5 e III of financial tion results schedule III lin the
- the listed entity SEBI results after the of SEBI lportal
shall after the 30 minutes (LoDRJ
[LoDR) l*t i.t.,
disclose to the Regulat 30 ofthe regulation, ldid not
Exchange[s), i ons, minutes lclosure of 201-5 related process
within 30 minutes 201.5 ofthe Ithe Boa.d to Q1 (23-24) the OTP
ofthe closure of closure Meeting financial mentio
the Board of the lheld on results not ned by
Meeting Board Zgrh July submitted us.
Meeting 2023. with the
held on stock
29tnfull exchange
2023. within 30
minutes from
the closure of
the meeting
held on 29th
uly 2023
\-*.....t [b) The listed entity has taken the following actions to comply with the observations
\t ?| ,,-
in previous reports: NIL
arC$
ii
,..,3

L''l
Sr. Compliance Regu- Devia Actio Tvp Details Fin Observa- Man Re-
No. Requirement lation/ tions n eof of e tions/ Re- marks
(Regulations/ Circula Take Acti Viola- Amo marksof age-
circulars/ rNo. nby on tion unt the Prac- men
guide- lines ticing Com- t Re-
including pany spon
specific clause) Secre-tary se

Advisory/ Clarification/Fine/Show Cause Notice/ Warning, etc - Nil.

ll. Compliances related to resignation of statutory auditors from listed entities and their
material subsidiaries asper SEBI Circular CIR/CFDICMDL/L14/2019 dated 18th October,
2At9:

Sr. Particulars Complian Observations

No. ce Status /Remarks by
(Yes/Nol PCS*
NA)

L Compliances with the following conditions while appointing/re-appointing an auditor

i. If the auditor has resigned within 45 days from

N.A. Ihere was no
resignation by
the end of a quarter of a financial year, the auditor Auditor during the
before such resignation, has issued the limited review period.
reviewf audit report for such quarter; or
ii. If the auditor has resigned after 45 days from the
end of a quarter of a financial year, the auditor
before such resignation, has issued the limited
review/ audit report for such quarter as well as
the next quarter; or
iii. If the auditor has signed the limited reviewf
audit report for the first three quarters of a
financial year, the auditor before such
resignation, has issued the limited review f audit
report for the lastquarter of such financial year
as well as the auditreport for such financial year.

2 Other conditions relating to resignation of statutory auditor

k, p
 N.A. was no
i. Reporting of concerns by Auditor with respect to the by
listed entity/its material subsidiary to the Audit during the
Committee: period
a. In case of any concern with the managementof the
listed entity/material subsidiary such as non-
availability of information / non- cooperation by
the management which has hampered the audit
process, the auditor has approached the Chairman
of the Audit Committee of the listed entity andthe
Audit Committee shall receive such concern
directly and immediately without specifically
waiting for the quarterly Audit Committee
meetings.
b. In case the auditor proposes to resign, all
concerns with respect to the proposed resignation,
alongwith relevant documentshas been brought to
the notice of the Audit Committee. In cases
where the proposed resignation is due to non-
receipt of information / explanation from the
company, the auditor has informed the Audit
Committee the details of informationl explanation
sought and not provided by the management, as
applicable.
c. The Audit Committee / Board of Directors, as the
case may be, deliberated on the matter on receipt
of such information from the auditor relating to the
proposal to resign as mentioned above and
communicate its views to the management and the
auditor.
ii. Disclaimer in case of non-receipt of information: was no
N.A.
The auditor has provided an appropriate disclaimerin its n by the
udit report, which is in accordance withthe Standards tor during the
Auditing as specified by ICAI / NFRA, in case where period.
listed entity/ its materialsubsidiary has not provided
asrequired by the auditor,
3
The listed entity / its material subsidiary has obtained
NA Ihere was no
resignation by
information from the Auditor upon resignation, in the Auditor during the
format as specified in Annexure- A in SEBI Circular review period.
CIR/CFD/C MD L / LL4 / 20 19 dated l8th Octob er, 20L9.

