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Austere Systems Limited (Formerly known as Austere Systems Private Limited) Date: 2nd October, 2026 BSE Limited, SME Platform Department of Corporate Affairs 20th Floor, P. J. Towers, Dalal Street, Mumbai – 400 001 Scrip Code: 544505 Sub.: Disclosure under Regulation 30 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 – Order dated September 23, 2025 passed by the Hon’ble National Company Law Appellate Tribunal Dear Sir/ Madam, Pursuant to Regulation 30 read with Para A(20) of Part A of Schedule III of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI Listing Regulations”), and pursuant to the Warning-cum-Advisory Letter dated October 1, 2026 issued by the Securities and Exchange Board of India (“SEBI”), the Company hereby makes the following disclosure in respect of the order dated September 23, 2025 passed by the Hon’ble National Company Law Appellate Tribunal (“NCLAT”), New Delhi, in Competition Appeal (AT) No. 36 of 2022. Kindly take the same on record. Thanking you, Yours faithfully, For Austere Systems Limited (Formerly known as ‘Austere Systems Private Limited’) Sneha Goenka Company Secretary & Compliance Officer M. No. A48476 Registered Office Address: Unit No 301-303, 3rd Floor, Plot No 34, A Square, Sector- 26, Pradhikaran, Nigdi, Pune, Maharashtra-411044 Corporate Office Address: Unit No:112-114,1st Floor, Vipul Plaza, Golf Course Road, Suncity Sector-54, Gurugram, Haryana-122002 Panchkula Office Address: Third Floor, SCO 3, Swastik Vihar, Sector-5, MDC, Panchkula-134109, Haryana GST NO. 27AANCA5362K2Z8, CIN: L74900PN2015PLC155381 Email Id: Hr@austere.co.in, Accounts@austere.co.in Contact no: Pune- 020-27656299, Gurgaon- 0124-4152526 www.austeresystems.com Austere Systems Limited (Formerly known as Austere Systems Private Limited) Annexure Sr. No. Description Details i) Name of the authority Hon’ble National Company Law Appellate Tribunal (NCLAT), New Delhi ii) Nature and details of the action(s) The proceedings originated from an order taken, initiated or order(s) passed dated April 4, 2022 passed by the Competition Commission of India (“CCI”), pursuant to which a penalty of ₹44,25,569/- (Rupees Forty-Four Lakh Twenty-Five Thousand Five Hundred Sixty-Nine only) was imposed upon the Company in relation to proceedings concerning historical soil- testing tenders. The Company had preferred an appeal before the Hon’ble NCLAT against the aforesaid order of the CCI. The Hon’ble NCLAT, vide its order dated September 23, 2025, dismissed the appeal preferred by the Company and upheld the order passed by the CCI. The NCLAT order did not enhance the quantum of the penalty nor did it impose any additional monetary penalty or any separate financial liability upon the Company over and above the penalty imposed by the CCI. Thereafter, being aggrieved by the NCLAT order, the Company preferred an appeal before the Hon’ble Supreme Court of India on December 12, 2025 and also filed an application seeking stay of the impugned order. Civil Appeal Diary No.: 62482/2025 Date of Filing: December 12, 2025 iii) Date of receipt of direction or order, September 23, 2025 including any ad-interim or interim orders, or any other communication from the authority iv) Details of the violation(s) / The proceedings relate to allegations contravention(s) committed or alleged considered by the CCI in connection with to be committed historical soil-testing tenders undertaken prior to the listing of the Company. The CCI had imposed the aforesaid penalty upon the Company vide its order dated April 4, 2022. The Company had challenged the said order before the Hon’ble NCLAT. The Hon’ble NCLAT, vide order dated September 23, 2025, dismissed the Company's appeal and upheld the CCI order. v) Impact on financial, operation or other The financial implication arising from the activities of the listed entity, aforesaid proceedings is limited to the quantifiable in monetary terms to the penalty of ₹44,25,569/-, which had already extent