The Members

Your Directors have pleasure in presenting the Twelfth Annual Report of yourCompany with the Audited Financial Statements along with Auditor1 s Report for the yearended March 31 2021.

1. FINANCIAL PERFORMANCE:

The Company's Financial Performance during its Twelfth Years of Operations issummarized below:

2. STATIC OF TMi: COMPANY'S AFFAIRS AND FUTURE OUTLOOK.

During the year under ended March 31 2021 Your company has achieved revenue of Rs.24569110/ - as compared to previous year of Rs. 21057580/ . The Company had incurreda Net loss of Rs. (270190/-).

3. DIVIDEND

The Board ot Directors of the Company has decided not to recommend any dividend for thefinancial year under consideration.

4. TRANSFER TO GENERAL RESERVES

The Company has not transferred any sum to the General Reserves Account during thereporting penod.

5. CHANGES IN THE NATURE OF BUSINESS

There has been no change in the nature of business during the year under review by theCompany.

6. MATERIAL CHANGES AND COMMITMENTS

There is no material change which may affect the financial position of the Companybetween the financial year and up to the date of tins report.

7. DETA1I-S IN RESPECT OF ADEQUACY OF INT ERNAL FINANCIAL CONTROLS

Based on the framework of internal financial controls and compliance systemsestablished and maintained by the Company work performed by the internal statutory' andsecretarial auditors and die reviews performed by management and the relevant Boardcommittees including the audit committee the board is of the opinion that the Company'sinternal financial controls were adequate and effective during the financial year2020-2021. The details in respect of internal financial control and their adequacy areincluded in the Management Discussion & Analysis which forms part of dais report.

8. PUBLIC DEPOSITS

During the year under review the company has not accepted any deposit under Section 73of the Companies Act 2013 read with Companies (Acceptance of Deposits) Rules 2014.

A) STATUTORY AUDITOR

M/s V. N. Purohit & Co. Chartered Accountants were appointed as the StatutoryAuditors of the Company to hold office for a period ot 5 years i.e. until the conclusionof the Annual General Meeting of the Company to be held in the year 2022.

Auditor's Report

The Auditor's Report for Financial Year Ended 31 2021 does not contain anyqualification reservation or adverse remarks. All Observations made in the IndependentAuditors' Report and Notes forming part of the Financial Statements are self-explanatoryand do not call for any farther comments and also there is no incident of fraud requiringreporting by the auditors under section 143(12) of the Companies Act 2013 dunng the year.The Auditor's report is enclosed with the financial statements.

11) SECRETARIAL AUDITOR

Pursuant to the provisions ot Section 204 of the Companies Act 2013 and the Companies(Appointment and Remuneration of Managenal Personnel) Rules 2014 the Company hasappointed M/s VMS & Co. Company Secretaries CS Megha Sharan (CP No.: 12171 FCS:9802) to undertake the secretarial audit of the Company for the Financial Year 2020-2021.

Secretarial Audit Report

[lie Secretarial Audit Report for the Financial Year Ended March 31 2021 does notcontain any qualification reservation or adverse remark. A copy of the Secretarial AuditReport (Form MR-3) as provided by the Company Secretary in Practice has been annexed tothe Report. (Annexure-T)

C) INTERNAL AUDITOR

Pursuant to provisions of Section 138 read with rules made there under the Board hasappointed M/s Anil Hanram Gupta & Co. Chartered Accountants as an Internal Auditorof the Company to check the internal controls and functioning of die activities of theCompany and also recommends way of improvement They have provided Internal Audit Reportof the Company tor the financial year ended March 31 2021. The Internal audit is carriedout quarterly basis and the report is placed in the Audit Committee Meeting and BoardMeeting tor their consideration and direction.

D) COST AUDITOR

The Company has not appointed the Cost Auditor as pursuant to Section 148 of theCompanies Act 2013 read with the Companies (Cost Records and Audit) Amendment Rules2014 the cost audit is not applicable to die Company.

10. SHARE CAPITAL

Dunne; the year under review the Authorized Share Capital of the Company is Rs.32000000 and the paid up equity share capital is Rs. 30121750/-.

A. Issue of equity shares with differential ri plats

The Company has not issued any equity shares with differential rights so no disclosureis required as per Rule 4 (4) of the Companies (Share Capital and Debentures) Rules 2014.

B. Issue of sweat equity shares

The Company has not issued sweat equity shares so no disclosure is required as perRule 8(13) of the Companies (Share Capital and Debentures) Rules 2014.

