In terms of Regulation 24A attached is the Annual Secretarial Compliance Report for financial year ended 31.03.2026.

Date: 23.06.2026 The Bombay Stock Exchange Ltd Department of Corporate Services/ Corporate Relation Phiroze Jeejeebhoy Towers, Dalal Street, Fort, Mumbai – 400 001, Maharashtra, India Dear Sir/Madam, Ref: BSE Scrip Code: 531370 | SPAR | ISIN: INE960B01015 Sub: Submission of Annual Secretarial Compliance Report for the year ended March 31, 2026 as per Regulation 24A of SEBI (LODR) Regulations, 2015 Pursuant to SEBI Circular No.CIR/CFD/CMD1/27/2019 dated February 8, 2019; please find enclosed herewith Annual Secretarial Compliance Certificate issued by M/s. Madhuri J. Bohra & Associates (COP No: 20329), Practicing Company Secretaries, Mumbai, for the financial year ended on March 31, 2026, under Regulation 24A of Securities Exchange Board of India (Listing Obligation and Disclosure Requirement) Regulations, 2015. We request you to kindly take the same on record. Thanking You Yours Faithfully For Sparc Electrex Limited Shobith Ganesh Hegde (Managing Director) DIN: 02211021 Place: Mumbai Encl: a/a MAOHU J. BOHRA & ASSOCIATES Company Secretaries 301-304, Acme lndustrial Park I. B. Patel Road, Goregaon East, Mumbai -400063 M: +918655559088 Email Id: csmadhuribohra(a),gmail.com Secretarial Compliance Report of Spare Electrex Limited For the year ended March 31, 2026 ([Pursuant to Circular CIR/CFD/CMD1/27 /2019 dated February 08, 2019 for the purpose of compliance with Regulation 24A of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015] Spare Electrex Limited 1202, 12th Floor, Esperanza Building, Next to Bank of Baroda, Linking Road, Bandra (West), Mumbai -400050 I have conducted the review of the compliance of the applicable Statutory Provisions and the adherence to good corporate practices by M/s. Spare Electrex Limited bearing CIN: L31100MH1989PLC053467 (hereinafter referred as "the listed entity"). The Secretarial Review was conducted in a manner that provided me a reasonable basis for evaluating the corporate conducts/statutory compliances and to provide my observations thereon. Based on my records maintained by the listed entity and also the information provided by the listed entity, its officers, agents and authorized representatives during the conduct of Secretarial Review, I hereby report that the listed entity has, during the review period covering the financial year ended on 31st March, 2026 complied with the statutory provisions listed hereunder in the manner and subject to the reporting made hereinafter: I, Madhuri Bohra, Proprietor of M/s. Madhuri J. Bohra & Associates, have examined: 1. All the documents and records made available to me and explanation provided by M/s. Spare Electrex Limited. ("the listed entity"), 2. The filings/ submissions made by the listed entity to the stock exchanges, 3. Website of the listed entity, 4. Any other document/ filing, as may be relevant, which has been relied upon to make this certification, for the year ended 31st March, 2026 {"Review Period") in respect of compliance with the provisions of : (a) The Securities and Exchange Board of India Act, 1992 ("SEBI Act") and the Regulations, circulars, guidelines issued thereunder; and (b) The Securities Contracts (Regulation) Act, 1956 ("SCRA"), rules made thereunder and the Regulations, circulars, guidelines issued thereunder by the Securities and Exchange Board of India ("SEBI"); Page 1 of 18 The specific Regulations, whose provisions and the circulars/ guidelines issued thereunder, have been examined, include:- (i) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015; (ii) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018; (iii) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011; (iv) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; Not Applicable for the year under review. (v) Securities and Exchange Board of India (Share Based Employee Benefits & Sweat Equity) Regulations, 2021; Not Applicable for the year under review. (vi) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021; Not Applicable for the year under review. (vii) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 and circulars/ guidelines issued thereunder. (viii) Securities and Exchange Board of India (Depositories and Participant Regulation), 2018 and circulars/ guidelines issued thereunder. (ix) Securities and Exchange Board of India (Delisting of Equity Shares) Regulations, 2021 Not Applicable for the year under review. and based on the above examination, I hereby report that, during the review period: (a) The listed entity has complied with the provisions of the above Regulations and circulars/ guidelines issued thereunder, except in respect of matters specified below: Page 2 of 18 Page days from '18,000/- plus However part necessary Pattern within fine delay. compliance receipt Shareholding make payment 21.01.2026. said Agent (RTA). Upon submit Company latest (excl. GST) resubmissions) Share Transfer required BSE, advising December, 2025 '18,000/ (followed from Registrar entity 31.12.2025. reminder from quarter ended December 2025 requisite data 2015 listed quarter ended followed Pattern (SHP) fine ended to non-receipt (LODR), Reg, Patten (SHP) 13.02.2026 Shareholding Company quarter Pattern (SHP) 31(1) SEBI Shareholding dated submit submission Shareholding Regulation submission taken communicatio required advised days submission of the terms Regulation Delay days action Advisory email Company delay delay matter accordingly. will resolve exchange clarification from year. seeking each financial 2024-25. Company will days of end F.Y. 2026-27. fees F.Y. (ALF) within Listing Fees (ALF) F.Y. 2026-27. annual listing invoice. Listing towards Annual payment arrear current F.Y. 2026- Annual Annual Listing make payment been billed in the make payment Invoice raised along with required this amount required 2024-25) F.Y. 2024-25 needed) invoice; instead, Listed entity '32,500/- (for F.Y. '32,500/- exchange F.Y. 2025-26 2015 Listing Fees Fees amounting from '32,500/- (LODR), Reg, Arrears Annual Annual Listing clarification Listing arrears SEBI payment arrears sought 2024-25 Annual Regulation made taken taken remitted after being include F.Y. terms Regulation Company action action Company Company specific clause) including guidelines Secretary circulars/ Company ( Regulations/ Practicing Requirement Circular Taken Action Violation Amount Remarks of the Response Compliance Regulation/ Deviations Action Type Details Fine Observations/ Management Remarks . y n a n o i t a m r o im o r f , A T R te h t as h E S y l t p m oy rn pa p m o C I . dP eH e tS h t t i m b u s ef no di e f ia v I e h0 t0 n 0 o l l a h say pn m o eC h T d ny an a y t l a n e ep th it m e r t a c i n u d e i 0v 0e 0l , 8 1 ' f o e d i ev m a se d e t la id a sy b , e g n a h c x e . y l t r o h s 6 2 0 2 . 2 d e w o ly bd er te ad dn y n a p m o C e h T 6 2 r 0 o 2 f . 3 t s o m st e eu h r t u s n e d i ta nsf eo eel bcl ni ew g i l i d d e s i c r e x e h c u s eo rn u s n e y n a p m o sn ri u c c y o a l e d t e y t o g n i yt br o ep re ur t u f . y n a p m o e C h t d e t t e h t .d ei na is fe n yi a l e d e h T 6 y5f a o l e ed n e o h i t fs os i m b u s n i i t a if lo i c n o c n e o R i f so s i l a t i p nae oCr ia th aSe ih lt i c n s t a r w o p te iR d u e A r a h S e i e c e r - n o n o et ut di d lu aA t e a t t i a s d i u q e r f or o f t r a r t s i g e eR h m t o r d f e dr ne et r e f s n a e r r T a h dS n a , r e b m n .o )p AU T tR n( e g A d n f a d pn 5 i 2 L R e h t t fp oi e c e rr o f y r a s s e c e n d e dr ne et aa t a d ,e rh, et A T me eR h cm t o r f­ n o n s 2y l t p m o r p y n a p m o C n eo c ln pai m e d h e t t t i m b u s . t r o p e R e h t _ f_ ot r 8 1 4 f oe g a P o he1ooht3oe2 [Showing first 8,000 characters — download PDF for full document]