Company Update

PHOENIX TOWNSHIP LIMITED : Corp. Office : Hede House, 14, BEST Marg, Colaba, Mumbai - 400 001. Tel. : (9122 ) - 6159 0900 E-mall :admin@hbgindia.com Website : www.hbgindia.com Park Inn by Radisson Sequeira Vado, Candolim, Goa - 408616 Tel.: (91-832) 6633333/ 103 E-mail : info@pirgoa.com Phoenix lsland Resort Pozhiyoor PO, Poovar, Thiruvanathapuram, Poovar, Kerala - 695 513. Tel.: +91 97471 29948 bookings poovar@phoenixresortsin REGD.

OFF. : Durga Bhavan, Hede Gentre, Tonca, Panaji, Goa - 403 001 Tel.{(91-832)-6642724/6453265 E-mail : hbggoa@yahoo.co.n CIN : L67190GA1993PLC001327 Date: 27.05.2025 To, BSE Limited, Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai - 400001. : ission of Annual Secretarial Compliance R for year ended 315t March, 2025 Dear Sir, In Compliance of regulation 24A SEBI (Listing Obligation Disclosure Requirement) Regulation, 2015 Please find the enclosed copy of Annual Secretarial Compliance Report dated 27t May, 2025. Thanking You Managing Director (DIN: 01411689) MEMBER HEDE BUSINESS GROUP ----------------Page (0) Break---------------- KOTHARI H. & ASSOCIATES COMPANY SECRETARIES HITESH KOTHARI (LLB, B. Com, IP, FCS) SONAM JAIN (B. Com, FCS) 1 Fort: 815, 8th Floor, BSE Building, Dalal Street, Fort, Mumbai-400001. Office No.- 7715964607/ 9920629460 Kandivali: A 1, Satya Co-Op Housing Society, Opp.

Telephone Exchange, S V Road, Kandivali (West), Mumbai-400067.E-mail: info@khacs.com, Website: www.khacs.com SECRETARIAL COMPLIANCE REPORT OF PHOENIX TOWNSHIP LIMITED FOR THE YEAR ENDED 31ST MARCH, 2025 [Pursuant to the Regulation 24A of SEBI (Listing Obligation and Disclosure Requirements) Regulation, 2015 read with SEBI Circular No. CIR/CFD/CMD1/27/2019 dated February 8, 2019] To, The Board of Directors PHOENIX TOWNSHIP LIMITED We Kothari H. & Associates, Practising Company Secretaries, have examined: (a) all the documents and records made available to us and explanation provided by Phoenix Township 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, 2025 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 thereunder; and (b) the Securities Contracts (Regulation) Act, 1956 (“SCRA”), rules made thereunder and the Regulations, circulars, guidelines issued thereunder by the Securities and Exchange Board of India (“SEBI”); The specific Regulations, whose provisions and the circulars/ guidelines issued thereunder, have been examined, include:- (a) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015; (b) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018; (Not Applicable for the Review Period) (c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011; (d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (Not Applicable for the Review Period) (e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021; (Not Applicable for the Review Period) ----------------Page (1) Break---------------- KOTHARI H. & ASSOCIATES COMPANY SECRETARIES HITESH KOTHARI (LLB, B. Com, IP, FCS) SONAM JAIN (B. Com, FCS) 2 Fort: 815, 8th Floor, BSE Building, Dalal Street, Fort, Mumbai-400001. Office No.- 7715964607/ 9920629460 Kandivali: A 1, Satya Co-Op Housing Society, Opp.

Telephone Exchange, S V Road, Kandivali (West), Mumbai-400067.E-mail: info@khacs.com, Website: www.khacs.com (f) Securities and Exchange Board of India (Issue and Listing of Non – Convertible Securities) Regulations, 2021; (Not Applicable for the Review Period) (g) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015; (h) Any other regulations as applicable and circulars/ guidelines issued thereunder; and based on the above examination, We hereby report that, during the Review Period: (a) The listed entity has complied with the provisions of the above Regulations circulars/ guidelines issued thereunder, except in respect of matters specified below: ** ** The Company has received an email from the Stock Exchange regarding: The Company has received an email from BSE dated 15th July, 2024, regarding non-compliance of Regulation 23(9) for non-submission of related party transaction for the half year ended 31.03.2024 within the prescribed time limit, but the fine was paid by the company and complied the Regulation.

