Company Update

DATE: 30.05.2025 TO, BSE LIMITED Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai- 400001 Company Scrip No. : 538817 Sub: Annual Secretarial Compliance Report for the year ended 31st March, 2025 Pursuant to Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 read with Circular No. CIR/CFD/CMD/1/27/2019 dated 8th February, 2019, please find enclosed Annual Secretarial Compliance Report for the year ended 31st March, 2025 issued by Mr. Kishor S Dudhatra, Practising Company Secretary.

We request you to take the above on record and acknowledge.

Thanking you, Yours sincerely, For CAPTAIN PIPES LIMITED KANTILAL M. GEDIA (WHOLETIME DIRECTOR) DIN: 00127949 Encl: Annual Secretarial Compliance Report Digitally signed by Kantilal Manilal GediyaDN: C=IN, O=Personal, T=6185, OID.2.5.4.65=ca696d784eb94c9286d423282b61ed54, Phone=768bf79255c78b2f039d1e09df9717909bb5b0c456be3db5fcfc3b292211b6e2, PostalCode=360002, S=Gujarat, SERIALNUMBER= 7b946936e4155cf08d658b9d623f35584dbb78ab4cc207e7bfa70e3bf2229019, CN=Kantilal Manilal GediyaReason: I am the author of this documentLocation: Date: 2025.05.30 13:40:32+05'30' Foxit PDF Reader Version: 12.0.2 Kantilal Manilal Gediya ----------------Page (0) Break---------------- 1 To, Date: 10.05.2025 The Board of Directors, CAPTAIN PIPES LIMITED CIN: L25191GJ2010PLC059094 Survey No-257, Plot No. 23 To 28, N.H.

No. 8-B, Shapar (Veraval), Rajkot - 360002 SECRETARIAL COMPLIANCE REPORT OF CAPTAIN PIPES LTD FOR THE FINANCIAL YEAR ENDED 31ST MARCH, 2025 I/We have conducted the review of the compliance of the applicable statutory provisions and the adherence to good corporate practices by CAPTAIN PIPES LTD, having its Registered Office at Survey No-257, Plot No. 23 To 28, N.H.

No. 8- B, Shapar(Veraval), Rajkot - 360002 IN.

Secretarial Review was conducted in a manner that provided me/us a reasonable basis for evaluating the corporate conducts/statutory compliances and to provide my/our observations thereon.

Based on my/our verification of the listed entity’s books, papers, minutes books, forms and returns filed and other records maintained by the listed entity and also the information provided by the listed entity, its officers, agents and authorized representatives during the conduct of Secretarial Review, I/we hereby report that the listed entity has, during the review period covering the financial year ended on 31st MARCH, 2025 complied with the statutory provisions listed hereunder in the manner and subject to the reporting made hereinafter : I/We KISHOR DUDHATRA - PRACTISING COMPANY SECRETARY have examined: (a) all the documents and records made available to us and explanation provided by CAPTAIN PIPES LTD , (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 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; (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 DURING THE PERIOD UNDER REVIEW (e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021; NOT APPLICABLE DURING THE PERIOD UNDER REVIEW (f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021; NOT APPLICABLE DURING THE PERIOD UNDER REVIEW ----------------Page (1) Break---------------- 2 (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, I/We hereby report that, during the Review Period: I. (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 No Compliance Requirement (Regulations/ circulars/ guide- lines including specific clause) Regulatio n/ Circular No. Deviati ons Action Taken by Type of Action Details of violaton Fine Amount Observations / Remarks of the Practicing Company Secretary Manage ment Response Remar ks NIL (b) The listed entity has taken the following actions to comply with the observations made in previous reports: Sr No Compliance Requirement(Re gulations/ circulars/ guide- lines including specific clause) Regulati on/ Circular No. Deviat ions Action Taken by Type of Action Details of Violation Fine Amou nt Observations / Re- marks of the Practicing Com pany Secretary Manage ment Response Remar ks NA II.

Compliances related to resignation of statutory auditors from listed entities and their material subsidiaries as per SEBI Circular CIR/CFD/CMD1/114/2019 dated 18th October, 2019: Sr No. Particulars Compliance Status (Yes/No/ NA) Observations/ Remarks by PCS* 1. Compliances with the following conditions while appointing/re-appointing an auditor i. If the auditor has resigned within 45 days from the end of a quarter of a financial year, the auditor before such resignation, has issued the limited review/ audit report for such quarter; or ii.

