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Sindhu Trade Links Ltd.

BSE: 532029 Sector: Others
NSE: N.A. ISIN Code: INE325D01025
BSE 00:00 | 07 Feb 21.20 0.15
(0.71%)
OPEN

21.75

HIGH

21.80

LOW

20.00

NSE 05:30 | 01 Jan Sindhu Trade Links Ltd
OPEN 21.75
PREVIOUS CLOSE 21.05
VOLUME 121566
52-Week high 55.40
52-Week low 15.30
P/E 117.78
Mkt Cap.(Rs cr) 3,269
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00
OPEN 21.75
CLOSE 21.05
VOLUME 121566
52-Week high 55.40
52-Week low 15.30
P/E 117.78
Mkt Cap.(Rs cr) 3,269
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Sindhu Trade Links Ltd. (SINDHUTRADE) - Director Report

Company director report

To

The Members

Sindhu Trade Links Limited

Your directors have immense pleasure in presenting their 30thAnnual Report together with the Audited Statement of Accounts for the financial year endedon 31st March 2022.

The financial results for the year under reviews are as follows:

(Amount in Lakhs)

Particulars

Standalone

Consoidated

2021-22 2020-21 2021-22 2020-21
Total Revenue 63245.26 72591.05 105218.20 96094.54
Total Expenses 59037.19 66853.46 109327.29 104151.70
Profit / (Loss) Before Tax 4208.07 7031.25 3874.60 6703.51
Current Tax 1067.14 254.04 1717.48 1034.23
Deferred Tax (164.73) 207.02 292.10 157.47
Tax of Previous Years (16.09) 284.63 22.68 318.48
Profit / (Loss) after Tax 3321.75 6285.56 (5277.30) (8213.69)

CHANGE IN ACCOUNTING POLICY/ PRINCIPLES

There has been no change in the Accounting Policy of the Company.

COMPANIES' OPERATIONS

On standalone basis the company has achieved the Total Revenue of Rs.63245.26 Lakhs as against the Rs. 72591.05 Lakhs during the previous year. PAT was at Rs.3321.75 Lakhs in current year as compared to Rs. 6285.56 Lakhs in previous year.

On Consolidation basis the company has achieved the Total Revenue ofRs. 105218.20 Lakhs as against the Rs. 96094.54 Lakhs during the previous year. PAT was atRs. (5277.30) Lakhs in current year as compared to Rs. (8213.69) Lakhs in previous year

CHANGE IN THE NATURE OF BUSINESS IF ANY

During the year under report there is no change in the business of theCompany and is continue to extracts its major revenue from the logistics trading of oiland lubricants and investment and finance operations.

TRANSFER TO RESERVES

During the year under review no amount has been transferred toreserves.

MATERIAL CHANGES BETWEEN THE DATE OF THE BOARD REPORT AND END OFFINANCIAL YEAR

There have been no material changes and commitments affecting thefinancial position of the Company which have occurred between the end of the financialyear of the Company to which the financial statements relate and the date of the report.

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

During the year under review there have been no such significant andmaterial orders passed by the regulators or courts or tribunals impacting the goingconcern status and company's operations in future.

STATUS OF SUBSIDIARY COMPANIES JOINT VENTURES AND ASSOCIATE

The subsidiaries in which the shareholding of the Company is presentlymore than half of the nominal capital of the Company as per section 2(87) of the CompaniesAct 2013 are:

• Hari Bhoomi Communications Private Limited is a Private LimitedCompany incorporated on 08.05.2007 by Registrar of Companies National Capital Territoryof Delhi and Haryana. The company is engaged in Publication of daily newspaper of Hindi inthe State of Chhattisgarh Madhya Pradesh Delhi and Haryana Bhopal under the name"Hari Bhoomi" and a TV channel namely "JANTA TV".

Specialised Areas:

This newspaper contains news of current events informative articlesdiverse features and advertising. It has contributed immensely in the field of mediathrough its eye-opening articles and independent views. "Hari Bhoomi" wasstarted initially as a Weekly in 1996 but later on in 1998 it became a Daily .It was thefirst Daily to be published from Rohtak (Haryana). "Hari Bhoomi" launched itsfirst edition in Chhattisgarh in 2001 from Bilaspur and added Raipur in 2002. Hari Bhoomistarted its Jabalpur Edition in 2008. Very recently Hari Bhoomi started its edition fromRaigarh (Chhattisgarh) and Bhopal.