S r . N o . Compliance Requirement (Regulations/ circulars / guidelines including specific clause) Regulation / Circular No. Deviatio ns Action Taken by Typ e of Acti on Details of Violation Fine Amount Observation/ Remarks of the Practicing Company Secretary (PCS) Manage ment Respons e Remar ks 1 Disclosure of related party transactions on consolidated basis Regulatio n 23 (9) -- Fine levied by the BSE ** ** 5,900/- The Company had paid the fine levied for Non filing of Related Party Transaction within the prescribed time limit for half year ended on 31.03 2024 . The The delay was not intentio nal.

Fine has been paid by the Compa ny ----------------Page (2) Break---------------- KOTHARI H. & ASSOCIATES COMPANY SECRETARIES HITESH KOTHARI (LLB, B. Com, IP, FCS) SONAM JAIN (B. Com, FCS) 3 Fort: 815, 8th Floor, BSE Building, Dalal Street, Fort, Mumbai-400001. Office No.- 7715964607/ 9920629460 Kandivali: A 1, Satya Co-Op Housing Society, Opp.

Telephone Exchange, S V Road, Kandivali (West), Mumbai-400067.E-mail: info@khacs.com, Website: www.khacs.com (b) The listed entity has taken the following actions to comply with the observations made in previous reports: Sr. No . Observation s/ Remarks of the Practicing Company Secretary in the previous reports Observatio ns made in the secretarial compliance report for the year ended (The years are to be mentioned) Compliance Requireme nt (Regulation s /Circular/ Guidelines including specific clause) Details of Violation / Deviatio ns and actions taken /penalty imposed, if any on the listed entity Remedi al Actions, taken by the listed entity, if any Commen ts of the Practicin g Company Secretar y on the actions taken by the listed entity (C) We hereby report that, during the review period the compliance status of the listed entity with the following requirements: Sr. No Particulars Compliance Status (Yes/No/NA) Observation s/ Remarks by PCS* 1. 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 (ICSI). Yes 2. Adoption and timely updation of the Policies: • All applicable policies under SEBI 剥最畬慴椀潮猠 慲攠 慤潰瑥搠 睩瑨 瑨攀 慰灲潶慬 潦 戀潡牤 潦 摩爀散瑯爀猀 潦 瑨攀 汩猀琀敤⁥渀瑩琀椀攀猀⸠ • All the policies are in conformity 睩瑨 匀䕂䤠剥最畬慴椀潮猠慮搠桡瘀攠戀敥渀 牥瘀椀敷敤 ☀ 甀灤慴敤 潮 瑩洀攬 慳 瀀敲 夀敳 ----------------Page (3) Break---------------- KOTHARI H. & ASSOCIATES COMPANY SECRETARIES HITESH KOTHARI (LLB, B. Com, IP, FCS) SONAM JAIN (B. Com, FCS) 4 Fort: 815, 8th Floor, BSE Building, Dalal Street, Fort, Mumbai-400001. Office No.- 7715964607/ 9920629460 Kandivali: A 1, Satya Co-Op Housing Society, Opp.

Telephone Exchange, S V Road, Kandivali (West), Mumbai-400067.E-mail: info@khacs.com, Website: www.khacs.com the regulations/ circulars/guidelines issued by SEBI.

3. Maintenance and disclosures on Website: • The listed entity is maintaining a functional website. • Timely dissemination of the documents/ information under a separate section on the website. • Web-links provided in annual corporate governance reports under Regulation 27(2) are accurate and specific which redirects to the relevant document(s)/section of the website.

Yes 4. Disqualification of Director(s): None of the director(s) of the listed entity is/ are disqualified under Section 164 of Companies Act, 2013 as confirmed by the listed entity.

Yes 5. Details related to subsidiaries of listed entities have been examined w.r.t.: (a) Identification of material subsidiary companies.

