Ahluwalia Contracts (India) Limited has announced the opening of a special window to facilitate the transfer and dematerialization of physical securities, following regulatory guidelines issued by the Securities and Exchange Board of India (SEBI).

Special Window Details

Pursuant to SEBI Circular No. HO/38/13/11(2)2026-MIRSD-POD/1/3750/2026 dated January 30, 2026, the company has opened a special window that will remain operational for one year. The window provides shareholders with an opportunity to transfer and dematerialize physical securities that were sold or purchased prior to April 1, 2019.

Scope of Coverage

The special window extends beyond new applications to include previously submitted transfer requests that faced processing issues. This facility is available for transfer requests that were:

• Previously rejected due to document deficiencies
• Returned for procedural issues
• Not attended to for various reasons
• Not processed due to other documentation problems

Transfer Conditions and Restrictions

Securities transferred under this special window will be subject to specific conditions designed to ensure regulatory compliance. All transferred securities will be mandatorily credited to the transferee only in dematerialized form. Additionally, these securities will be subject to a lock-in period of one year from the date of registration of transfer.

During the lock-in period, the transferred securities cannot be:

• Transferred to another party
• Lien-marked for any purpose
• Pledged as collateral

Application Process

Eligible shareholders can submit their transfer requests along with requisite documents to the company's Registrar and Transfer Agent (RTA). The designated RTA is MUFG Intime India Private Limited, Unit: Ahluwalia Contracts (India) Limited.

Regulatory Compliance

The announcement was made in compliance with Regulation 47(1)(b) of SEBI Listing Regulations, 2015 as amended. The company published the notice in Financial Express (English) and Jansatta (Hindi) newspapers on April 24, 2026, ensuring proper dissemination of information to all stakeholders.

The notice was signed by Vipin Kumar Tiwari, Company Secretary, and submitted to major stock exchanges including BSE Limited, National Stock Exchange of India Limited, and Calcutta Stock Exchange Limited, referencing the company's scrip codes BSE: 532811 and NSE: AHLUCONT.

Ahluwalia Contracts (India) Limited has received an administrative warning from the Securities and Exchange Board of India (SEBI) for violating Risk Management Committee meeting frequency requirements under the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The company has now provided a formal clarification to BSE Limited addressing the regulatory breach and outlining its commitment to future compliance.

Regulatory Violation Details

The non-compliance centered on Regulation 21(3C) of SEBI LODR Regulations, 2015, which mandates that Risk Management Committee meetings be conducted such that no more than 180 days elapse between consecutive meetings. The company's Risk Management Committee meetings were held with a significant gap that breached this requirement.

SEBI Warning and Regulatory Framework

SEBI issued the administrative warning letter on July 9, 2024, addressing the Corporate Governance Reports for the period from March 2023 to March 2024. The warning letter, signed by Jitendra Kumar, Deputy General Manager of the Corporation Finance Department, emphasized the serious nature of the compliance breach.

The SEBI LODR Regulations establish specific requirements for Risk Management Committee operations. Regulation 21(3A) mandates that Risk Management Committees meet at least twice per year, while Regulation 21(3C) ensures continuous oversight by limiting gaps between consecutive meetings to 180 days maximum.

Company's Formal Clarification Response

Ahluwalia Contracts submitted its formal clarification to BSE Limited on April 7, 2026, acknowledging the regulatory breach and providing detailed explanations. The company confirmed that while it met the requirement of holding at least two Risk Management Committee meetings in the same financial year, the gap between meetings exceeded the prescribed 180-day limit.

Key points from the company's response include recognition of the 270-day gap violation, commitment to future compliance with Regulation 21(3C), acknowledgment that the delay in intimating the SEBI letter to stock exchanges was unintentional, and assurance of improved compliance procedures.

Future Compliance Commitment

The company has committed to ensuring compliance with SEBI LODR requirements going forward, specifically stating it will keep the 180-day requirement in mind for future Risk Management Committee meetings. SEBI warned that any future aberrations would be viewed seriously and could result in appropriate regulatory action. The warning letter has been directed to be placed before the company's Board of Directors and disseminated to stock exchanges for their information and records.