The Board of Directors (the "Board") of Aditya Ultra Steel Limited ("your Company"/ “the Company”) is pleased to present the 13^th (Thirteenth) Annual Report and the Audited Financial Statements of your Company for the financial year ended 31^st March, 2024 ("financial year under review").

THE STATE OF THE COMPANY'S AFFAIRS:

The Company was incorporated on 27^th July, 2011. Your company is engaged in manufacturing of thermo-mechanically-treated (TMT) bars.

The demand for TMT bars is growing due to the construction industry's expansion and the need for steel in infrastructure development. India's TMT bar market is expected to grow significantly between 2022 and 2030. In FY23, India consumed 50.3 million tonnes of TMT bars, which is up from 46 million tonnes in the previous fiscal year.

During the Financial year, under review, the Company has made remarkable growth as mentioned below in terms of Revenue and Profit.

i. The total income of the Company increased by 10.73 % at Rs. 58859.60 Lakhs (Previous year Rs. 53157.90 Lakhs).

ii. The Total Expenses has been increased by Rs. 5120.62 Lakhs as compared to last year (Previous year Rs. 52666.06 Lakhs)

iii. The Profit before Tax was at Rs. 1072.92 Lakhs against the previous year Profit of Rs. 491.84 Lakhs and the Net Profit after Tax stood at Rs. 768.94 Lakhs for the year 2023-24 compare to previous year Net Profit after tax was Rs. 370.00 Lakhs.

INITIAL PUBLIC OFFER:

Initial Public Offer has been authorized by the Board of Directors vide a resolution passed at its meeting held on May 17,2024 and by the Shareholder of our Company, vide a special resolution passed pursuant to Section 62(l)(c) of the Companies Act, 2013 at the Extra Ordinary General Meeting held on May 18, 2024. The company has filed the Draft Red Herring Prospectus with NSE for in-principle for listing on NSE emerge platform (SME Listing) and the company has received the in-principle approval from NSE dated 27/08/2024. Initial Public Offer is 74,00,000 fully paid equity shares of face value of Rs. 10 each at price decided through book building process. Prospectus are available on the website of the company i.e. www.aditya-ultra-steel.com.

CAPITAL STRUCTURE OF THE COMPANY:

During the year under review, the company has increased its authorized share capital from Rs. 20,00,00,000/- (Rupees Twenty Crores) i.e. 2,00,00,000 (Two Crores) shares of Rs. 10/- (Rupees Ten) each to Rs. 25,00,00,000/- (Rupees Twenty-Five Crores) i.e.

2.50.00. 000 (Two Crores Fifty Lakhs) shares of Rs. 10/- (Rupees Ten) each.

The Board of Directors in the Board Meeting held on 25/11/2023 passed a resolution to issue 1,11,120 shares on private placement basis. However, the Board in their meeting held on 03/01/2024 made a strategic decision by passing a resolution to refund the share application money.

The Board of Directors in the Board Meeting held on 10/01/2024 for the second time passed a resolution to issue 1,11,120 shares on private placement basis. The Board in their meeting held on 13/02/2024 allotted 1,11,120 (One Lakh Eleven Thousand One Hundred Twenty) fully paid up equity shares of Rs 10/- each of on private placement basis. As a result, the paid-up share capital of the company increased from Rs.

12.20.00. 000/- (Rupees Twelve Crores Twenty Lakhs) to Rs. 12,31,11,200/- (Rupees Twelve Crore Thirty-One Lakh Eleven Thousand Two Hundred) i.e. 1,23,11,120 (One

Crore Twenty-Three Lakh Eleven Thousand One Hundred Twenty) Shares of Rs. 10 /-(Ten) each.

