Date: May 29, 2026

Regulatory Compliance Disclosure

Nalwa Sons Investments Limited submitted its Annual Secretarial Compliance Report for the financial year ended March 31, 2026 to BSE Limited and National Stock Exchange of India Limited. The report was prepared by M/s. Rajesh Garg & Co., Practicing Company Secretaries and Secretarial Auditors of the Company, in accordance with Regulation 24A(2) of SEBI Listing Regulations.

Historical Compliance Matter Resolution

The report disclosed one historical compliance matter from previous years that has been resolved:

  • During FY 2021-22, there was a delay in reporting a change of more than 2% in shareholding of promoter and promoter group of Shalimar Paints Limited under Regulation 29(2) of SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011.
  • The company is a shareholder and one of the Persons Acting in Concert (PACs) and part of the promoter group of Shalimar Paints Limited.
  • In March 2022, 1,65,000 equity shares (equivalent to 0.23% of share capital) of Shalimar Paints Limited were acquired by Ms. Urvi Jindal, one of the PACs, through inter-se transfer amongst immediate relatives.
  • This transaction, along with other inter-se transfers by PACs, resulted in a change of more than 2% of the total shareholding.
  • The requisite disclosure under SAST Regulations, which was initially inadvertently missed, was given by Ms. Urvi Jindal on April 17, 2024.
  • Settlement applications were filed with SEBI, resulting in Settlement Order No. SO/2024-25/PSD Settlement/S-26 dated March 13, 2025 received on March 17, 2025.
  • A settlement amount of ₹3,04,500 (Rupees Three Lakh Four Thousand Five Hundred only) was paid by Ms. Urvi Jindal on a joint and several liability basis including on behalf of all PACs during FY 2025-26.
  • The company stated there is no financial impact on the company and no material impact of such settlement order on the financial, operational or other activities of the company.

Current Year Compliance Status

The secretarial compliance report for FY 2025-26 confirmed the following compliance status:

Secretarial Standards: Yes - Compliances are in accordance with applicable Secretarial Standards issued by ICSI.

Policy Adoption and Updates: Yes - All applicable policies under SEBI Regulations are adopted with board approval and are in conformity with SEBI Regulations, reviewed and updated on time.

Website Maintenance and Disclosures: Yes - Functional website maintained with timely dissemination of documents/information and accurate web-links in annual corporate governance reports.

Director Disqualification: Yes - No directors are disqualified under Section 164 of Companies Act, 2013, verified through director declarations, MCA website filings, and ROC disqualified directors list.

Subsidiary Details: Yes - Examination of material subsidiary identification and disclosure requirements completed.

Document Preservation: Yes - Documents are preserved as per archival policy prescribed under Listing Regulations.

Performance Evaluation: Yes - Performance evaluation of Board, Independent Directors and Committees conducted at start of FY 2025-26, noted in Board Meeting dated May 28, 2025 and disclosed in annual report for FY 2024-25.

Related Party Transactions: Yes - Prior approval of Audit Committee obtained for all related party transactions. No instances requiring ratification/rejection.

Event Disclosures: Yes - All required disclosures under Regulation 30 along with Schedule III of SEBI LODR Regulations provided within prescribed time limits (verified on sample basis).

Insider Trading Compliance: Yes - Compliance with Regulation 3(5) & 3(6) of SEBI (Prohibition of Insider Trading) Regulations, 2015 (verified on sample basis).

SEBI/Stock Exchange Actions: No - No actions taken against the listed entity/its promoters/directors/subsidiaries by SEBI or Stock Exchanges under SEBI Regulations and circulars/guidelines.

Auditor Resignation: NA - No resignation of statutory auditors from the company or its material subsidiaries.

Additional Non-compliances: NA - No additional non-compliance observed for any SEBI regulation/circular/guidance note.

Employee Benefit Scheme: NA - The company does not have any Employee Stock Option Scheme.

No material disclosures under the following sections:

KMP / Board / Auditor Changes, Dividend Declaration, Board Meeting Outcomes, Financial Results, Disinvestment / Strategic Actions, Media Release / Investor Communication