Sarla Performance Fibers Limited has filed its Annual Secretarial Compliance Report for the financial year ended March 31, 2026, with BSE and NSE exchanges. The report, mandated under Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, was prepared by practicing company secretary CS Swati Gupta.

Regulatory Compliance Overview

The secretarial audit examined the company's compliance with various SEBI regulations including LODR Regulations 2015, Substantial Acquisition of Shares and Takeovers Regulations 2011, and Prohibition of Insider Trading Regulations 2015. The review covered all filings, submissions to stock exchanges, and corporate governance practices during FY26.

Stock Exchange Clarifications

The report identified four instances where stock exchanges sought clarifications from the company during the review period:

Technical Filing Corrections

The most significant clarification involved BSE's query regarding face value figures in the September 2025 quarterly results. The company explained that the XBRL instance document incorrectly reflected the aggregate paid-up equity share capital amount of ₹835.03 Lakhs instead of the unit face value of Re. 1 per share. This technical error was promptly corrected through a revised XBRL submission.

Previous Year Follow-up

The report also addressed a pending matter from the previous year regarding a Corporate Governance Report filing delay for the June 2023 quarter. NSE had imposed a penalty of Rs. 58,000 plus 18% GST, against which the company filed a waiver application by paying Rs. 11,800. The response to this waiver application remains pending with the stock exchange.

Compliance Status Assessment

The secretarial audit confirmed the company's adherence to key compliance requirements:

• Secretarial Standards: Full compliance with applicable ICSI standards
• Policy Framework: Timely adoption and updates of SEBI-mandated policies
• Website Maintenance: Functional website with proper document disclosures
• Director Qualifications: No disqualification issues under Companies Act 2013
• Related Party Transactions: Proper audit committee approvals obtained

Audit Scope and Limitations

CS Swati Gupta noted that the audit focused on regulatory compliance verification rather than financial record accuracy. The report serves the specific purpose of Regulation 24A(2) compliance and does not constitute an assurance regarding the company's future viability or management effectiveness.

The company operates from multiple locations including its registered office and Works 1 at Silvassa, along with additional manufacturing facilities in Dadra and Vapi, Gujarat. The secretarial compliance report reinforces the company's commitment to maintaining regulatory standards while addressing technical filing challenges through prompt corrective measures.

Sarla Performance Fibers Limited has informed stock exchanges that it does not fall under the Large Corporate classification as per SEBI's regulatory framework for fund raising through debt securities. The company made this disclosure on April 13, 2026, to both BSE and NSE, clarifying its status regarding applicable regulatory requirements.

Regulatory Compliance Disclosure

The disclosure was made in reference to multiple SEBI circulars, including SEBI/HO/DDHS/DDHS-RACPOD1/P/CIR/2023/172 dated October 19, 2023, and related operational circulars from August 10, 2021, and November 26, 2018. These circulars establish the framework for fund raising by issuance of debt securities by Large Corporate Entities.

Financial Position and Classification Criteria

The company's financial position as of March 31, 2026, clearly demonstrates its non-qualification for Large Corporate status:

The company's total outstanding long-term borrowings of ₹40.33 crore fall significantly below the ₹1,000 crore threshold specified under Clause 3.2(b) of the SEBI Circular dated October 19, 2023, for identification as a Large Corporate.

Corporate Details and Operations

Sarla Performance Fibers Limited operates with CIN L31909DN1993PLC000056 and maintains multiple manufacturing facilities across different locations. The company has its registered office and primary works at Amli Piparia Industrial Estate in Silvassa, along with additional manufacturing units in Dadra and Vapi, Gujarat.

Regulatory Implications

Since the company does not meet the Large Corporate criteria, the specific framework applicable to Large Corporates regarding debt securities issuance is not applicable to Sarla Performance Fibers Limited. This clarification helps investors and stakeholders understand the regulatory environment under which the company operates.

The disclosure was signed by Company Secretary & Compliance Officer Mustafa Manasawala and Chief Financial Officer Kayvanna Shah, ensuring proper corporate governance compliance. The company has designated NSE as the stock exchange where any applicable fines would be paid in case of regulatory shortfalls, though such provisions do not currently apply given its non-Large Corporate status.