Then after, for rationalizing its capital structure the Board of Directors in the Board Meeting held on 14/02/2024 passed a resolution to issue Bonus Shares in the ratio of 2:5 which were allotted in the Board meeting held on 16/02/2024. As a result, the total number shares increased from 1,23,11,120 (One Crore Twenty-Three Lakh Eleven Thousand One Hundred Twenty) to 1,72,35,568 (One Crore Seventy-Two Lakh Thirty-Five Thousand Five Hundred Sixty-Eight) and paid-up share capital increased from Rs. 12,31,11,200/- (Rupees Twelve Crore Thirty-One Lakh Eleven Thousand Two Hundred) to Rs. 17,23,55,680 (Rupees Seventeen Crore Twenty-Three Lakh Fifty-Five Thousand Six Hundred Eighty).

TRANSFER TO RESERVE:

Your Directors proposes to retain an amount of Rs. 768.94 Lakh in the statement of profit & loss account and not transferred to any reserves.

DIVIDEND:

Your Directors in order to conserve the resources do not recommend any dividend for the year 2023-24 under review.

CHANGE IN NATURE OF COMPANY'S BUSINESS:

During the year under review, there is no change in the nature of company’s Business.

DETAILS OF DIRECTORS / KEY MANAGERIAL PERSONNEL APPOINTED / RESIGNED:

i. Retirement by Rotation:

Pursuant to the provisions of Section 152(6) of the Companies Act, 2013, Mr. Varun jain (DIN: 03502561), retires by rotation at the ensuing Annual General Meeting and being eligible, offers himself for re-appointment. Your directors recommend his reappointment.

ii. Appointment/Cessation:

• During the year under review, there was change in the constitution of the Board of Directors of the Company and the following Directors were on the Board of the Company as on 31^st March, 2024:

DETAILS QF HOLDING / SUBSIDIARY COMPANIES / JOINT VENTURES / ASSOCIATE COMPANIES:

The Company doesn’t have any Holding/ Subsidiary/ Joint Ventures/ Associate Companies at the start of the year, during the year or at the end of the year and hence there is no requirement of giving the statement containing the salient feature of the financial statement of the company's subsidiary or subsidiaries, associate company or companies and joint venture or ventures.

DECLARATION BY INDEPENDENT DIRECTORS;

During the Financial year under review, Declarations were received from all the independent Directors of the Company stating that they satisfy the "criteria of Independence” as defined under Regulation 16(b) & 25(8) of SEBI (Listing Obligations and Disclosure Requirements] Regulations, 2015 read with the provisions of Section 149(6) of the Companies Act, 2013, any other applicable Schedules and Rules framed there-under.

Further in the opinion of the Board, the independent directors possess requisite expertise, experience and integrity. All the independent directors on the Board of the Company are registered with the Indian Institute of Corporate Affairs, Manesar, Gurgaon as notified by the Central Government under Section 150(1) of the Companies Act, 2013 and as applicable shall undergo online proficiency self-assessment test within the time prescribed by the IICA.

DISCLOSURE UNDER SECTION 164m OF THE COMPANIES ACT, 2013:

The Company has received the disclosure in Form D1R-8 from its Directors being appointed or re-appointed and has noted that none of the Directors are disqualified under Section 164(2) of the Companies Act, 2013 read with Rule 14(1) of Companies (Appointment and Qualification of Directors) Rules, 2014.

DEPOSIT:

The Company has not invited/accepted any Deposit within the meaning of Chapter V of the Companies Act, 2013 other than exempted deposit as prescribed under the Companies Act, 2013. Hence there are no particulars to report about the deposit falling under Rule 8 (5) (v) and (vi) of Companies (Accounts) Rules, 2014.

DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED BY REGULATORS OR COURTS OR TRIBUNALS:

During the year under review, there were no significant and material orders passed by any Regulators or Court or Tribunals which may have impact on the going concern status or which may have impact on the Company's operation in future.

