Company Update

Ref: DIL/SEC/2025-26 May 27, 2025 The Listing Manager BSE Limited Phiroze Jeejeebhoy Towers Dalal Street, Mumbai -400001 Scrip Code- 500068 Name of the Company - DISA India Limited Dear Sir, Sub: Annual Secretarial Compliance Report for the year ended March 31, 2025. Pursuant to Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, read with relevant SEBI Circulars issued from time to time, please find attached the Annual Secretarial Compliance Report issued by Mr. Vijayakrishna K T, Practicing Company Secretary, for the Financial Year ended March 31, 2025. This is for your information and records.

Yours sincerely, For DISA India Limited, Shrithee M S Company Secretary & Compliance Officer Encl: As above DISA India Limited Registered & Corporate Office: 6th Floor, S-604, World Trade Center (WTC), Brigade Gateway Campus, 26/1, Dr Rajkumar Road, Malleswaram-Rajajinagar, Bangalore-560 055, Karnataka, India T: +9180 2249 6700-03 I F: +91 80 2249 6750 I E: bangalore@noricangroup.com W: www.noricangroup.com ON: L8S110KA1984PLC006116 I GST: 29AAACG5030f1ZY We are Norican : DISA I ltalPresseGauss I Monitizer I Simpson Regional Sales: New Delhi: delhi@noricangroup.com Kolkata: kolkata@noricangroup.com Pune: pune@noricangroup.com Parts & Services: cdc.india@noricangroup.com I StrikoWestofen I Wheelabrator Norican Group Shaping Industry Manufacturing Facility: Tumkur: No. 28·32, Satyamangala Industrial Area, Tumkur-572104, Karnataka, India.

T: +91816 6602000/01 E: tumkur@noricangroup.com ----------------Page (0) Break---------------- VIJAYAKRISHNA KT # 496/4, II Floor, 10th Cross Near Bashyam Circle, Sadashivanagar, Bangalore -560 080, INDIA BBM, LLB, FCS, ACMA Company Secretary Tel : +91 80 23610847, Mob.: 9448481544 e-mail : vijaykt@vjkt.in SECRETARIAL COMPLIANCE REPORT OF DISA INDIA LIMITED CIN: L85110KA1984PLC006116 ktvijaykrishna@gmail .corn FOR THE FINANCIAL YEAR ENDED 315T MARCH, 2025 I, Vijayakrishna KT, Practising Company Secretary, have examined: (a) all the documents and records made available to us and explanation provided by Disa India 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 Report. for the financial year ended 31st March, 2025 ("Review Period") 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 SEBI; The specific Regulations, whose provIsIons and the circulars/ guidelines issued thereunder, have been examined, include: - (a) Securities and Exchange Board of India (LODR) Regulations, 2015; (b) Securities and Exchange Board of India (Issue of Capital and Disclosure Re uirements) Regulations, 2018; nd Exchange Board of India (Substantial Acquisition of Shares and Regulations, 2011; . 66, Sathyanarayana Layout, West of Chord Road, III Stage, Bangalore -560 079, INDIA ----------------Page (1) Break---------------- (d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021; (f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021 (g) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015; (h) other regulations as applicable. and circulars/ guidelines issued thereunder; and 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 and circulars/ guidelines issued thereunder, except in respect of matters specified below: Sr. Compl Regul Deviatio Acti Type Details Fine Observ Mana Re- No iance ation/ ns on of of Amou ations geme mar Requir Circul Take Action Violati nt /Remar nt ks ement ar No. n by on ks Resp (Regul of the onse ations/ Practici circula ng rs/ Compa guideli ny nes includi Secreta ng ry specifi (PCS) C clause NIL ----------------Page (2) Break---------------- (b) The listed entity has taken the following actions to comply with the observations made in previous reports: Sr. Observation Observation Compliance Details of Remedi Comment No s/ Remarks s made in Requiremen violation/ al s of the . of the the t Deviation actions, PCS Practicing Secretarial (Regulation sand if any, on the Company Compliance sf actions taken by actions Secretary report for circulars/ taken the taken by (PCS) in the the year guidelines /penalty listed the listed previous ended including imposed, entity entity reports) specific if any, on clause) the listed ..... (The entity years are to be mentioned) NIL (Note: 1. Provide the list of all the observations in the repo11 for the previous year along with the actions taken by the listed entity on those observations.

2. /\dd the list of all observations in the reports pertaining to the periods prior to the previous year in case the entity has not taken sufficient steps to address the concerns raised/ observations.

I. I hereby report that, during the review period the compliance status of the listed entity with the following requirements: Sr. No 1. Particula rs Secretarial Standards: The compliances of the listed entity are in accordance with the applicable Secretarial ndards (SS) issued by the Institute of Company Secretaries of India (ICSI). Complian ce Status(Ye s/No/NA) YES Observations /Remarks by PCS* ----------------Page (3) Break---------------- 4 2. 3. 4. 5. 6. Adoption and timely updation of the Policies: • All applicable policies under SEBI Regulations are adopted with the approval of Board of Directors of the listed entities. • All the policies are in conformity with SEBI Regulations and have been reviewed & updated on time, as per the regulations/ circulars/guidelines issued by SEBI.

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.

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.

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.

Preservation of Documents: The listed entity is preserving and maintaining .. records as prescribed under SEBI ..... ions and disposal of records as per /..:::.::-/ :: poli~~ preservation of documents and YES YES YES YES YES ----------------Page (4) Break---------------- 7. 8. 9. 10. 11. archival policy prescribed under SEBI LODR Regulations, 2015. 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.

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.

Disclosure of events or information: The listed entity has provided all the required disclosure(s) under Regulation 30 along with Schedule Ill of SEBI LODR Regulations, 2015 within the time limits prescribed thereunder.

Prohibition of Insider Trading: The listed entity is in compliance with Regulation 3(5) & 3(6) SEBI (Prohibition of Insider Trading) Regulations, 2015. 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 (i eluding under the Standard Operating rocedures issued by SEBI through various __,.,--i..;.,.rtulars) under SEBI Regulations and rs/ guidelines issued thereunder (or) YES YES YES YES YES YES Certain ransactions were ratified and approved subsequently. ----------------Page (5) Break---------------- 12. 13. The actions taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges are specified in the last column.

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.

Additional Non-Compliances, if any: No additional non-compliances obseNed for any SEBI regulation/circular/guidance note etc. except as reported above.

NA NA During the review period, there has been no change in he Statutory Auditors.

During the review period, no additional non - compliance was obseNed.

ObseNations/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 (Note: In case of non-compliance, details of such non-compliance need to be mentioned) 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. responsibility is to report based upon our examination of relevant nd information.

This is neither an audit nor an expression of ----------------Page (6) Break---------------- 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.

Place: Bengaluru Date: 21st May, 2025 retary : 8 CP: 980 7 : F001788G000403365 Peer Review Certificate No. 1883/2022 ----------------Page (7) Break----------------