1t. we hereby report that, during the review period the compliance status of the listed entity is
a asbelow:

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Sr. Particulars Compliance Observations/
No. Status Remarks by
(YeslNo/NA) PCS*
Yes
L. 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 ICSIJ, as notified
by the Central Government under section 118(10J of the
Companies Act, 2013 and mandatorily applicable.
2 Adoption and timely updation of the Policies:
Yes
o All applicable policies under SEBI Regulations are
adopted with the approval of board of directors of the
listed entities.
o All the policies are in conformity with SEBI Regulations
and have been reviewed & updated on time, as per the
regulations/circulars/guidelines issued by SEBL
3 Maintenance and disclosures on Website:
Yes
o The Listed entity is maintaining a functional website
o Timely dissemination of the documents/ information
under a separate section on the website
o Web-links provided in annual corporate governance
reports under Regulation 27(2) are accurate and
specific which re- directs to the relevant
documentfsl/section of the website
4. Disqualifi cation of Director:
Yes
None of the Director[sJ of the Company isf are disqualified
under Section L64 af Companies Act, 2013as confirmed by
the listed entity.
5. Details related to Subsidiaries of listed entities have
NA There is no
been examined w.r.t.:
subsidiary of
the Listed
(a) Identiflcation of material subsidiary companies Entity
(b) Disclosure requirement of material as well as other
subsidiaries
Yes
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.

.:{ t'i r \
fiil
il Lr
..1
 Yes
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/during the financial year
as prescribed in SEBI Regulations.

B. Related Party Transactions :

[a] The listed entity has obtained prior approval of Audit Yes
Committee for all related parly transactions; or

entity has provided detailed reasons

[bJ The listed
with confirmation whether the transactions
subsequently approved/ratified/rejected the
Audit Committee, in case no prior approval has
obtained.
The Company has
9, Disclosure of events or information:
submitted Q1 (23-
The listed entity has provided all the required disclosure[sJ 24) financial results
under Regulation 30 along with Schedule III of SEBI LODR after the 30 minutes
Regulations, 201,5 within the time limits prescribed of the closure of the
thereunder. Board meeting held
onZ9thluly 2023.
Yes
10. Prohibition of Insider Trading:
The listed entity is in compliance with Regulation 3[5] & 3[6]
SEBI [Prohibition of Insider TradingJ Regulations, 2015.

LL, Actions taken by SEBI or Stock Exchange(s), if any:

No actionfsJ has been taken against the listed entity/ its Yes
promoters f directors/ subsidiaries either by SEBI or by
Stock Exchanges (including under the Standard Operating
Procedures issued by SEBI through various circularsJ under
SEBI Regulations and circulars/ guidelines issued
thereunder except as provided under separate paragraph
herein.
L2 Additional Non-compliances, if any:
No additional non-compliance observed for any SEBI Yes
regulation / cir cular / guidance note etc.

Assumptions & Limitation of scope and Review:

i. 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 s of financial Records and Books of
Accounts of the listed entity
1t
rrrnfiI}ARi
Y ! '.'r1 '-' * -

r--jl" i;C.
r'. ': '!r 3-
 a. This Report is solely for the intended purpose of compliance in terms of Regulation Z4A
(Z) ofthe SEBI flisting Obligatlons and Disclosure Requirements) Regulations, 2015 and
is neither an assurance as tothe future viability of the listed entity nor of the efficacy or
effectiveness with which the management hasconducted the affairs of the listed entity.

@{ft,,B,fl,
<r-
VANO*AR,&
Bhautik Kanasagara C,iF I'{o. _*
Practicing Company Secretary ne4 tlt

ACS No. 60290; CP No. 231.36

? 3,1
UDIN: ,{060290F00043 1375
PR No. 3274/2A23

Place: Vadodara
Date: 23.05.2024