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Shukra Pharmaceuticals Ltd.

BSE: 524632 Sector: Health care
NSE: N.A. ISIN Code: INE551C01028
BSE 00:00 | 24 Sep 88.00 -4.60
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NSE 05:30 | 01 Jan Shukra Pharmaceuticals Ltd
OPEN 88.00
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VOLUME 500
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52-Week low 34.80
P/E 46.07
Mkt Cap.(Rs cr) 14
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OPEN 88.00
CLOSE 92.60
VOLUME 500
52-Week high 108.05
52-Week low 34.80
P/E 46.07
Mkt Cap.(Rs cr) 14
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Shukra Pharmaceuticals Ltd. (SHUKRAPHARMA) - Director Report

Company director report

To

The Members

Shukra Pharmaceuticals Limited

The Directors' present the 27th Annual report on the business and operationsof your Company for the financial year 2019-20.

1) FINANCIAL RESULTS AND OPERATIONAL REVIEW:

Particulars Year Ended 31.03.2020 (Rs.) Year Ended 31.03.2019 (Rs.)
Gross Sales/Income 118460196 56596324
Less Depreciation 14781941 9626854
Profit/(Loss) before Tax 1708391 7243648
Taxes/Deferred Taxes 1352351 2623950
Profit/(Loss) After Taxes 356040 4619698
P& L Balance b/f 96503133 91883435
Profit/ (Loss) carried to Balance Sheet 96859173 96503133

2) BRIEF DESCRIPTION OF THE COMPANY'S WORKING DURING THE YEAR/STATE OF COMPANY'SAFFAIR:

During the period under review the Company has been engaged in the business ofmanufacturing and trading of pharmaceuticals Products laboratory testing and made aprofit of Rs. 356040/-. Your Directors are optimistic about company's business andhopeful of better performance with increased revenue in next year.

3) CHANGE IN THE NATURE OF BUSINESS:

There was no change in the nature of the business of the Company during the year underreview.

4) DIVIDEND:

Since the Company has made insufficient profit the directors are unable to recommendany dividend during the year under review.

5) TRANSFER OF UNCLAIMED DIVIDEND TO INVESTOR EDUCATION AND PROTECTION FUND:

The company does not have any amount which required to be transferred to the InvestorEducation and Protection Fund (IEPF).

6) SEGMENT:

The Company is operating only in two sector i.e. pharmaceutical and Laboratory. Butduring the year the laboratory segment has commenced very minor commercial operation.

7) TRANSFER TO RESERVES:

Out of the profits available for appropriation no amount has been transferred to theGeneral Reserve and the balance amount of Rs. 356040/- has been carried forward tocredit balance of profit & loss account in surplus.

8) CHANGES IN SHARE CAPITAL:

The paid up Equity Share Capital of the Company as on March 31 2020 isRs.15656750/-

A) Issue of equity shares with differential rights:

During the year under review the Company has not issued any shares with differentialvoting rights.

B) Issue of sweat equity shares:

During the year under review the Company has not issued any sweat equity shares.

C) Issue of employee stock options:

During the year under review the Company has not issued any sweat equity shares.

D) Provision of money by company for purchase of its own shares by employees or bytrustees for the benefit of employees:

The Company has no scheme of provision of money for purchase of its own shares byemployees or by trustees for the benefit of employees. Hence the details under rule 16 (4)of Companies (Share Capital and Debentures) Rules 2014 are not required to be disclosed.

9) FINANCE:

The Company has not borrowed loan from any Bank or Financial institution during theyear under review.

10) DETAILS PERTAINING TO SHARES IN SUSPENSE ACCOUNT:

The Company does not have any shares in the demat suspense account or unclaimedsuspense account. Hence Disclosures with respect to demat suspense account/ unclaimedsuspense account are not required to mention here.

11) MATTERS RELATED TO DIRECTORS AND KEY MANAGERIAL PERSONNEL:

Mr. Sujay Mehta (DIN: 02145467) Director retire by rotation at the forthcoming AnnualGeneral Meeting and being eligible offer himself for reappointment.

a) Key Managerial Personnel:

The following are the Key Managerial Personnel of the Company.