Pending material litigations against our Company:

An application bearing Company Petition No. CP/19(AHM) of 2022 has been filed under sections 73(4) and 76(2) of the Companies Act, 2013 read along with Companies (Acceptance of Deposits) Rules, 2014 ("Application”) by Mr, Mujlibhai Karamshibhai Patel and Mr. Sandipkumar Karamshibhai Patel (collectively, "Applicants”) against our

Company before the Hon'ble National Company Law Tribunal, Ahmedabad Bench at Ahmedabad ("NCLT”). The matter is relating to a dispute arising out of the deposit amounts ("Deposits") that are payable to the Applicants by our Company. The Applicants in the Application have prayed for payment of Deposits made by the Applicants amounting to ^ 48.13 lakh along with interest on account of its default in repayment of amounts given as Deposits in the form of unsecured loan by the Applicants at an agreed rate of interest. Further, the Applicants alleged that since our Company had not replied to certain letters sent to it by the Applicants seeking repayment, the Applicants had filed a complaint under investor compliant form with the RoC for default in repayment of Deposits. Thereafter, the RoC had issued a notice dated July 31, 2020 ("Notice") to our Company in relation to the aforementioned complaint. The Applicants stated that since no reply was received by them from the RoC, the Applicant has filed the Application before the NCLT. However, our Company had duly sent a reply to the Notice on October 10, 2020 denying all the claims of the Applicants, including the receipt of Deposits from the Applicants, and the existence of any liability with respect to the repayment of any dues to the Applicants in view of a memorandum of understanding ("MoU”) executed on May 1, 2016 by and between the promoters, shareholders, and past directors of our Company, including the Applicants on one part, and our Company, including the present shareholders and directors, on the other part. The MoU lays down certain terms and conditions pertaining to transfer of 100% shareholding of our Company from the past directors to the present directors of our Company. Through the MoU, the Applicants, being the erstwhile directors, had waived-off all past liabilities of our Company with respect to payment of dues except an amount of 111.75 Cr not attributable to the Applicants. The MoU further lays down that the liability with respect to all dues payable before the date of execution of the MoU (inclusive) would be that of the transferors of the shareholding, i.e., the past directors, including the Applicants themselves, who had resigned from the directorship of our Company before the execution of the MoU. The matter is presently pending.

INTERNAL FINANCIAL CONTROLS:

The internal financial controls with reference to the Financial Statements are commensurate with the size and nature of business of the Company. The Company has adopted the policies and procedures for ensuring the orderly and efficient conduct of its business, including adherence to Company’s policies, safeguarding of its assets, prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information.

CONSERVATION OF ENERGY. TECHNOLOGY ABSORPTION. FOREIGN EXCHANGE EARNINGS AND OUTGO:

Pursuant to Rule 8 (3) of Companies (Accounts) Rules, 2014 and section 134 of the Companies Act, 2013, the Company has effectively taken steps for conservation of resources and all effective measures have been taken to save energy.

(B) Technology absorption-

The Company has taken precautionary steps for technology absorption by implementing various measures & efforts which improve the productivity of the machineries, improve quality of a product, reduce the cost of a manufacturing and no specific investment has been made in reduction in technology absorption.

(C) Foreign exchange earnings and Outgo-

During the period under review foreign exchange earnings or out flow reported as follow:

VIGIL MECHANISM

Pursuant to Section 177(93 of the Companies Act, 2013, the company has adopted Whistle Blower Policy to deal with any instance of fraud and mismanagement The employees of the company are free to report violations of any laws, rules, regulations and concerns about unethical conduct to the Audit Committee under this policy. The policy ensures that strict confidentiality is maintained whilst dealing with concerns and also that no discrimination with any person for a genuinely raised concern,

NUMBER OF BOARD MEETINGS:

The calendar of meetings to be held in a year is decided in advance by the Board and circulated to the Directors. The gap between two consecutive meetings was not more than one hundred and twenty days as provided in section 173 of the Act.

During the year, 27 meetings of the Board were held during the financial year 2023-24 on following dates.