C. Issue of employee stock options

The Company has not issued employee stock options so no disclosure is required as perRule 12(9) of the Companies (Share Capital and Debentures) Rules 2014.

1). Provision of money by company for purchase of its own share by employees or bytrustee for the benefit of employees

The Company has not made any provision for purchase of its own share of employees or bythe trustee for the benefit of employees so no disclosure is required as per Rule 16(4) ofthe Companies (Share Capital and Debentures) Rules 2014.

E. Issue of shares on preferential basis

The Company has not issued any share on preferential basis during the year.

F. Issue of Bonus Shares

Dunng the year pursuant to Section 63 of the Companies Act 2013 read with theCompanies (Share Capital and Debentures) Rules 2014 the Company has not issued bonusshares.

11. LISTING FEES

Listing tees tor financial year 2020 21 have been paid to BSE SME on which the sharesof the Company are listed.

12. CONSERVATION OF ENERGY. TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS ANDOUTGO

The details of conservation of energy technology absorption foreign exchange andoutgo are as follows:

A. Conservation of energy

The company is not engaged in any manufacturing or processing activity as suchparticulars required to be given in terms of Section 134(3)(m) of the Companies Act 2013read with the Companies (Accounts) Rules 2014 regarding conservation of energy are notapplicable.

B. Technology absorption

The company is not engaged in any manufacturing or processing activity as suchparticulars required to be given in terms of Section 134(3)(m) of the Companies Act 2013read with the Companies (Accounts) Rules 2014 regarding technology' absorption are notapplicable.

C. Foreign exchange earnings and outgo

There has been no expenditure and/or earning in foreign exchange.

13. DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED

During the financial year 2020 21 no significant and material orders passed by theregulators or courts or tribunals impacting the going concern status and company^soperations in the future.

14. CORPORATE SOCIAL RESPONSIBILITY

Pursuant to provisions of Section 135 of the Companies Act 2013 every company havinga Net Worth of Rupees Five Hundred Crore (Rs.500 Crore) or more; or Turnover of Rupees OneThousand Crore (Rs.1000 Crore) or more; or Net Profit is Rupees Five Crore (Rs.5 Crore) ormore dunng the immediately preceding financial year is required to constitute a CorporateSocial Responsibility Committee ("GSR Committee") of the Board. But thisprovision is not applicable to your company; as dunng the immediately preceding financialyear company has not reached this limit.

15. BUSINESS RESPONSIBILITY RliPORT

As per Regulation 34(2)(f) of the SEBI (LODR) Regulations 2015 top one thousand(1000) listed entities based on market capitalization shall contain the BusinessResponsibility Report in their Annual Report. As the Company does not fall under top 500listed Companies based on market capitalization therefore this regulation is notapplicable to the Company.

m EXIE ACT .PE. .THE. ANNEAL. RETURN

The extract ot annual return in Form MGT 9 as requited under Section 92(3) ol theCompanies Act 2013 and Rule 12 of the Companies (Management and Administration) Rules2014 is available on the website of the Company at u wn.akmhue.iom.

In accordance with Section 134(3)(a) of the Companies Act 2013 an extract of theAnnual Return in Form No. MGT — 9 as ‘Annexure-IT' has been enclosed withthe Board's Report.

17. MANAGEMENT DISCUSSION AM) ANALYSIS REPORT

In terms of the Regulation 34(2)(e) of SEBI( Listing Obligations and DisclosureRequirements) Regulations 2015 the Management's Discussion and Analysis Report (MDAR) isset out in the Annual Report.

18. DIRECTORS AND KEY MANAGERIAL PERSONNEL

The Board of the Company was duly constituted in accordance with the provisions of theCompanies Act 2013. As of the date of the report your company has the followingDirectors on its Board:

A. Directors

During the financial year 2020-2021 there was no appointment or resignation ofdirector of the company.

Director's retiring by Rotation

Mrs. Purva Mangal (DIN: 02816099) will be retinng by rotation at the ensuing AnnualGeneral Meeting and being eligble offer himself for re-appointment.

The Board of Directors on the recommendation of the Nomination and RemunerationCommittee recommends the reappointment ot aforesaid Director to the Members of the Companyat the ensuing Annual General Meeting.

B. Chief f financial Officer

During file Financial Year 2020-21 under review there is no change in appointmentresignation of Chief Financial Officer of the Company.

C. Company Secretary & Compliance Officer

During the year under review Mr. Roshan Jha was appointed as Company Secretary andCompliance Officer of the company w'.e.f. June 01 2020.