Mr. Dakshesh Shah Managing Director
Mr. Karnik Shah Chief Executive Officer

During the year the following changes occurred in the Composition of Board Directorsdue to Appointments and Resignations of several Directors:

Name and Designation Date of Appointment Date of Resignation
Ms. Payal Mehta Chief Executive Officer -- 13/04/2019
Ms. Payal Mehta Chief Financial Officer 13/04/2019 03/05/2019
Mr. Karnik Shah Chief Financial Officer 03/05/2019 28/05/2019
Mr. Karnik Shah Chief Executive Officer 28/05/2019 31/03/2020
Ms. Bhumika Vasvani Company Secretary -- 15/07/2019
Ms. Arpita Shah Company Secretary 07/12/2019 --

12) NUMBER OF MEETINGS OF BOARD OF DIRECTORS:

The meetings of the Board of Directors are held at periodical intervals and aregenerally at the registered office of the Company Ahmedabad. The meeting dates aredecided well in advance and the agenda and notes on agenda are circulated in advance tothe directors. All material information is incorporated in the notes on agenda forfacilitating meaningful and focused discussion at the meeting. Where it is not perusableto attach supporting or relevant documents to the agendas the same is tabled before themeeting. In case of business exigencies or urgency of matters resolutions are passed bycirculation. Senior Management persons are often invited to attend the Board Meetings andprovide clarifications as and when required.

During the year 2019-20 08 (Eight) Board Meetings were convened and duly held on:

13/04/2019 03/05/2019 28/05/2019 15/07/2019 14/08/2019
13/11/2019 07/12/2019 14/02/2020

The Board of Directors of the Company was present at the following Board Meeting heldduring the year under review:

Name of Director Board Meeting Held Meetings attended Attendance at last AGM
Dakshesh Rameshchandra Shah 8 8 Yes
Payalben Sujay Mehta 8 8 Yes
Sujay Jyotindra Mehta 8 8 Yes
Nileshkumar Patel 8 8 Yes
Bhoomiben Patel 8 8 Yes

13) STATEMENT INDICATING THE MANNER IN WHICH FORMAL ANNUAL EVALUATION HAS BEEN MADE BYTHE BOARD OF ITS OWN PERFORMANCE AND THAT OF ITS COMMITTEES AND INDIVIDUAL DIRECTORS:

Pursuant to the provisions of the Companies Act 2013 and SEBI (Listing Obligations andDisclosure Requirement) Regulations 2015 the Board has carried out an annualperformance evaluation of its own performance the directors individually as well as theevaluation of the working of its Audit Nomination and Remuneration Committees.

During the year the Board adopted a formal mechanism for evaluating its performanceand as well as that of its Committees and individual Directors including the Chairman ofthe Board. The exercise was carried out through a structured evaluation process coveringvarious aspects of the Boards functioning such as composition of the Board &committees experience & competencies performance of specific duties &obligations governance issues etc. Separate exercise was carried out to evaluate theperformance of individual Directors including the Board Chairman who were evaluated onparameters such as attendance contribution at the meetings and otherwise independentjudgment safeguarding of minority shareholders interest etc.

The evaluation of the Independent Directors was carried out by the entire Board andthat of the Chairman and the Non-Independent Directors were carried out by the IndependentDirectors.

The Directors were satisfied with the evaluation results which reflected the overallengagement of the Board and its Committees with the Company.

14) PARTICULARS OF EMPLOYEES & EMPLOYEE REMUNERATION:

The table containing the names and other particulars of employees in accordance withthe provisions of Section 197(12) of the Companies Act 2013 read with Rule 5(1) of theCompanies (Appointment and Remuneration of Managerial Personnel) Rules 2014 is providedas "Annexure- A" to the Board's report.

None of the employees of the Company drew remuneration of Rs. 10200000/- or more perannum and Rs. 850000/- or more per month during the year. No employee was in receipt ofremuneration during the year or part thereof which in the aggregate at a rate which isin excess of the remuneration drawn by the managing director or whole-time director ormanager and

holds by himself or along with his spouse and dependent children not less than twopercent of the equity shares of the company.

15) EMPLOYEE RELATIONS:

Employee relations throughout the Company were harmonious. The Board wishes to place onrecord its sincere appreciation of the devoted efforts of all employees in advancing theCompany's vision and strategy to deliver good performance.

