Dir is in a VBA library that communicates with Windows, most likely using low-level Windows API calls. I do not know the internals of how this works but it is not executing a shell command. (In VBA you would see a call to the built-in Shell function to execute a shell command.)
However, it's not at all clear what you say is forbidden. Are you even allowed to use VBA? Some people refer to VBA as "script."
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