Further Mr. Roshan Jha had resigned from the post of Company Secretary and ComplianceOfficer of the company w.e.f July 31 2021 and Company had appointed Ms. Firdaus asCompany Secretary and Compliance Officer of the Company w.e.f. August 02 2021.

I). Independent Director

In teons of Section 149 of the Companies Act 2013 and iules made there under theCompany has Two Non-Promoter NonExecutive Independent Directors in line with the act. TheCompany has received necessary declaration from each Independent Director under Section149 (7) of the Companies Act 2013 that they meet the criteria of independence laid downin Section 149 (6) of the Act. Further all the Independent Directors of the Company haveregistered themselves in the Independent Director Data Bank.

A separate meeting ot Independent Directors was held on February 18 2021 to review thepertomiance ot Non Independent Directors and Board as whole and performance of Chairman ofthe Company including assessment of quality quantity and timeliness of flow ofinformation between Company management and Board.

E. Performance p.valuation

Pursuant to the provisions of the Companies Act 2013 and Regulation 17(10) of SEB1(Listing Obligations and Disclosure Requirements) Regulations 2015 a separate exercisewas carried out to evaluate the performance of individual Directors including theChairman of the Board who were evaluated on parameters such as level of engagement andcontribution and independence of judgment thereby safeguarding the interest of theCompany.

The performance evaluation of the Independent Directors was carried out by the entireBoard. The performance evaluation of the Chairman and the Non Independent Directors wasearned out by the Independent Directors. The board also carried out an annual performanceevaluation ot the working of its Audit Nomination and Remuneration as well as stakeholderrelationship committee. The Directors expressed their satisfaction with the evaluationprocess. The Board of Directors reviewed all the laws applicable to the company preparedby the company and taking steps to rectify instances of non-compliances.

19. NUMBER OF MEETINGS OF IT IE BOARD

The Board of Directors duly met five (5) times i.e. 01.06.2020 29.06.2020 31.08.202011.11.2020 and 10.02.2021 during the year in respect of which notices were given and theproceedings were recorded and signed. Tlie intervening gap between any two meetings waswithin the period presenbed by the Companies Act 2013. Following are tlie details of thedirectors who have attended meetings during the year

A. Audit Committee

The Company has a Audit Committee of Directors in compliance with provisions of theCompanies Act 2013 and Regulation 18 of SEBI (Listing Obligations and DisclosureRequirements) Regulations 2015.

Tlie Committee compnses of:

• Mrs. Rmku Goyal (Chairman & Independent Director)

• Mr. Anoop Kumar Mangal (Member & Managing Director)

• Mr. Manoj Kumar (Member & Independent Director) and

• Ah. Roshan ]ha (Secretary of the Audit Committee).

The terms of reference of the Audit Committee inter alia include overseeing thefinancial reporting process reviewing the financial statements and recommending theappointment of Auditors. All the recommendations made by Audit Committee were accepted.

During the year (4) four meetings of the members of the Audit Committee were held i.e.29.06.2020 31.08.2020 11.11.2020 and 10.02.2021

Vigil Mechanism

The Company has a well framed vigil mechanism/whistle blower policy for its directorsand employees. The company believes in honesty integrity ethics transparency and goodconduct in its professional environment and provides such kind of environment to itsemployees and directors and always encourages its team to follow such standards in theiractivities. Tire directors employees and other team members ate free to report on theissues which require genuine concern. An Audit Committee of the Board of directors hastire responsibility to review the functioning of vigil mechanism and the same has beenperformed by the committee periodically.

This policy is posted on the website at unit1.akjnhcf.com.

B. Nomination and Remuneration Committee

The Company has a Nomination & Remuneration Committee of Directors in compliancewith provisions of the Companies Act 2013 and Regulation 19 of SEBI (Listing Obligationsand Disclosure Requirements) Regulations 2015. Tire Committee's scope of work includesnominate die directors as per their qualifications experience and positive attributesdeciding on remuneration and policy matters related to remunerations of Directors andlaying guidelines for remuneration package or compensation etc.

The Committee comprises oh

• Mr. Manoj Kumar (Chairman & Independent Director)

• Mr. Shambhu Dayal Mangal (Member Non-Executive Director) and

• Mrs. Rinku Goyal (Member Independent Director).

Dunng the year one (1) meeting of the members of the Nomination and RemunerationCommittee was held on 31.08.2020.