16) REPORT ON PERFORMANCE AND FINANCIAL POSITION OF SUBSIDIARIES. ASSOCIATES AND JOINTVENTURE COMPANIES:

The Company has 01(One) Subsidiary Company named Sukarnov Pharmaceuticals PrivateLimited which has still not commence its operations.

17) CHANGE OF NAME:

The Company has not changed its name during the year under review.

18) STATUTORY AUDITORS:

The Company's Auditors M/s. B. J. Trivedi & Associates Chartered AccountantsAhmedabad who was appointed in the Annual General Meeting in the year 2016 for a block of5 year until the conclusion of the Annual General Meeting to be held in 2021 subject toratification of their appointment at every annual general meeting. Hence the board hasrecommended to ratify his appointment for FY 2019-20 as they are eligible for theappointment.

The Company has appointed M/s. Soni & Patel Chartered Accountants Ahmedabad asinternal auditors of the company.

19) COST AUDITORS:

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 since the cost audit is not applicable to the Company.

20) SECRETARIAL AUDIT REPORT:

Pursuant to the provisions of Section 204 of the Companies Act 2013 and The Companies(Appointment and Remuneration of Managerial Personnel) Rules 2014 the Company hasappointed CS Rupal Patel Practicing Company Secretary to undertake the Secretarial Auditof the Company. The Secretarial Audit Report is annexed herewith as "Annexure-B".

Reply to the qualification Remarks in Secretarial Audit Report:

1. The company is in the process of complying with these requirements of thecomposition of the Nomination and Remuneration Committee w.r.t. SEBI (Listing

Obligations and Disclosure Requirement) Regulations 2015 read with the Companies Act2013.

2. Though the Company has not published notice for Financial Result the company hasuploaded the same on Website of the company and also submitted to BSE Limited also.

3. The Company is in process of filing return and maintaining register as mentioned inFactory Act 1948.

4. The company has taken note of non-compliances with respect to maintenance ofregisters and returns for Provident Fund and Employee Insurance and shall take necessarysteps to maintain the same in near future.

5. The Board of Director has taken serious not of non-compliance with various clausesas mentioned in Consent Order No. AWH-24673 dated 28/08/2017 issued by the GujaratPollution Board Gandhinagar and committed to comply with the same in coming year.

6. The query as to non-payment of dividend has been complied with in the current year.

7. The Company has taken serious note of delay in compliance with various clauses ofSEBI (LODR) committed to the same and will complied in future within time.

8. The company has opened separate bank account as per section 123 of the CompaniesAct 2013 in the current year.

9. The company is in process of filling the form IEPF 2 and also in compliance withsection 96 read with subsection 2 of section 125 of The Companies Act 2013.

10. Due to non-commencement of the business of Sukarnov Pharmaceuticals PrivateLimited the board has decided to struck off the Company and hence the consolidatedfinancial statements has not been filed by the Company.

11. The Company has taken note of the observation made by the statutory auditors of theCompany under section 189 of the Companies act 2013 and will undertake to comply thesame.

12. The Company has instructed Labour Contractor to get his entity registered withrespective act.

13. The Company has filed DPT-3 with additional fees and the Company will file infuture within time.

21) RESPONSE TO AUDITOR'S REMARKS:

Observation made by the Statutory Auditors in their Report are self explanatory andtherefore do not call for any further comments under section 134(3)(f) of the CompaniesAct 2013 except five qualified opinions towards which the response of your Directors areas under:-

1. The Board of Directors has taken note of the comment as to interest free loans andadvances to related parties and the made changes in terms and conditions so as to complywith the qualification remark.

2. Necessary accounting has been done in the books of accounts and complied with thequalification remark.

3. The Company has appointed Mr. Mehul Patel on 11th May 2020 and compliedwith the requirement of the section 203 of the Companies Act 2013 for appointment ofChief Financial Officer (CFO).

4. The Company has made necessary arrangement for complied with the same but Due toCOVID-19 Pandemic the financial instrument has been issued but the same has not beenpresented to the bank for clearance. The Company has complied with same in currentFinancial Year.

5. With respect to note as to availment of interest free loans from directors andbalance confirmation declaration from directors the Board hereby confirm that the loanswere taken to meet the urgent business needs of the company and later on also obtainedconfirmation of balances and declaration from the said directors.

22) INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY:

The Company has an Internal Control System commensurate with the size scale andcomplexity of its operations. During the year under review the company retained externalaudit firm to review its existing internal control system with a view of tighten the sameand introduce system of self certification by all the process owners to ensure thatinternal controls over all the key business processes are operative. The scope andauthority of the Internal Audit (IA) function is defined in the Internal Audit Charter.

The Internal Audit Department monitors and evaluates the efficacy and adequacy ofinternal control system in the Company its compliance with operating systems accountingprocedures and policies at all locations of the Company and its subsidiaries. Based on thereport of internal audit function process owners undertake corrective action in theirrespective areas and thereby strengthen the controls. Significant audit observations andcorrective actions thereon are presented to the Audit Committee of the Board.

23) AUDIT COMMITTEE:

The Audit Committee of the Board of Directors of the Company comprises 3 Members. aswell as those in section 177 of the Companies Act 2013 and include the reviewing ofquarterly halfyearly and annual financial statements before submission to the Boardensure compliance of internal control systems and internal audit timely payment ofstatutory dues and other matters.

During the year under review 6 meetings of the committee were held 13/04/201903/05/2019 28/05/2019 14/08/2019 13/11/2019 and 14/02/2020. The composition ofcommittee and attendance at its meetings is given below:

Sr. No. Name Position Category Number of meeting Attend
1 Ms. Bhoomiben Patel Chairman Non-Executive Independent Director 6
2 Mr. Nileshkumar Patel Member Independent Director 6
3 Ms. Payal Sujay Mehta Member Executive Director 6

24) VIGIL MECHANISM:

The Company has a vigil mechanism named Whistle Blower Policy to deal with instances offraud and mismanagement if any. The company has adopted a Whistle Blower Policy whichaffords protection and confidentially to Whistle blowers. The Audit Committee Chairman isauthorized to receive Protected Disclosures under this Policy. The Audit Committee is alsoauthorized to supervise the conduct of investigations of any disclosures made whistleblowers in accordance with policy.

No personnel have been denied access to the Audit Committee. As of March 31 2020 noProtected Disclosures have been received under this policy.

25) NOMINATION AND REMUNERATION COMMITTEE:

The Board of Directors of the company have constituted a Nomination & RemunerationCommittee of Directors mainly for the purposes of recommending the Company's policy onRemuneration Package for the Managing/Executive Directors reviewing the structure designand implementation of remuneration policy in respect of key management personnel.

The Nomination & Remuneration Committee consisted of 3 Members. During the yearunder review 5 meetings of the committee were held 13/04/2019 03/05/2019 28/05/201915/07/2019 and 07/12/2019. The name of members Chairman and their attendance at theRemuneration Committee Meeting are as under Committee of Board:

Sr. No. Name Position Category Number of meeting Attend
1 Ms. Bhoomiben Patel Chairman Non-Executive Independent Director 5
2 Mr. Nileshkumar Patel Member Independent Director 5
3 Ms. Payal Sujay Mehta Member Executive Director 5

The Board has on the recommendation of the Nomination and Remuneration Committeeframed a policy for selection and appointment of Directors Key Managerial Personnel andSenior Management and their remuneration. The Remuneration Policy is also available on theCompany's website at www.shukrapharmaceuticals.com

26) STAKEHOLDERS RELATIONSHIP COMMITTEE:

The Stakeholders Relationship Committee consisted of 3 Members. During the year underreview 4 meetings of the committee were held 12/04/2019 11/07/2019 05/10/2019 and08/01/2020. The name of members Chairman and their attendance at the StakeholdersRelationship Committee are as under Committee of Board:

Sr. No. Name Position Category Number of meeting Attend
1 Ms. Bhoomiben Patel Chairman Non-Executive Independent Director 4
2 Mr. Nileshkumar Patel Member Independent Director 4
3 Ms. Payal Sujay Mehta Member Executive Director 4

The status of shareholders' complaints received so far/number not solved to thesatisfaction of shareholders/number of pending share transfer transactions (as on 31stMarch 2020 is given below):-

Complaints Status: 01.04.2019 to 31.03.2020

Number of complaints received so far 1
Number of complaints solved 1
Number of pending complaints 0

Compliance Officer:

Ms. Arpita Shah is Compliance Officer of the company for the purpose of complying withvarious provisions of Securities and Exchange Board of India (SEBI) Listing Agreementwith Stock Exchanges Registrar of Companies and for monitoring the share transfer processetc.