(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. Yes 7. Performance Evaluation: The listed entity has conducted performance evaluation of the board, independent directors and the Yes ----------------Page (4) Break---------------- KOTHARI H. & ASSOCIATES COMPANY SECRETARIES HITESH KOTHARI (LLB, B. Com, IP, FCS) SONAM JAIN (B. Com, FCS) 5 Fort: 815, 8th Floor, BSE Building, Dalal Street, Fort, Mumbai-400001. Office No.- 7715964607/ 9920629460 Kandivali: A 1, Satya Co-Op Housing Society, Opp.

Telephone Exchange, S V Road, Kandivali (West), Mumbai-400067.E-mail: info@khacs.com, Website: www.khacs.com committees at the start of every financial year/during the financial year as prescribed in SEBI Regulations.

8. Related Party Transactions: (a) The listed entity has obtained prior approval of audit committee for all related party transactions; (b) In case no prior approval obtained, the listed entity shall provide detailed reasons along with confirmation whether the transactions were subsequently approved/ratified/rejected by the audit committee Yes 9. Disclosure of events or information: The listed entity has provided all the required disclosure(s) under Regulation 30 along with Schedule III of SEBI LODR Regulations, 2015 within the time limits prescribed thereunder.

Yes 10. Prohibition of Insider Trading: The listed entity is in compliance with Regulation 3(5) & 3(6) SEBI (Prohibition of Insider Trading) Regulations, 2015. Yes 11. Actions taken by SEBI or Stock Exchange(s), if any: No action(s) has been taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under SEBI Regulations and circulars/ guidelines issued thereunder (or) The actions taken against the listed entity/ its promoters/ directors/ subsidiaries Yes ----------------Page (5) Break---------------- KOTHARI H. & ASSOCIATES COMPANY SECRETARIES HITESH KOTHARI (LLB, B. Com, IP, FCS) SONAM JAIN (B. Com, FCS) 6 Fort: 815, 8th Floor, BSE Building, Dalal Street, Fort, Mumbai-400001. Office No.- 7715964607/ 9920629460 Kandivali: A 1, Satya Co-Op Housing Society, Opp.

Telephone Exchange, S V Road, Kandivali (West), Mumbai-400067.E-mail: info@khacs.com, Website: www.khacs.com *Observations/Remarks by PCS are mandatory if the Compliance status is provided as ‘No’ or,’NA’ We further, report that the listed entity is in compliance/ not in compliance with the disclosure requirements of Employee Benefit Scheme Documents in terms of regulation 46(2) (za) of the LODR Regulations.

Not Applicable Assumptions & limitation of scope and review: 1. 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 correctness and appropriateness of financial records and books of account of the listed entity.

4. This report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the SEBI (LODR) Regulations, 2015 and is neither an assurance as to the future viability of the listed entity nor of the efficacy or effectiveness with which the management has conducted the affairs of the listed entity. either by SEBI or by Stock Exchanges are specified in the last column.

12. Resignation of statutory auditors from the listed entity or its material subsidiaries: In case of resignation of statutory auditor from the listed entity or any of its material subsidiaries during the financial year, the listed entity and / or its material subsidiary(ies) has / have complied with paragraph 6.1 and 6.2 of section V-D of chapter V of the Master Circular on compliance with the provisions of the LODR Regulations by listed entities.

NA There was no resignation of statutory auditors from the Company or its material subsidiary 13. Additional Non-compliances, if any: No additional non-compliances observed for any SEBI regulation/circular/guidance note etc. except as reported above.

Yes ----------------Page (6) Break---------------- KOTHARI H. & ASSOCIATES COMPANY SECRETARIES HITESH KOTHARI (LLB, B. Com, IP, FCS) SONAM JAIN (B. Com, FCS) 7 Fort: 815, 8th Floor, BSE Building, Dalal Street, Fort, Mumbai-400001. Office No.- 7715964607/ 9920629460 Kandivali: A 1, Satya Co-Op Housing Society, Opp.

Telephone Exchange, S V Road, Kandivali (West), Mumbai-400067.E-mail: info@khacs.com, Website: www.khacs.com KOTHARI H & ASSOCIATES Company Secretaries (Peer review : 5312/2023) Hitesh Kothari FCS No: F6038 Place: Mumbai COP NO: 26758 Date: 27.05.2025 UDIN: F006038G000449019 ----------------Page (7) Break----------------