23.06.2023, 04.07.2023, 29.07.2023, 31.07.2023, 24.08.2023, 26.08.2023, 12.09.2023,

26.09.2023, 30.09.2023, 07.11.2023, 25.11.2023, 30.11.2023, 11.12.2023, 13.12.2023,

14.12.2023, 20.12.2023, 03.01.2024, 04.01.2024, 10.01.2024, 20.01.2024, 13.02.2024, 14.02.2024,16.02.2024,17.02.2024,19.02.2024, 01.03.2024,14.03.2024.

AUDIT COMMITTEE

During the financial year 2023-24, due to resignation of independent directors and nonexecutive directors, the audit committee was reconstituted by the board.

The Committee comprises of 3 Non-Executive Director and the Chairman being an independent Director. The Composition of the Committee as on 31^st March 2024 and attendance of the members is given hereunder:

During the Financial year 2023-24, 6 meetings of the Audit Committee were held on following dates:

30.06.2023, 24.08.2023, 26.08.2023, 26.09.2023, 03.01.2024,19.02.2024.

Requisite quorum was present during the meetings.

The primary objective of the Audit Committee is to monitor and provide effective supervision of the management's financial reporting process to ensure accurate and timely disclosures, integrity and quality of financial reporting. The Committee oversees related party transactions, the work carried out in the financial reporting process by the

management, the Statutory Auditors, Internal Auditor, the Cost Auditor, the Secretarial Auditor and notes the processes and safeguards employed by each of them.

The Company Secretary of the Company acts as Secretary of the Committee.

NOMINATION & REMUNERATION COMMITTEE^

During the financial year 2023-24, due to resignation of independent directors and nonexecutive directors, the Nomination and Remuneration committee was reconstituted by the board.

The Committee comprises of 2 Non-Executive Director and 1 Executive Director the Chairman being an Independent Director. The Composition of the Committee as on 31^st March, 2024 and attendance of the members is given hereunder:

During the Financial year 2023-24, 5 meetings of the Nomination and Remuneration Committee were held on following dates:

29.07.2023, 25.11.2023, 30.11.2023, 20.12.2023, 03.01.2024, 17.02.2024 and

19.02.2024.

Requisite quorum was present during all the meetings.

The primary objective of the Nomination and Remuneration Committee ("NRC”) is to identify persons who are qualified to become directors and who may be appointed in senior management in accordance with the criteria laid down including remuneration payable to the senior management, recommend to the Board their appointment and carry out evaluation of every director’s performance.

STAKEHOLDER RELATIONSHIP COMMITTEE:

During the financial year 2023-24, due to resignation of independent directors and nonexecutive directors, the stakeholder’s relationship committee was reconstituted by the board.

The Committee comprises of 2 Non-Executive Director and 1 Executive Director, the Chairman being An Independent Director. The Composition of the Committee and attendance of the members is given hereunder:

During the Financial year 2023-24, 2 (Two] meeting of the Stakeholder Relationship Committee was held on 03.01.2024 and 19.02.2024, Requisite quorum was present during the meetings.

The Committee looks into the grievances ofthe Shareholders related to transfer of shares, and non-receipt of annual report and recommends measure for expeditious and effective investor service. However, there were no Complaints received to the Company during the Financial year 2023-24.

The Company Secretary of the Company acts as Secretary of the Committee.

The Company has duly appointed Registrar and Share Transfer Agent (R&T Agent) for servicing the shareholders holding shares in physical or dematerialized form. All requests for dematerialization of shares are likewise processed and confirmations thereof are communicated to the investors within the prescribed time. There were no complaints received during the year ended 31^st March 2024.

CORPORATE SOCIAL RESPONSIBILITY COMMITTEE:

The Committee comprises of 2 Executive Director and 1 Executive Director, the Chairman being an Independent Director. The Composition of the Committee and attendance of the members is given hereunder:

* The composition of CSR Committee was reconstituted on 20.12.2023 as mentioned in the table given below. However, no meeting is held during the year under review after such reconstitution.