a) Share Transfer System:

All the transfers are received and processed by share Transfer agents and are approvedby share transfer committee. Share Transfer requests received in physical form areregistered within 30 days and demat requests are confirmed within 15 days.

b) Dematerialization of shares and liquidity:

Details of Registrar and Share Transfer agent of the Company for dematerialization ofshares:

Name : Purva Sharegistry (India) Private Limited
Address : Unit no. 9 Shiv Shakti Ind. Estt. J .R. Boricha marg Opp. Kasturba Hospital Lane Lower Parel (E) Mumbai 400011.
Tel : 22-2301 2518 / 6761
Fax : 022 - 23012517
Email : support@purvashare.com

27) STATEMENT CONCERNING DEVELOPMENT AND IMPLEMENTATION OF RISK MANAGEMENT POLICY OFTHE COMPANY:

The Company has laid down a Risk Management Policy and identified threat of such eventswhich if occurs will adversely affect either / or value to shareholders ability ofcompany to achieve objectives ability to implement business strategies the manner inwhich the company operates and reputation as "Risks". Further such Risks arecategorized in to Strategic Risks Operating Risks & Regulatory Risks. A detailedexercise is carried out to identify evaluate manage and monitoring all the three typesof risks.

28) EXTRACT OF ANNUAL RETURN:

As required pursuant to section 92(3) of the Companies Act 2013 and rule 12(1) of theCompanies (Management and Administration) Rules 2014 an extract of annual return in MGT9 as a part of this Annual Report as "Annexure-C".

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

There is no any Material changes occurred subsequent to the close of the financial yearof the Company to which the balance sheet relates and the date of the report.

30) DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS ORTRIBUNALS IMPACTING THE GOING CONCERN STATUS AND COMPANY'S OPERATIONS IN FUTURE:

There is no significant and material order passed by the regulators or courts ortribunals impacting the going concern status and company's operations in future during theyear under review.

31) DETAILS IN RESPECT OF ADEQUACY OF INTERNAL FINANCIAL CONTROLS WITH REFERENCE TO THEFINANCIAL STATEMENTS:

The Company has adequate and proper Internal financial controls with reference to theFinancial Statements during the year under review.

32) PARTICULARS OF CONTRACTS OR ARRANGEMENTS WITH RELATED PARTIES:

All related party transactions that were entered into during the financial year were onan arm's length basis and were in the ordinary course of business. There were nomaterially significant related party transactions made by the Company with PromotersDirectors Key Managerial Personnel or other designated persons which may have a potentialconflict with the interest of the Company at large.

33) PUBLIC DEPOSIT:

During the year under review the Company has not accepted any deposits to which theprovisions of section 73 74 of the Companies Act 2013 read with Acceptance of DepositsRules 2014 as amended are applicable.

34) PARTICULARS OF LOANS. GUARANTEES OR INVESTMENTS UNDER SECTION 186:

Details of Loans Guarantees and Investments covered under the provisions of Section186 of the Companies Act 2013 are given in the notes to the Financial Statements.

35) CORPORATE GOVERNANCE:

As per SEBI circular no: CFD/POLICYCELL/7/2014 dated 15th September 2014(Regulation 27(2) of SEBI (Listing Obligations and Disclosure Requirements) Regulations2015 shall not be mandatory to the following class of companies:

a) Companies having paid up equity share capital not exceeding Rs.10 crore and NetWorth not exceeding Rs.25 crore as on the last day of the previous financial year;

Provided that where the provisions of (Regulation 27(2) of SEBI (Listing Obligationsand Disclosure Requirements) Regulations 2015 becomes applicable to a company at a laterdate such company shall comply with the requirements of (Regulation 27(2) of SEBI(Listing Obligations and Disclosure Requirements) Regulations 2015 within six months fromthe date on which the provisions became applicable to the company.

Accordingly it may be noted that the paid up share capital of the Company is below Rs.10 crore and Net Worth of the Company has not exceeded Rs.25 crore as on 31stMarch 2020 and hence Corporate Governance is not applicable to the Company.

