Intimation of comments of the Board of Directors with reslpect to delay filing of Related Party Transactions

Ref: SUBAM/BSE/24/2026 Date: July 22, 2026 The Manager (Listing), BSE Limited, P. J. Towers, Dalal Street, Mumbai — 400001 Scrip Code — 544267 Ref: Email received from BSE having Ref. SOP-Review-dated- 30-06-2026 Subject: Clarification - Intimation of comments of the Board of Directors with respect to delay in fiing of Related Party Transaction disclosure under Regulation 23(9) of SEBI Listing Regulations With reference to regarding the above subject, we wish to state that the referred penalty_ amounted to Rs. 5,000/-, levied by BSE under Regulation 23(9} of the SEBI Listing Regulations due to a one-day delay in filing the Disclosure of Related Party Transactions for the half-year ended March 31, 2026, with the Stock Exchange(s) in XBRL mcde. The disclosure was required to be filed on May 26, 2026, i.e., the date of declaration of the financial results for FY 2025-26. However, due to technical and system-related issues, the Company could not upload the XBRL file within the prescribed timeline. The file was subsequently uploaded on May 27, 2026, and Board took note of the said delay and advised to strengthen the internal process for timely filing. The Company is committed to ensuring timely compliance: with all- applicable regulatory requirements and to making all filings within the_prescribed timelines going forward. Kindly take the same on record and oblige. Thanking You, For Subam Papers Limited Managing Director T. Balakumar DIN: 00440500 Place: Vaduganpatti/ Tirunelveli SUBAM PAPERS LIMITED - Reg. Off. SFNo 143-146, Vaduganpatti Village, Nadukallur to Tirunelveli, Tirunelveli Taluk. Tirunelveli - 627 010, Tamil Nadu, India. Contact No: 9489926130, E-mail ID: finance@subampapers.com Website: www.subampapers.com U21012TN2004PLC054403, GSTIN:33AAICS5376E1Z b s T Py P . CS qubamgaeers.com From: info@subampapers.com Sent: 14 July 2026 09:14 To: ‘bse.soplodr' Cc: ‘Accounts - Subam’ Subject: RE: 544267-Fines as per SEBI Master Circular No. HO/49/14/14(7)2025-CFD- POD2/1/3762/2026 issued on July 11, 2023 and last updated on January 30,2026 (Chapter VII (A)-Penal Action for Non-Compliance) Attachments: 20260711 SOP Fine Payment.pdf Dear Sir/ Madam With reference to below trail mail send here with Annexure 1 relating remittance particulars of SOP fine for your observation and taken on record. Thanks & Regards Poovalingam Nagarajan Company Secretary/ Compliance officer Subam Papers Limited Tirunelveli - 627010 From: bse.soplodr [mailto: bse.soplodr@bseindia.com] Sent: 30 June 2026 19:14 To: info@subampapers.com; accounts@subampapers.com; info@subampapers.com Cc: bse.soplodr Subject: 544267-Fines as per SEBI Master Circular No. HO/49/14/14(7)2025-CFD-POD2/1/3762/2026 issued on July 11, 2023 and last updated on January 30,2026 (Chapter VII (A)-Penal Action for Non-Compliance) Ref.: SOP-Review-30/06/2026 The Company Secretary/Compliance Officer Company Name: Subam Papers Ltd Scrip Code: 544267 Dear Sir/Madam, Sub: Fines as per SEBI Master Circular No. HO/49/14/14(7)2025-CFD-POD2/1/3762/2026 issued on July 11, 2023 and last updated on January 30,2026 (Chapter VII (A)-Penal Action for Non-Compliance). The company is advised to refer to the SEBI Master Circular No. HO/49/14/14(7)2025-CFD-POD2/I/3762/2026 issued on July 11, 2023 and last updated on January 30,2026 (hereinafter referred to as the ‘SEBI SOP Master Circular’) issued by Securities and Exchange Board of India (SEBI) with respect to penal actions prescribed for non-compliance of certain provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and the Standard Operating Procedure for suspension and revocation of trading of specified securities of listed entities. The Exchange had also issued a guidance note regarding the provisions of the said SEBI circular which is disseminated on the Exchange website at the following link: https:/www.bseindia.com/downloads1/Guidance Note for SEBI SOP Circular.pdf In this regard it is observed that the company is non-compliant/late compliant with the following Regulations for the period mentioned below: Applicable Fine prescribed Fines levied for Fine payable by the company Regulation of SEBI *) (inclusive of GST @ 18 %) as on June 30,2026 (LODR) Regulations, 2015 Basic Fine GST@ 18 Total Fine % payable Regulation 23 (9) Rs. 5,000/- per day | half year ended March 5000 900 5900 Non-compliance with | till the date of 2026 the requirement to | compliance. disclose related party transactions in the format as specified and within the prescribed timeline. Total SOP Fine 5000 900 5900 Note: In case of Non-Compliance the fines will continued to be levied till the date of compliance. The Company is therefore advised to note that as per the provisions of SEBI SOP Master Circular: e The company is required to ensure compliance with above regulation and ensure to pay the aforesaid fines including GST within 15 days from the date of this letter/email, failing which Exchange shall, initiate action related to freezing of the entire shareholding of the promoter in this entity as well as all other securities held in the demat account of the promoter. The company is advised to bring the provisions of SEBI SOP Master Circular to the notice of promoter of the company. e The company is also advised to ensure that the subject matter of non-compliance which has been identified and indicated by the Exchange and any subsequent action taken by the Exchange in this regard shall be placed before the Board of Directors of the company in its next meeting. Comments made by the board shall be duly informed to the Exchange for dissemination. Yours faithfully Harshad Naik Reena Raphel Manager Manager Listing Compliance Listing Compliance In case of any further queries please email the following ids: [Particulars Email Id IQuery on remittance bse.soplodr@bseindia.com |Query on compliance | Harshad.Naik@bseindia.com | Company is requested to remit the fine amount to the following designated VIRTUAL BANK ACCOUNT of the Exchange: Company Name Subam Papers Ltd Account Name Bank Name & Branch Virtual Bank Account No.* IFSC Code BSE Limited ICICI Bank Ltd.- CMS Branch BSER13459 ICIC0000104 *Note: This bank account is specifically dedicated to SOP fine and Waiver fees only, Therefore, company is advised not to deposit/credit any amount payable other than SOP fines/penalties/waiver. The company is required to submit fine remittance details in the following format given at Annexure I to Email id: bse.soplodr@bseindia.com Annexure-I (On letterhead of the company) Sub: Details of Payment of fines for Non-Compliance with Regulations of SEBI (LODR) Regulations, 2015. Remittance details: Scrip Code | Regulation & Quarter | Bank UTR | Date of Amount paid | TDS deducted, if Net Amour number Payment any This mail is classified as ‘C OlFIDENTIAL” by Reena Raphel on June 30, 2026 at 19:13:44.