Company Update

GGL/SE/2025-26/P13 Date: May 30, 2025 To The General Manager Listing, The Corporate Relations Department, BSE LIMITED PJ Towers, 25th floor, Dalal Street, Mumbai -400 001. Dear Sir/ Madam, Sub: Annual Secretarial Compliance Report for the Financial Year ended 31st March, 2025 under Regulation 24A of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 Ref: Gautam Gems Limited (BSE Script Code: 540936) Pursuant to Regulation 24A(2) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended, read with the applicable circulars issued by the Securities and Exchange Board of India and BSE Limited ,please find enclosed herewith the Annual Secretarial Compliance Report of Gautam Gems Limited for the year ended March 31, 2025, issued by Neelam Somani & Associates, Practicing Company Secretaries, secretarial auditors of the Company.

You are kindly requested to take above information on record.

Thanking you For Gautam Gems Limited Gautam P. Sheth Managing Director DIN: 06748854 Encl: As Stated ----------------Page (0) Break---------------- 1 CS Neelam Somani & Associates COMPANY SECRETARIES Address: C-1001, Sarovar landmark, Gordhanvadi Cross Road, Kankaria, Ahmedabad-380022, Gujarat.

Contact: +91-8638402502 Email: neelamsomani90@gmail.com ANNUAL SECRETARIAL COMPLIANCE REPORT Secretarial Compliance Report of Gautam Gems Limited for the financial year ended 31st March, 2025 I have examined: (a) all the documents and records made available to us and explanation provided by Gautam Gems 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 Requirements) Regulations, 2018; NOT APPLICABLE (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 (e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021; NOT APPLICABLE (f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021; NOT APPLICABLE ----------------Page (1) Break---------------- 2 (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 I. I 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 As per the representation received the Company has done the Compliances as per the Secretarial Standards issued by ICSI 2. 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.

Yes Yes 3. Maintenance and disclosures on Website:  The listed entity is maintaining a functional website.  Timely dissemination of the documents/ information under a Yes Yes Yes ----------------Page (2) Break---------------- 3 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.

NA There is no material subsidiary company as per the information received 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 committees at the start of every financial year/during the financial year as prescribed in SEBI Regulations.

Yes 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, Yes NA The Company has obtained the prior approval. ----------------Page (3) Break---------------- 4 the listed entity shall provide detailed reasons along with confirmation whether the transactions were subsequently approved/ratified/rejected by the audit committee.

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 either by SEBI or by Stock Exchanges are specified in the last column.

NA No action has been taken against the Company by SEBI or Stock Exchange 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 Yes The Statutory Auditors has been appointed as per the regulations of SEBI (LODR) Regulations, 2015 ----------------Page (4) Break---------------- 5 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.

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

No The SOP fine was imposed on the Company under regulation 24A & 19(1)/19(2) of SEBI (LODR) Regulations, 2015 during the year under review.

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.

Neelam Somani & Associates Neelam Rathi FCS No.: 10993 CP No.: 12454 UDIN : F010993G000502946 Peer Review No. 5612/2024 Place: Ahmedabad Date: 30/05/2025 NEELAM RATHI Digitally signed by NEELAM RATHI Date: 2025.05.30 12:25:09 +05'30' ----------------Page (5) Break----------------