36) MANAGEMENT DISCUSSION AND ANALYSIS:

Management discussion and analysis Report pursuant to Schedule V of the SEBI (ListingObligations and Disclosure Requirement) Regulations 2015 forms part of this Report andthe same is annexed as "Annexure-D".

37) DETAIL OF FRAUD AS PER AUDITORS REPORT:

There is no fraud in the Company during the Financial Year ended 31st March2020. This is also being supported by the report of the auditors of the Company as nofraud has been reported in their audit report for the financial year ended 31st March2020.

38) OBLIGATION OF COMPANY UNDER THE SEXUAL HARASSMENT OF WOMEN AT WORKPLACE(PREVENTION PROHIBITION AND REDRESSAL) ACT 2013:

The Company has zero tolerance for sexual harassment at workplace and has adopted apolicy against sexual harassment in line with the provisions of Sexual Harassment of Womenat Workplace (Prevention Prohibition and Redressal) Act 2013 and the rules framed thereunder.

During the financial year 2019-20 the company has not received any complaints onsexual harassment and hence no complaints remain pending as of 31 March 2020.

39) CONSERVATION OF ENERGY. TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS ANDOUTGO:

The information on conservation of energy technology absorption and foreign exchangeearnings and outgo stipulated under Section 134(3)(m) of the Companies Act 2013 read withRule 8 of The Companies (Accounts) Rules 2014 is annexed herewith as "Annexure-E".

40) CORPORATE SOCIAL RESPONSILIBILTY (CSR):

The Provision of Section 135 of the Company Act 2013 are not applicable since thecompany does not fall under Category of Rule 9 of the Corporate Responsibility Rules 2014.

41) DIRECTORS' RESPONSIBILITY STATEMENT:

To the best of their knowledge and belief and according to the information andexplanations obtained by them your Directors make the following statements in terms ofSection 134(3)(c) of the Companies Act 2013:

a) that in the preparation of the annual financial statements for the year endedMarch 31 2020 the applicable accounting standards have been followed along with properexplanation relating to material departures if any;

b) that such accounting policies have been selected and applied consistently andjudgment and estimates have been made that are reasonable and prudent so as to give a trueand fair view of the state of affairs of the Company as at March 31 2020 and of theprofit of the Company for the year ended on that date;

c) that proper and sufficient care has been taken for the maintenance of adequateaccounting records in accordance with the provisions of the Companies Act 2013 forsafeguarding the assets of the Company and for preventing and detecting fraud and otherirregularities;

d) that the annual financial statements have been prepared on a going concern basis;

e) that proper internal financial controls were in place and that the financialcontrols were adequate and were operating effectively;

f) that systems to ensure compliance with the provisions of all applicable laws were inplace and were adequate and operating effectively

42) SECRETARIAL STANDARDS:

The Directors State that applicable Secretarial Standards i.e. SS-1 and SS-2 relatingto ‘Meetings of the Board of Directors' and General Meetings' respectively havebeen duly followed by the Company.

43) LISTING WITH STOCK EXCHANGES:

The Company confirms that it has paid the Annual Listing Fees for the year 2019-20 toBSE where the Company's Shares are listed.

44) PREVENTION OF INSIDER TRADING:

In January 2015 SEBI notified the SEBI (Prohibition of Insider Trading) Regulation2015 which came into effect from May 2015. Pursuant thereto the Company has formulatedand adopted a new code for Prevention of Insider Trading.

The New Code viz. "Code of Internal Procedures and Conduct for regulatingMonitoring and reporting of Trading by Insiders" and "Code of Practices andProcedures for fair Disclosure of Unpublished price Sensitive Information" has beenframed and adopted. The Code requires pre-clearance for dealing in the Company's sharesand prohibits purchase or sale of Company shares by the Directors and designated employeeswhile in possession of unpublished price sensitive information in relation to the Companyand during the period when the Trading Window is closed. The Company is Responsible forimplementation of the Code.

45) ACKNOWLEDGEMENTS:

The management is grateful to the government authorities Bankers Vendors for theircontinued assistance and co-operation. The directors also wish to place on record theconfidence of members in the company.

For On Behalf of Shukra Pharmaceuticals Limited
Date : 28/11/2020 Payal Mehta Arpita Shah
Place : Ahmedabad Director Company Secretary & Compliance Officer
Dakshesh Shah (DIN: 02145421)
Managing Director
(DIN: 00561666)

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