Nomination and Remuneration Policy:

Nomination and Remuneration Policy in the Company is designed to create a highperfonnance culture. It enables the Company to attract motivated and retained manpower incompetitive market and to harmonize the aspirations of human resources consistent withthe goals of the Company. The Company pays remuneration by way of salary benefitsperquisites and allowances to its Executive Directors and Key Managerial Personnel. Annualincrements are decided by the Nomination and Remuneration Committee within the salaryscale approved by the members and are effective from April 1 of each year.

The Nomination and Remuneration Policy as adopted by the Board of Directors is placedon the website of the Company at www.akmlace.com.

Remuneration of Director:

The details of remuneration paid during the financial year 2020-21 to Managing Directorof the Company are provided in the Annual Return.

C. Stakeholders Relationship Committee

The Company has a Stakeholder Relationship Committee of Directors in compliance withprovisions of the Companies Act 2013 and Regulation 20 of SEBI (Listing Obligations andDisclosure Requirements) Regulations 2015 to look into the Redtessal of complaints ofinvestors such as transfer or credit of shares non-receipt of dividend/notices /annualreports etc.

The Committee comprises of:

• Mrs. Rinku Goyal (Chairman & Independent Director)

• Mr. Shambhu Dayal Manga] (Member Non Executive Director) and

• Mr. Mano) Kumar (Member Independent Director).

Du ring the year one (1) meeting of the members of the Stakeholders RelationshipCommittee was held on 11.11.2020

21. DIM AIKS OI' SUBSIDIARY/JOINT VENT URE/ ASSOCIATE COMPANIES

The Company does not have any Subsidiary/ Joint Venture/ Associate Companies.

22. PERFORMANCE AND FINANCIAL POSITION OF EACH OF TIIF. SUBSIDIARIES ASSOCIATES ANDIOINT VENTURE COMPANIES

The Company has no subsidianes Joint Venture Companies so there is no requirement ofdescnption of the performance of Subsidiaries and Joint Venture Companies.

23. PARTICULARS OF LOANS. GUARANTEE OR INVESTMENTS

Loans Guarantees and Investments covered under section 186 of the Companies Act 2013form part of the notes to the financial statement and same is provided in this AnnualReport

24. PARTICULARS OF CONTRACTS OR ARKANGMLNTS WI TH RELATED PAR TIES

The Company has entered into contracts and arrangements with related parties andcomplied with the provisions of section 188 of the Companies Act 2013. Details of SuchContracts and Arrangements are enclosed as Annexure-III in Form AOC-2.

25. PARTICULARS OF EMPLOYEES

None of the employees of the Company were in teceipt of remuneration in excess oflimits as presenbed under Rule 5(2) of the Companies (Appointment and Remuneration ofManagerial Personnel) Rules 2014.

Disclosures pertaining to remuneration and other details as required under Section197(12) of the Companies Act 2013 read with Rule 5(1) of Companies (Appointment andRemuneration of Managerial Personnel) Rules 2014 are mentioned below:

(A) Information as per Rule 5fl) of the Companies /Appointment and Remuneration ofManagerial Personnel) Rules. 2014

1. Remuneration of each Director and Key Managerial Personnel (KMP) along withparticulars of increase in remuneration during the financial year Ratio of remunerationof Directors to the Median Remuneration of employees.

2. The median remuneration of the Company for all its employees is Rs. 240000/-forthe financial year 2020-2021

3. The Percentage decrease in median remuneration of employees in the Financial Year33.33%

4. Number of permanent employees on the rolls of the Company: Two (As at March 312021).

5. Average percentile increase already made in the salaries of employees other thanthe managerial personnel in the last

financial year is NIL and its comparison with the percentile increase in the managerialremuneration and justihcation thereof and point out if there are any exceptionalcircumstances for increase in the managenal remuneration

6. Affirmation Pursuant to Rule 5(l)(xii) of the Companies (Appointment andRemuneration of Managerial Personnel) Rules 2014 it is attmned that the remunerationpaid to the Directors Key Managenal Personnel is as per the remuneration policy of theCompany.

26. SEXUAL HARRASEMENT

To foster a positive workplace environment free from harassment of any nature we haveinstitutionalized the Anti-Sexual Harassment Initiative (ASHf) framework through which weaddress complaints of sexual harassment at the all workplaces of the Company. Our policyassures discretion and guarantees non-retaliation to complainants. We follow agender-neutral approach in handling complaints of sexual harassment and we are compliantwith the law of the land where we operate.

During the year under review then were no incidences of sexual harassment reported.

