A statutory compliance certificate and stock exchange submission covering the maintenance of a Structured Digital Database (SDD) under the SEBI (Prohibition of Insider Trading) Regulations, 2015, certified by a Practicing Company Secretary for companies exempt from Regulation 24A of the LODR Regulations.

[Date]

To,

[Name of Stock Exchange]

[Address of Stock Exchange]

ISIN: [ISIN Number]

Symbol: [Trading Symbol]

Sub: SDD Compliance Certificate for the Financial Year Ended 31st March, 20XX

Ref: NSE Circular bearing Ref. No: NSE/CML/31, dated October 18, 2024 for ensuring compliance with Structured Digital Database (“SDD”)

Dear Sir/Madam,

With reference to the captioned circular, the listed entities to whom the provisions compliance of Regulation 24A of SEBI (Listing Obligation and Disclosure Requirements) Regulations, 2015 (“LODR Regulations”) are not applicable, are required to confirm the certified status of SDD by submitting SDD Compliance Certificate in the prescribed format, by a Practicing Company Secretary within 60 days from the end of the Financial Year.

Since, [Company Name] is listed on the [NSE SME Platform / Main Board], the provisions of Regulation 24A of SEBI (LODR) Regulations, 2015 are not applicable to the Company. Therefore, pursuant to the provisions of Regulation 3(5) and 3(6) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 read with the NSE Circular bearing Ref. No: NSE/CML/31, dated October 18, 2024, we hereby enclose the Compliance Certificate with respect to Structured Digital Database maintained by the Company as per the aforesaid Regulations issued by M/s. [Name of PCS Firm], Practicing Company Secretaries, for the year ended March 31, 20XX.

You are requested to take the above on your record.

Thanking You

Yours Faithfully

For [Company Name]

[Signatory Name]

COMPANY SECRETARY & COMPLIANCE OFFICER

Membership No.: [Membership No.]

Compliance Certificate for the Financial Year Ended 31st March, 20XX

(Pursuant to Securities and Exchange Board of India (Prohibition of Insider Trading)

Regulations, 2015)

I, [Name of Practicing Company Secretary], Practicing Company Secretary, Proprietor of [Name of PCS Firm] (Company Secretaries) appointed by M/s. [Company Name] (Company) and aware of the compliance requirement of Structured Digital Database (SDD) pursuant to provisions of Regulation 3(5) and 3(6) of Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (PIT Regulations) and I certify that:

1. the Company has a Structured Digital Database in place;

2. control exists as to who can access the SDD;

3. all the UPSI disseminated in the reporting period have been captured in the Database;

4. the system has captured nature of UPSI along with date and time.

5. the database has been maintained internally and an audit trail is maintained

6. the database is non-tamper able and has the capability to maintain the records for 8 years.

I also confirm that the Company was required to capture [Number] ([Number in words]) number of events during the financial year ended 20XX-XX and has captured [Number] ([Number in words]) number of the said required events.

I would like to report that the non-compliance(s) was observed in the reporting period and the remedial action(s) taken along with timelines in this regard: [NOT APPLICABLE, AS NO NON-COMPLIANCE WAS OBSERVED / Details of non-compliance and remedial action]

For [Name of PCS Firm]

(Company Secretaries)

[Name of Practicing Company Secretary]

Practicing Company Secretary

FCS/ACS: [Membership No.]

COP No.: [COP No.]

UDIN: [UDIN Number]

Date: [DD-MM-YYYY]

Place: [City]