During the Financial year 2023-24, 1 (One) meeting of the Stakeholder Relationship Committee was held on 24.08,2023. Requisite quorum was present during the meetings.

The primary objective of the committee is to develop and implement the company's CSR strategy, ensuring that it aligns with the company’s values, goals, and business objectives. The committee sets priorities for CSR initiatives and decide on the areas of focus, such as environmental sustainability, social equity, or community development. It is also responsible for creating and updating CSR policies and guidelines. This includes defining the principles and standards the company will follow to ensure ethical behavior and positive social impact

Further, the committee monitors the execution of CSR programs and projects to ensure they meet the defined objectives. They assess the effectiveness of these initiatives and provide recommendations for improvement.

CORPORATE SOCIAL RESPONSIBILITY:

The Board in compliance with the provisions of Section 135(1] of the Companies Act, 2013, and rules made thereunder has constituted CSR Committee consisting of Mr. Varun Jain, Mr. Sunil Singhi and Ms. Sapna Jain. A brief outline of the CSR Policy and the CSR initiatives undertaken by the Company during the year is given in Annual Report on Corporate Social Responsibility (CSR) activities in the Annexure II, which forms part of this report.

POMCIES

In accordance with the requirements of the Companies Act, 2013 and SEBI (LODR) Regulations, 2015, the Board of Directors of the Company has framed the following policies:

1. Policy on materiality of dealing with Related Party Transactions.

2. Policy for Preservation of Documents

3. Whistle Blower Policy

4. Policy for procedure of inquiry in case of leak of Unpublished Price Sensitive Information (UPS1)

5. Archival Policy

6. Criteria for making payments to Non- Executive Directors

7. Dividend Distribution Policy

8. Familiarization programme for independent directors.

9. Code of conduct to regulate, monitor and report trading by insiders.

10. Policy for determining Material Subsidiary

11. Policy on disclosure of material events or information

12. Materiality policy

13. Board Diversity Policy

14. Policy on identification of Group Companies, Material Creditors and Material Litigations.

15. Policy on prevention of sexual harassment

16. Terms and conditions for appointment of Independent Directors.

17. Nomination &Remuneration Policy

18. Code of Conduct for board members and senior management.

All the above policies have been displayed on the website of the Company viz. https://www.adityaultrasteel.com/

AUDITORS

i. Statutory Auditor and their Report

M/s. S N Shah & Associates, Chartered Accountants, (Firm Registration No. 0109782W) were re-appointed as statutory auditor of the Company at the Extra-Ordinary General Meeting held on 31^st May, 2023, to hold the office till the conclusion of Annual General Meeting to be held in the year 2025.

Auditors Report

The Notes on financial statements referred to in the Auditors' Report are self-explanatory and do not call for any further comments.. The report does not contain any qualification, reservation or adverse remark.

ii. INTERNAL AUDITOR

The Board of Directors had appointed M/s. N R Kalal & Associates, Chartered Accountants (FRN: 149215W), as Internal Auditors of the Company for the Financial Year 2023-24.

iii. SECRETARIAL AUDITOR AND SECRETARIAL AUDIT REPORT

The Board of Directors of the Company has in compliance with the provisions of Section 204(1) of the Companies Act, 2013 and rules made therein appointed M/s K Jatin & Co., Company Secretaries as Secretarial Auditor, to carry out Secretarial Audit of the Company for the financial year 2023-24.

The Report of the Secretarial Auditor is annexed to this Report as "Annexure III” which is self-explanatory and gives complete information. The Secretarial Audit Report does not contain any qualification, reservation or adverse remark.

iv. COST RECORDS AND COST AUDITORS:

Pursuant to the provisions of Section 148 of the Companies Act, 2013 read, with relevant rules made thereunder, maintenance of cost records is required and accordingly such accounts and records are made and maintained by the Company. The cost audit for the financial year 2023-24 was carried out in time, and the Cost Audit Report with requisite data, in the prescribed form CRA-4, has already been filed with Ministry of Corporate Affairs (MCA) within the permissible time, last year.

