SHRADHA IN PROJECTS LIMITED

14s gcr

\c)4a, Company Secretary & Compliance Officer

(ICSI M No. A47702)

Komal Shrimankar

SHRADHA IN PROJECTS LIMITED

SH RADHA

[Formerly known as Shradha Infraprojects (Nagpur) Limited] CIN - L45200MH1997PLC110971

Regd. Ofc.: Shradha House, Near Shri Mohini Complex, Kingsway, Block No F/8, Nagpur 440001, Maharashtra, India Email-id: [email protected], Phone No. 0712-6617181

Through Online Filing

Ref No: SINL/CS/ 65

Date: May 15, 2019

To,

The Manager - Listing Department,

SME Platform — NSE EMERGE

National Stock Exchange of India Limited

Exchange Plaza, C-1, Block —G,

Bandra Kurla Complex, Bandra (East),

Mumbai- 400051

Reference: Symbol: SHRADHA (Series: SM) INE 715 Y 01015

Subject: Submission of Annual Secretarial Compliance Report for the year ended March 31, 2019

Dear Sir/Madam,

With reference to SEBI Circular No. CIR/CFD/CMD1/27/2019 dated 8th February 2019, all listed

Companies has to submit the Annual Secretarial Compliance Report within 60 days from the end of the financial year ended March 31, 2019 issued by a Practicing Company Secretary based on a check of the compliance will all applicable SEBI Regulations and circulars / guidelines issued thereunder.

Accordingly, we are enclosing the copy of Annual Secretarial Compliance Report dated 05t" May 2019 for

the financial year ended March 31, 2019 issued by CS Riddhita Agrawal, Practicing Company Secretary.

Kindly take the same on your records.

Thanking You,

Yours faithfully,

For SHRADHA INFRAPROJECTS LIMITED

[Formerly known as Shradha Infraprojects (Nagpur) Limited]

Encl.: As stated above

8S CS RIDDHITAAGRAWALPracticing Company Secretary

B.Com,ACSAddress: L-702, Rail Vihar, Sector 4, Kharghar, Navi Mumbai - 410210

Contact: +91 -9096962064 I Email id:[email protected]

SECRETARIAL COMPLIANCE REPORTOF

SHRADHA INFRAPROJECTS LIMITED[Formerly known as Shradha Infraprojects (Nagpur) Limited]

For the year ended March 31,2019

I, CS Riddhita Agrawal, Practicing Company Secretary, have examined:

(a) all the documents and records made available to me and explanation provided by themanagement of Shradha Infraprojects Limited [Formerly known as ShradhaInfraprojects (Nagpur) Limited]("the listed entity"),

(b) the filings/ submissions made by the listed entity to the stock exchanges,(c) website of the listed entity,(cl) any other document/ filing, as may be relevant, which has been relied upon to make

this certification,

for the year ended March 31, 2019 ("Review Period") in respect of compliance with theprovisions of :

(a) the Securities and Exchange Board of India Act, 1992 ("SEBI Act") and theRegulations, circulars, guidelines issued thereunder; and

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

And the specific Regulations, whose proVISIOns and the circulars/ guidelines issuedthereunder, have been examined, includes-

(c) Securities and Exchange Board of India (Listing Obligations and DisclosureRequirements) Regulations, 2015;

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os CS RIDDHITAAGRAWALPracticing Company Secretary



(d) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements)Regulations, 2018;

(e) Securities and Exchange Board of India (Substantial Acquisition of Shares andTakeovers) Regulations, 2011;

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

(g) Securities and Exchange Board of India (Registrars to an Issue and Share TransferAgents) Regulations, 1993 regarding the Companies Act and dealing with client

(h) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018(Not applicable to the Company during the Audit Period);

~i) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations,2014(Not applicable to the Company during the Audit Period);

;.

(j) Securities and Exchange Board of India (Issue and Listing of Debt Securities).~.

Regulations, 2008 (Not applicable to the Company during the Audit Period),

(k) Securities and Exchange Board of India(Issue and Listing of Non- Convertible andRedeemable Preference Shares) Regulations, 2013(Not applicable to the Companyduring the Audit Period);

Based on the above examination, I hereby report that, during the Review Period:

(a) The listed entity has complied with the provisions of the above Regulations andcirculars / guidelines issued thereunder, except in respect of matters specified below:-

Observations/ Remarksof the

Sr.No. Compliance Requirement Deviations(Regulations/ Circulars / Guidelinesincluding specific clause)

NIL

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os CS RIDDHITAAGRAWALPracticing Company Secretary



(b) The listed entity has maintained proper records under the provisions of the aboveRegulations and circulars/ guidelines issued thereunder insofar as it appears from myexamination of those records.

(c) The following are the details of actions taken against the listed entity/ its promoters/directors/ material subsidiaries either by SEB!or by Stock Exchanges (including underthe Standard Operating Procedures issued by SEB! through various circulars) underthe aforesaid Acts/ Regulations and circulars/ guidelines issuedthereunder:

Sr.No. Action taken Details of Details of Observations/ Remarks

by violation action taken of the PracticingE.g. fines, Company Secretarywarning letter,debarment, etc.

NIL

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

Sr.No. Observations Observations Actions taken Comments of theof the made ill the by the listed Practicing CompanyPracticing secretarial entity, if any Secretary on the actionsCompany compliance taken by the listedSecretary in report for the entitythe preVIOUSyear ended ...reports (The years are to

be mentioned)

Not Applicable

Signature:

Place: Mumbai

Date: 10th May 2019Membership No.: FCSNo.:

CPNo.:1005412917

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Documents

SHRADHA IN PROJECTS LIMITED