If the auditor has resigned after 45 days from the end of a quarter of a financial year, the auditor before such resignation, has issued the limited review/ audit report for such quarter as well as the next quarter; or iii.

If the auditor has signed the limited review/ audit report for the first three quarters of a financial year, the auditor before such resignation, has issued the limited review/ audit report for the last quarter of such financial year as well as the audit report for such financial year.

NA - - - 2. Other conditions relating to resignation of statutory auditor i. Reporting of concerns by Auditor with respect to the listed entity/its material subsidiary to the Audit Committee: a. In case of any concern with the management of the listed entity/material subsidiary such as non-availability of information / non- cooperation by the management which has hampered the audit process, the auditor has approached the Chairman of the Audit Committee of the listed entity and the NA ----------------Page (2) Break---------------- 3 Audit Committee shall receive such concern directly and immediately without specifically waiting for the quarterly Audit Committee meetings. b. In case the auditor proposes to resign, all concerns with respect to the proposed resignation, along with relevant documents has been brought to the notice of the Audit Committee.

In cases where the proposed resignation is due to non-receipt of information / explanation from the company, the auditor has informed the Audit Committee the details of information/ explanation sought and not provided by the management, as applicable c. The Audit Committee / Board of Directors, as the case may be, deliberated on the matter on receipt of such information from the auditor relating to the proposal to resign as mentioned above and communicate its views to the management and the auditor. ii.

Disclaimer in case of non-receipt of information: The auditor has provided an appropriate disclaimer in its audit report, which is in accordance with the Standards of Auditing as specified by ICAI / NFRA, in case where the listed entity/ its material subsidiary has not provided information as required by the auditor. - NA - - - 3. The listed entity / its material subsidiary has obtained information from the Auditor upon resignation, in the format as specified in Annexure-A in SEBI Circular CIR/ CFD/CMD1/114/2019 dated 18th October, 2019. NA ----------------Page (3) Break---------------- III.

I/we hereby report that, during the review period the compliance status of the listed entity is appended as below : Sr. No. Particulars Compliance Status (Yes/No/NA) Observations/ 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 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 separate section on the website
Web-links provided in annual corporate governance reports under Regulation 27(2) are accurate and specific which re- directs to the relevant document(s)/section of the website YES YES YES - - 4. Disqualification of Director: None of the Director(s) of the Company 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 NA Company has no any subsidiary company.

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 - ----------------Page (4) Break---------------- 8. Related Party Transactions: (a) The listed entity has obtained prior approval of Audit Committee for all related party transactions; or (b) The listed entity has provided detailed reasons along with confirmation whether the transactions were subsequently approved/ratified/rejected by the Audit Committee, in case no prior approval has been obtained.

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 except as provided under separate paragraph herein.

NA No such event during the period under review 12. Additional Non-compliances, if any: No additional non-compliance observed for any SEBI regulation/circular/guidance note etc. NA No such event during the period under review ----------------Page (5) Break---------------- 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 Accounts of the listed entity.

4. This Report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the SEBI (Listing Obligations and Disclosure Requirements) 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.

DATE : 10.05.2025 KISHOR DUDHATRA PLACE : AHMADABAD COMPANY SECRETARIES PROPRIETOR M. NO. FCS 7236 C.P.NO.

3959 PEER REVIEW CERTIFICATE NO.: 1919/2022 UDIN NO.: F007236G000313938 Digitally signed by Kishor Savjibhai DudhatraDN: C=IN, O=Personal, T=1337, OID.2.5.4.65=3mjcifkazwhb4n2g916o78vde5p0yxrt, Phone=61af04d59471671c7040140287773c103523de75329e195404ef257312026c16, PostalCode=360001, S =Gujarat, SERIALNUMBER=787f9cdc944006ba143af0f38b0e381dcd71bb4e00b87e505a68ebea8260a57b, CN=Kishor Savjibhai DudhatraReason: I am the author of this document Location: Date: 2025.05.10 19:08:37+05'30'Foxit PDF Reader Version: 12.0.2 Kishor Savjibhai Dudhatra ----------------Page (6) Break----------------