Further, in accordance with the said applicable provisions, the audit of the cost records of the Company for the financial year 2023-24 as required is being carried out by Cost Auditors M/s. Anuj Aggarwal & Co., Cost Accountants, (FRN: 102409) Cost Auditors.

The Cost Audit Report will be filed on or before the due date with the MCA in due course of time after the same is approved by the Board of Directors of the Company within the permissible timeline.

DIRECTORS RESPONSIBITLY STATEMENT:

As required under the provisions of Section 134 of the Act, to the best of their knowledge and belief the Board of Directors report that:

a. In the preparation of the annual accounts, the applicable accounting standards have been followed along with proper explanation relating to material departures.

b. The Directors have selected such accounting policies and applied them consistently and made judgments and estimates that are reasonable and prudent so as to give a true and fair view of the state of affairs of the Company at the end of the financial year and of the profits of the Company for that period.

c. The Directors have taken proper and sufficient care for the maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities.

d. The Directors have prepared the annual accounts on a going concern basis.

e. The Directors have laid down Internal Financial Controls as required by Explanation to Section 134(5)(e) of the Act) to be followed by the Company and such internal financial controls are adequate and are operating effectively.

f. The Directors have devised proper systems to ensure compliance with the provisions of applicable laws and such systems are adequate and operating effectively.

PARTICULARS OF EMPLOYEES!

None of the employee has received remuneration exceeding the limit as stated in Rule 5(2) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014.

COMPLIANCE WITH THE SECRETARIAL STANDARDS:

The Company has complied with all the provisions of Secretarial Standards on Board Meetings and General Meetings issued by the Institute of Company Secretaries of India.

ENVIRONMENT AND SAFETY!

The company understands the value of operating in an ecologically friendly and safe manner. The Company’s philosophy mandates that activities be carried out in such a way that all parties involved are safe, environmental standards are followed, and natural resources are preserved.

RELATED PARTY TRANSACTIONS:

All the transact! ons/contracts/arrangements of the nature as specified in Section 188(1) of the Companies Act, 2013 entered by the Company during the year under review with related party (ies) are in ordinary course of business and on arm’s length. AOC-2 is forming part of this report as Annexure I.

The Details ofthe Transactions with related parties as per accounting standards are given in the Note No. 29 of the Financial Statement to the note forming part of the accounts.

PARTICULARS OF LOANS / GUARANTEES / INVESTMENT:

The Particulars of loans, guarantee or investment made under Section 186 of the Companies Act, 2013 are forming part to the Financial Statements for the year ended 31^st March 2024.

EXTRACT OF THE ANNUAL RETURN

Pursuant to section 92(3) of the Companies Act, 2013 (‘the Act') and rule 12(1) of the Companies (Management and Administration) Rules, 2014, extract of annual return is placed on the website of the company www.aditya-ultra-steel.com.

RISK MANAGEMENT POLICY

The Company has a structured risk management policy. The Risk management process is designed to safeguard the organization from various risks through adequate and timely actions. It is designed to anticipate, evaluate and mitigate risks in order to minimize its impact on the business. The potential risks are inventoried and integrated with the management process such that they receive the necessary consideration during decision making.

ANNUAL PERFORMANCE EVALUATION:

In compliance with the provisions of the Act and voluntarily under SEBI (LODR) Regulations, 2015, the performance evaluation was carried out as under:

Board:

In accordance with the criteria suggested by the Nomination and Remuneration Committee, the Board of Directors evaluated the performance of the Board, having regard to various criteria such as Board composition, Board processes, Board dynamics etc. The Independent Directors at their separate meetings, also evaluated the performance of the Board as a whole based on various criteria. The Board and the Independent Directors were of the unanimous view that performance of the Board of Directors on a whole was satisfactory.