possible been imposed by the CCI and had been disclosed in the Company's Red Herring Prospectus (“RHP”) issued prior to listing. Registered Office Address: Unit No 301-303, 3rd Floor, Plot No 34, A Square, Sector- 26, Pradhikaran, Nigdi, Pune, Maharashtra-411044 Corporate Office Address: Unit No:112-114,1st Floor, Vipul Plaza, Golf Course Road, Suncity Sector-54, Gurugram, Haryana-122002 Panchkula Office Address: Third Floor, SCO 3, Swastik Vihar, Sector-5, MDC, Panchkula-134109, Haryana GST NO. 27AANCA5362K2Z8, CIN: L74900PN2015PLC155381 Email Id: Hr@austere.co.in, Accounts@austere.co.in Contact no: Pune- 020-27656299, Gurgaon- 0124-4152526 www.austeresystems.com Austere Systems Limited (Formerly known as Austere Systems Private Limited) The NCLAT order did not increase or modify the quantum of the said penalty and did not impose any additional monetary liability upon the Company. Further, the order did not result in any suspension, debarment, disqualification, closure of operations, restriction on the Company's business activities or disruption of its ongoing operations. Accordingly, apart from the aforesaid penalty of ₹44,25,569/-, the NCLAT order has not resulted in any additional material adverse financial or operational impact on the Company. Registered Office Address: Unit No 301-303, 3rd Floor, Plot No 34, A Square, Sector- 26, Pradhikaran, Nigdi, Pune, Maharashtra-411044 Corporate Office Address: Unit No:112-114,1st Floor, Vipul Plaza, Golf Course Road, Suncity Sector-54, Gurugram, Haryana-122002 Panchkula Office Address: Third Floor, SCO 3, Swastik Vihar, Sector-5, MDC, Panchkula-134109, Haryana GST NO. 27AANCA5362K2Z8, CIN: L74900PN2015PLC155381 Email Id: Hr@austere.co.in, Accounts@austere.co.in Contact no: Pune- 020-27656299, Gurgaon- 0124-4152526 www.austeresystems.com Austere Systems Limited (Formerly known as Austere Systems Private Limited) Explanation for Delay in Disclosure: The Company respectfully submits the following explanation for the delay in making the present disclosure: 1. The underlying proceedings initiated by the CCI, the CCI order dated April 4, 2022, the penalty of ₹44,25,569/- and the appeal preferred by the Company before the Hon’ble NCLAT had already been comprehensively disclosed in the RHP issued by the Company prior to its listing. 2. The equity shares of the Company were listed on BSE Limited on September 12, 2025, and the NCLAT order was passed shortly thereafter on September 23, 2025. 3. The Company further considered that the NCLAT order represented an appellate outcome in respect of proceedings already disclosed and did not: o enhance the quantum of the penalty; o impose any fresh monetary penalty or additional financial liability; o introduce any new litigation or claim; o result in any suspension, debarment, disqualification or restriction on the Company's operations; or o cause any disruption to the Company's ongoing business activities. 4. Accordingly, based on the Company's understanding at the relevant time, the NCLAT order was considered to be a subsequent development in continuation of the proceedings already disclosed in the RHP, and a separate disclosure of the order was not made to the Stock Exchange at that time. 5. The Company further submits that the omission was inadvertent and arose from its understanding regarding the disclosure treatment of a subsequent appellate order in proceedings which had already been disclosed prior to listing. There was no intention to suppress, conceal or withhold the underlying proceedings, the penalty or the financial exposure from the Stock Exchange or investors. 6. Upon subsequent review of the applicable disclosure requirements and the matter in its entirety, the Company has taken steps to provide complete and updated disclosure to the Stock Exchange after advisory from SEBI. 7. The Company has also strengthened its internal compliance and escalation mechanism for monitoring judicial, regulatory and sta [Showing first 8,000 characters — download PDF for full document]