CMS Info Systems Limited — THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992

To CMS Info Systems Limited T -151, 5 th Floor, Tower no. 10, Railway Station Complex, Sector – 11 CBD Belapur, Navi Mumbai, Maharashtra – 400614. Sir, Deputy General Manager Corporation Finance Department Policy and Development – 2 rajkd@sebi.gov.in No.: SEBI/HO/CFD/PoD2/OW/P/2024/34828/1 November 8, 2024 Kind attention: Mr. Debashis Dey, Company Secretary and Compliance Officer Sub: Request for Informal guidance by way of an interpretive letter under the provisions of SEBI (Informal Guidance) Scheme, 2003 ("Scheme") received from CMS Info Systems Limited ("Applicant" / "Company") This is with reference to your Informal Guidance application dated August 21, 2024 ("Application") seeking guidance on Regulations 31 and 31A of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("LODR Regulations" or "LODR") read with Regulations 2(oo) and 2(pp) of the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 ("ICDR Regulations" or "ICDR") . The following information is gathered from your Application and the clarification provided vide your email dated September 30, 2024: Prior to listing, 100% shares of the Company were acquired by Sion Investments Pte. Limited ("Sion") on August 27, 2015 from the then existing shareholders of the Company . To ensure compliance with the mandated minimum shareholder requirements under section 3(1)(a) of the Companies Act, 2013, 6 shareholders 1 held 1 share each of the Company (originally acquired and paid for by Sion) purely in the capacity as 'Nominee Shareholders' of Sion . In compliance with the requirements of the Companies Act, 2013, the nominee shareholders had submitted Form MGT 4 and the beneficial owner i.e., Sion 1 6 nominee