Committees of the Board:

The performance ofthe Audit Committee, the Nomination and Remuneration Committee was evaluated by the Board having regard to various criteria such as committee composition, committee, processes, committee dynamics etc. The Board was of the unanimous view that all the committees were performing their functions satisfactorily and according to the mandate prescribed by the Board under the regulatory

requirements including the provisions of the Act, the Rules framed thereunder and the Listing Agreement.

Individual Directors:

(a) Independent Directors: In accordance with the criteria suggested by the Nomination and Remuneration Committee, the performance of each independent director was evaluated by the entire Board of Directors [excluding the director being evaluated) on various parameters like engagement, leadership, analysis, decision making, communication, governance and interest of stakeholders. The Board was of the unanimous view that each independent director was a reputed professional and brought his/her rich experience to the deliberations ofthe Board. The Board also appreciated the contribution made by all the independent directors in guiding the management in achieving higher growth and concluded that continuance of each independent director on the Board will be in the interest of the Company.

(b) Non-Independent Directors: The performance of each of the non-independent directors was evaluated by the Independent Directors at their separate meeting. Further, their performance was also evaluated by the Board of Directors. The various criteria considered for the purpose of evaluation included leadership, engagement, transparency, analysis, decision making, functional knowledge, governance and interest of stakeholders. The Independent Directors and the Board were of the unanimous view that each of the non-independent directors was providing good business and people leadership.

MATERIAL CHANGES AND COMMITMENTS. IF ANY. AFFECTING THE FINANCIAL POSITION OF THE COMPANY WHICH HAVE OCCURRED BETWEEN THE END OF THE FINANCIAL YEAR OF THE COMPANY TO WHICH THE FINANCIAL STATEMENTS RELATE AND THE DATE OF THE REPORT:

There are no material changes and commitments, which may have affect the financial position of the Company between the end of the financial year of the company to which the financial statements relate and the date ofthe report.

SEXUAL HARASSMENIl

The Company has constituted an Internal Complaint Committee as required under Section 4 ofthe Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressed) Act, 2013 and the Rules made thereunder. During the year under review, no complaints were reported.

TRANSFER TO THE INVESTOR EDUCATION AND PROTECTION FUND:

During the year under review, the provisions of Section 125(2) of the Companies Act, 2013 do not apply as there was no dividend declared and paid in last seven years so the Company was not required to transfer any amount to the Investor Education and Protection Fund (IEPF) established by the Central Government pursuant to the provision

of Section 125 (e) of the Companies Act, 2013 as there is no amounts unclaimed for a period of 7 years from the date it became due for repayment.

REPORTING OF FRAUD:

During the year under review there was no instance of any fraud which has been reported by any Auditor to the Audit Committee or the Board.

DETAILS OF APPLICATION MADE OR ANY PROCEEDING. PENDING UNDER THE INSOLVENCY AND BANKRUPTCY CODE. 2016:

During the year under review, there were no applications made or proceedings pending in the name of Company under the Insolvency and Bankruptcy Code, 2016.

DETAILS OF DIFFERENCE BETWEEN VALUATION AMOUNT ON ONE TIME SETTLEMENT AND VALUATION WHILE TAKING LOAN FROM THE BANKS OR FINANCIAL INSTITUTIONS

During the year under review, there has been no one time settlement of loans taken from the Banks or Financial Institutions.

APPRECIATION:

Your Directors would like to express their sincere appreciation for the co-operation and assistance received from the employees, Banks, Financial Institutions, Customers, Business Associates, Government Departments, suppliers, and other stakeholders who have extended their valuable sustained support and encouragement during the year under review.

Your Directors take this opportunity to recognize and place on record their gratitude and appreciation for the commitment displayed by all executive officers and staff at all levels of the company. We look forward for the continued support of all stakeholders in the future and we are very thankful for the confidence shown in the Company.