Action(s) initiated or orders passed

Date: 12-09-2026 Listing Operations Listing Department BSE Limited, National Stock Exchange of India P J Towers, Dalal Street, Limited, Mumbai-400001, India Exchange Plaza, C-1, Block G, Bandra Kurla Complex, Scrip Code: 543263 Bandra Debentures Scrip Code: (E ) Mumbai – 400051 940727,940717,940317,940325,940319, 940323,939639,939655,940725,940321, Symbol: SMCGLOBAL 939651,939657,939643,940327,939647, 940719,940721 and 940723 Subject: Disclosure of the Settlement Order Passed by SEBI in Respect of Pulin Comtrade Limited (Wholly Owned Subsidiary). Dear Sir/ Ma’am, Pursuant to Regulation 30 read with Schedule III of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, we hereby inform that the our wholly subsidiary Company Pulin Comtrade Limited (formerly known as SMC Comtrade Limited) has received a Settlement Order passed by the Securities and Exchange Board of India (SEBI) in respect of settlement applications filed under the National Spot Exchange Limited (NSEL) Settlement Scheme 2025. The above intimation is also being made available on the Company's website at www.smcindiaonline.com. Kindly take the same on record. Thanking You, For SMC Global Securities Limited Suman Kumar E.V.P. (Corporate Affairs & Legal), Company Secretary& General Counsel Membership No. F5824 Annexure 1: Details as required under Regulation 30 are as under: Annexure 1: S. No. Particulars Information 1 Name of the Authority Securities and Exchange Board of India (SEBI) 2 Nature and details of the Settlement order in favour of Pulin Comtrade Limited action(s) taken / (formerly known as SMC Comtrade Limited), wholly order(s) passed: owned subsidiary of SMC Global Securities Limited w.r.t. 6 months of voluntary debarment from trading in proprietary capacity and from taking up new clients in commodity segment and payment of settlement amount of Rs. 9,10,780 3 Date of receipt of 11th September, 2026 direction / order: 4 Details of violation(s) / Pulin Comtrade Limited (formerly known as SMC contravention(s): Comtrade Limited), in its capacity as a broker/member, had facilitated certain transactions relating to paired contracts traded on the National Spot Exchange Limited (“NSEL”), in respect of which regulatory proceedings were initiated concerning alleged non-compliance with the applicable regulatory framework. 5 Impact on financial, NA operation or other activities: 6 Monetary impact: Settlement amount - Rs. 9,10,780 PSD/SD/SettScheme/3/2025-26 SECURITIES AND EXCHANGE BOARD OF INDIA SETTLEMENT ORDER IN RESPECT OF SETTLEMENT APPLICATIONS FILED UNDER THE NATIONAL SPOT EXCHANGE LIMITED (NSEL) SETTLEMENT SCHEME 2025 1. The Forward Markets Commission (hereinafter referred to as “FMC”) administered the Forward Contracts (Regulation) Act, 1952 (hereinafter referred to as "FCRA"). In exercise of powers conferred under Section 27 of the FCRA, the Department of Consumer Affairs, Ministry of Consumer Affairs, Food and Public Distribution, Government of India, vide notification no. SO 906(E) dated June 05, 2007 (hereinafter referred to as “Exemption Notification”) granted an exemption from the provisions of the FCRA to all forward contracts of one-day duration for sale and purchase of commodities traded on the NSEL. The said exemption was subject to certain conditions, including that “no short sale by the members of the exchange shall be allowed”, “all outstanding positions of the trades at the end of the day shall result in delivery” and all information or returns relating to trading as and when asked for should be provided by NSEL to the Central Government or its designated agency. 2. In September 2009, NSEL introduced the concept of paired contracts which allowed simultaneous buying and selling in the same commodity through two different contracts at two different prices on the exchange platform. The investors could buy a short duration contract and sell a long duration contract, and vice versa, at the same time and at a pre-determined price. The trades for the buy contract (T+2 /T+3) and the sell contract (T+25/T+36) used to take place on NSEL on the same day, at the same time, and at different prices, involving the same counterparties. The transactions were structured in a manner such that the buyer of the short duration contract always ended up making profits. Page 1 of 16 3. On February 06, 2012, FMC was appointed by the Department of Consumer Affairs, Government of India as the ‘designated agency’, in accordance with the conditions prescribed under the Exemption Notification, authorizing it to collect trading data from NSEL and to examine the same for taking appropriate measures, if needed, to protect investors’ interest. Accordingly, FMC called for trading data from different spot exchanges, including NSEL, in the prescribed reporting formats. After analyzing the trading data received from NSEL, FMC passed an Order bearing no. 4/5/2013-MKT-1/B dated December 17, 2013, wherein it was, inter alia, observed that fifty-five (55) contracts offered for trading on the NSEL platform were in violation of the relevant provisions of the FCRA and that the condition prohibiting short sales by members of the exchange was not being complied with by NSEL and its members. FMC further observed that the ‘paired contracts’ offered for trading on the NSEL platform were in violation of the relevant provisions of the FCRA and the conditions specified in the Exemption Notification, while granting exemptions to contracts traded on NSEL from the purview of the FCRA. 4. Subsequently, in 2015, FMC was merged with the Securities and Exchange Board of India (hereinafter referred to as “SEBI”). Consequent upon the merger and the role assigned to it, SEBI examined the role of members who traded on the NSEL platform. Based on the same, enquiry proceedings were initiated against 302 stock brokers (members) for allegedly participating in and/or facilitating its client in entering into paired contracts on NSEL’s platform. 5. Out of 302 enquiry proceedings initiated, the Designated Authority (hereinafter referred to as “DA”) recommended no action in respect of 129 entities and 12 proceedings were disposed of by the Designated Members (hereinafter referred to as “DM”) without any directions. Therefore, total number of brokers against whom orders were passed with directions was 161. Page 2 of 16 Total no. of Total no. of Total no. of Total no. of brokers brokers where brokers where brokers where against whom DAs did not DM passed the DM passed the SEBI initiated recommend orders without orders with enquiry any action any directions directions proceedings in NSEL matter 302 129 12 161 6. In respect of orders passed in the matter, various appeals were filed before the Hon’ble Securities Appellate Tribunal (hereinafter referred to as “SAT”). SAT vide its order dated December 12, 2023, inter alia, directed SEBI to consider and come out with a settlement scheme preferably within three months from date of order. 7. In this regard, SEBI decided to introduce a Settlement Scheme referred to as the ‘NSEL Settlement Scheme, 2025’ (hereinafter referred to as the “Scheme”) in terms of Section 15JB of the Securities and Exchange Board of India Act, 1992 (hereinafter referred to as “SEBI Act, 1992”) read with regulation 26 of the Securities and Exchange Board of India (Settlement Proceedings) Regulations, 2018 (hereinafter referred to as “Settlement Regulations, 2018”). Regulation 26 of the Settlement Regulations, 2018 reads as under: “Settlement Schemes. 26. Notwithstanding anything contained in these regulations, the Board may specify a settlement scheme for any class of persons involved in respect of any similar specified defaults. Explanation. - A settlement order issued under a Settlement scheme shall be deemed to be a settlement order under these regulations.” 8. Accordingly, SEBI framed the Scheme in accordance with the provisions of the Settlement Regulations, 2018 and issued Public Notices dated [Showing first 8,000 characters — download PDF for full document]