Comments of Board of Directors on fine imposed by BSE is hereby submitted.

HOC/BSE/429BM/2nd Qtr/2026 04th November, 2026 BSE Limited., Phiroze Jeejeebhoy Towers, Dalal Street Mumbai – 400 001 Sir/ Madam, Sub: Comments of Board of directors on Fine imposed by BSE for Q1 of FY 2026-27 with regard to non-compliance of requirement pertaining to SEBI LODRR This has reference to the e-mails dated 25.08.2026 received from BSE Limited ("BSE"), informing the Company that penalties of Rs.5,05,000/- plus applicable GST have been imposed for non-compliance with Regulation 17(1) (Composition of the Board of Directors) and non-compliance of regulation 20(2)/(2A) of SEBI LODRR, Non-compliance with the constitution of stakeholder relationship committee ("SEBI LODR Regulations") during the quarter ended June 30, 2026. BSE has further informed that these matters shall be placed before the Board of Directors of the Company and the comments made by the Board shall be duly disseminated on the Exchange portal. Accordingly, in the 429th Board meeting held on 04.11.2026, this matter was reported to Board of Directors. The Board noted that the appointment of Directors to the Board of HOCL falls within the purview of the Ministry of Chemicals and Fertilizers, Department of Chemicals and Petrochemicals, Government of India. Accordingly, the non-compliance with Regulation 17(1), 20(2)/(2A) of the SEBI (LODR) Regulations, 2015, was attributable to circumstances beyond the direct control of the Company. With regard to the non-compliance with Regulations 20(2) and 20(2A), the Board noted that the same arose due to the non-availability of requisite Independent Directors on the Board, and the circumstances was beyond the reasonable control of the Company. Submitted for kind information and records. Thanking you. Yours faithfully, For Hindustan Organic Chemicals Limited Subramonian H Company Secretary & Compliance Officer