Pursuant to Regulation 24A of SEBI (LODR) Regulations, 2015, we are enclosing herewith the Annual Secretarial Compliance report for the year ended on 31st March, 2026
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Pervasive Commodities Ltd has filed its Annual Secretarial Compliance Report for FY2025-26, disclosing 9 instances of non-compliance with SEBI regulations. The violations include delayed submission of investor complaints statement (Regulation 13(3), Rs. 1,180 fine), delayed newspaper advertisement publication (Regulation 47), and several corporate governance lapses. Major governance-related fines include Rs. 4.60 lakh and Rs. 1.83 lakh for Board composition issues (Regulation 17), Rs. 1.84 lakh and Rs. 73,160 for Audit Committee gaps (Regulation 18), and similar amounts for Nomination and Remuneration Committee (Regulation 19), plus Rs. 1.06 lakh for not appointing a qualified Company Secretary. Total fines levied amount to approximately Rs. 11.65 lakh. Management states these governance provisions became applicable from May 20, 2025, and the company appointed an Independent Director on November 1, 2025, within the six-month compliance window. The company has filed waiver applications for governance-related fines.
The filing reveals weak internal compliance controls, with repeated violations across multiple quarters. Total fines of Rs. 11.65 lakh are modest relative to company size. The company claims compliance was achieved within prescribed timelines after governance rules became applicable. Investors should monitor whether the company maintains proper Board composition and committee structure going forward, as repeated non-compliance could attract regulatory action or impact investor confidence.