27. Corporate Governance:

Your Company strives to incorporate the appropnate standards for corporate governance.However pursuant to Regulation 15(2) of SEBI (Listing Obligations and DisclosureRequirements) Regulations 2015 the Company is not required to mandatonly comply with theprovisions of certain regulations of the SEBI (Listing Obligations and DisclosureRequirements) Regulations 2015 and therefore the Company has not provided a separatereport on Corporate Governance although few of the information are provided in thisreport of Directors under relevant heading

28. PREVENTION OF INSIDER TRADING

The Company has a Code of Conduct for Prevention of Insider Trading with a view toregulate trading in securities by' the Directors and certain designated employees of theCompany. The Code requires pre-clearance for dealing in the Company's shares and prohibitsthe purchase or sale of Companyr shares by the Directors and designated employees while inpossession of unpublished price sensitive information in relation to the Company andduring the period when the trading window is closed. The Board is responsible forimplementation of the Code. All Board Directors and the designated employees haveconfirmed compliance with the Code.

29. CODE OF CONDUCT

The Board of Directors has approved a Code of Conduct which is applicable to members ofthe Board and all employees in the course of day to day business operations of thecompany. Tire Code has been placed on the Company's website www.akmlace.com. The Code laysdown the standard procedure of business conduct which is expected to be followed by thedirectors and die designated employees in their business dealings and in particular onmatters relating to integrity in the work place in business practices and in dealing withstakeholders.

All tlx- Board Members and the Senior Management personnel have confirmed compliancewith the Code.

30. DISCLOSURE Oh RELATIONSHIP BETWEEN DIRECTOR INTER-SE

Mr. Anoop Kumar Mangal Mrs. Purva Mangal and Mr. Shambhu Dayal Manga] are related toeach other. Mr. Anoop Kumar Mangal is the son of Mr. Shambhu Dayal Mangal and Mrs. PurvaMangal is the wife of Mr. Anoop Kumar Mangal.

31. APPLICABILITY Ol THE INDIAN ACCOUNTING STANDARDS (USD AS!

The financial statements have been prepared in accordance with the Indian AccountingStandards (Ind AS) specified under section 133 of the Companies Act 2013 read with Rule3 of the Companies (Indian Accounting Standards) Rules 2015.

32. SECRETARIAL STANDARDS

Your Company complies with the Secretarial Standard on Meetings of Directors (SS-1) andSecretanal Standard on General Meetings (SS-2) whenever it has applicable. Your Companywill comply with the other Secietanai Standards issued by the Institute of CompanySecretaries of India (ICSI) as and when they are made mandatory.

33. DIRECTOR'S RESPONSIBILITY STATEMENT

In accordance with Clause (c) of sub-section (3) of Section 134 of the Companies Act2013 the Board of Directors of the company informed the members that:

(A) In the preparation of the annual accounts for the financial year ended March 312021 the applicable accounting standards had been followed along with proper explanationrelating to material departures;

(B) Ihe directors had selected such accounting policies and applied them consistentlyand made judgments and estimates that are reasonable and prudent so as to give a true andfair view of the state of affairs of the company at the end of the financial year and ofthe profit and loss of the company for that period;

(C) The directors had taken proper and sufficient care for the maintenance of adequateaccounting records in accordance with the provisions of this Act for safeguarding theassets of the company and for preventing and detecting fraud and other irregularities;

(D) The directors had prepared the annual accounts on a going concern basis; and

(E) The directors had devised proper systems to ensure compliance with the provisionsol all applicable laws and that such systems were adequate and operating effectively.

34. RISK MANAGEMENT POLICY

The Board of Directors of the Company are of the view that currently no significantrisk factors are present which may threaten the existence of the company. During the yearyour Directors have an adequate risk management infrastructure in place capable ofaddressing those risks. The company manages monitors and reports on the principal nsks anduncertainties that can impact its ability to achieve its strategic objectives. The AuditCommittee and Boaid ol Directors review these procedures periodically. The company'smanagement systems organizational structures processes standards code of conduct andbehavior together form a complete and effective Risk Management System (RMS).

35. CAUTIONARY NOTE

The statements forming part of the Board's Report may contain certain forward lookingremarks within the meaning of applicable securities laws and regulations. Many factorscould cause the actual results performances or achievements of the Company to bematerially different from any future results performances or achievements that may beexpressed or implied by such forward looking statements.

36. ACKNOWLEDGEMENT

Your Directors wish to place on record their sincere appreciation for significantcontributions made by the employees at all levels through their dedication hard work andcommitment enabling the Company to achieve good performance during the year under review.

Your Directors also take this opportunity to place on record the valuable co-operationand support extended by the banks government business associates and the shareholdersfor their continued confidence reposed in the Company and look forward to having the samesupport in all future endeavors.