Hari Bhoomi is a member of Indian Newspaper Society Audit Bureau ofCirculations (Two esteemed organizations of Newspapers/Magazines/AdvertisingAgencies/Advertisers) and also member of MRUC (Media Research Users Council) anorganization conducting Indian Readership Survey.

% of Holding by the Company:

The present authorised share capital of the company is Rs.31000000/- divided into 3100000 equity shares of Rs. 10/- each. The present paid- upshare capital of the company is Rs. 30357000/- divided into 3035700 equity shares ofRs. 10/- each. STLL is holding 84.68% of the nominal capital of HBCPL.

• Indus Automotives Private Limited: A Private Limited Companyincorporated on July 05 2010 by Registrar of Companies National Capital Territory ofDelhi and Haryana. The company acts from manufacturers to retailers storers andwharehousers importers exporters repairers hirers in all types of automotive vehiclesusable on land sea or air and to do all the allied activities relating thereto.

Specialised Areas:

The Company is engaged in the business of trading of genuineautomobiles spare parts heavy earthmoving equipment parts lubricants tyres tubes andflaps. The Company holds authorised dealership of Asia Motor Works Ltd (AMW Ltd) forcommercial vehicles for Tyres tube and flaps of Birla Tyre Ceat Ltd. MRF Limited J.KTyre & Industries Ltd. Apollo Tyres Ltd. for dealership for Lubricant of ValvolineCummins Pvt. Ltd. Total Oil India Pvt Ltd. dealership for genuine automobiles spareparts of Ashoka Leyland Tata Motors Mahindra Mico TVS Bosch Telco and Turbo anddealership for spare parts of heavy earthmoving parts with machinery parts of LiebherrIndia Ltd Tata Hitachi Hindustan Motors. The Company also has LMV workshop located atDipka korba C.G. for repairs & maintenance of Light motor vehicles.

Present Financial Structure and % of holding of STLL:

The present authorised share capital of the company is Rs. 5500000/ -divided into 550000 equity shares of Rs. 10/- each. The present paid- up share capitalof the company is Rs. 5250000/- divided into 525000 equity shares of Rs. 10/- each.STLL is holding 98.10% of the nominal share capital of In APL.

• Sudha Bio Power Private Limited A Private Limited Companyincorporated on 21st July 2011 by Registrar of Companies Hyderabad. TheCompany is engaged in the business of generating harnessing developing accumulatingdistributing and supplying of electricity by setting up Bio mass power plants by use ofliquid gaseous or solid fuels for the purpose of light heat motive power and for allother purposes for which electric energy can be employed. However due to all operationaland management activities were carried out from New Delhi and keeping in view theadministrative convenience cost effectiveness growth potential and opportunitiesexisting the Company shifted its registered office from Andhra Pradesh to New Delhi on25.02.2016.

Specialised Areas:

It is presently engaged into the business of generating distributingand supplying of electricity through its Bio Mass Power Plant by use of liquid gaseous orsolid fuels and to generate Power supply either by hydro solar thermal gas diesel oilor through Renewable Energy Sources such as solar photo voltaic and wind mill and or anyother means and to Transmit distribute supply and sell such power either directly orthrough Transmission lines and facilities of central/State Governments or privateCompanies or Electricity Boards to industries and to Central/ State Governments to beproved other consumers or electricity including for captive consumption for any otherindustrial projects promoted by this company or promoter Companies and generally todevelop generate accumulate power at any other place or places and to transmitdistribute sell and such supply such power and to acquire coal mines in India and/ orabroad and to acquire concessions or licenses granted by or to enter into contracts withthe Government of India or any other government authority for the construction operationand maintenance of any electric installation for the production transmission or useelectric power of lighting heating signalling and other allied activities thereto.

Present Financial Structure and % of holding of STLL

During the year under review the present authorized share capital ofthe company is Rs. 360000000/- divided into 36000000 equity shares of Rs. 10/- each.The present paid- up share capital of the company is Rs. 90100000/- divided into9010000 equity shares of Rs. 10/- each. STLL is holding 100% of the nominal sharecapital of In SBPPL.

• Victory Oil & Gas Services Private Limited A PrivateLimited Company incorporated on 16th February 2022 by Registrar of CompaniesShillong. The company is engaged in the business of natural gases and its distribution.

• Param Mitra Resources Pte. Ltd. ("PMR" or"Company" or "Param Mitra") is a leading Coal and Power player inIndonesia promoted by the Sindhu Family a leading coal-mining coal logistics coalbeneficiation power generation and power distribution in India with over 30 years ofexperience in the coal and energy sector under the flagship of Sainik-Aryan Group (SAG).

Specialised Area:

PMR has proven expertise in conducting exploration mining &logistics operations in India and abroad and the same allows the company to understand andmanage the operations of mines in the most cost effective manner. The company has itspresence over many counties. Some of them are described below:

Australia: Param Mitra has recently entered into a mine managementagreement with an operating mine in Western Australia for producing 3 mn tons per annum.

Indonesia: Param Mitra is presently operating four mines giving itaccess to over 1.5 bn tonnes of reserves in East Kalimantan.

Marketing Strategy : Param Mitra has a multi dimensional marketing andend use strategy for coal which will be produced by several mines in Indonesia. ParamMitra is currently supplying and exploring more opportunities of supply in South and EastAsia. Strategically looking at a combination of

• Long term relationships with commodity players and off-takeagreements

• Domestic Market strategy

• Power sector in Indonesia

Present Financial Structure and % of holding of STLL

During the year under review the present paid up share capital of thecompany is 75735514 Equity Shares of USD $ 1 each. STLL is holding 92.46% of thenominal share capital In PMR Pte. Ltd.

The below mentioned list of Companies are subsidiaries of Hari Bhoomi& PMR Pte. Ltd. which itself are subsidiaries of STLL:

Subsidiary of Hari Bhoomi:

> Legend Travels Private Limited A Private Limited Companyincorporated on 21st October 1997 by Registrar of Companies National CapitalTerritory of Delhi and Haryana. The company was incorporated with a view to carry on thebusiness of Media & Entertainment including running of T.V. Channel IPTV RadioChannel & Publishing of News Paper.

Specialised Areas:

Currently it is engaged in the support services to Media Companies.

Present Financial Structure and % of holding of Hari Bhoomi:

During the year under review the present authorized share capital ofthe company is Rs. 100000000/- divided into 10000000 equity shares of Rs. 10/- each.The present paid- up share capital of the company is Rs. 96797790/- divided into9679779 equity shares of Rs. 10/- each. Hari Bhoomi is holding 100% of the nominal sharecapital in LTPL

SUBSIDIARIES OF PARAM MITRA RESOURCES PTE. LTD. (OVERSEAS SUBSIDIARIES)

The overseas subsidiaries are presently engaged in coal mining andallied activities thereto. The details of the Companies are mentioned below:

PARAM MITRA RESOURCES PTE. LTD.

Param Mitra Coal Resources Pte Limited (PMCR Pte Ltd.) Oceania Resources Pty Limited (OR Pty Ltd.) Param Mitra Power Pte Ltd. Sukarma Coal Resources Pte Ltd (SCR Pte Ltd)
The paid up share capital of the Company is USD 30000000 divided into 30000000 equity shares of USD 1/- each. The paid up share capital of the Company is 100000 USD divided into 100000 equity shares of USD 1/- each. The paid up share capital of the Company is 10000 USD divided into 10000 equity shares of USD 1/- each. The paid up share capital of the Company is 1600000 USD divided into 1600000 equity shares of USD 1/- each.
PMR Pte Ltd (Subsidiary of STLL) is holding 65% of the share capital of OR Pty Ltd. PMR Pte Ltd (Subsidiary of STLL) is holding 70% of the share capital of PMP Pte Ltd.
PMR Pte Ltd (Subsidiary of STLL) is holding 60% of the share capital of PMCR Pte Ltd. PMR Pte Ltd (Subsidiary of STLL) is holding 100% of the share capital of SCR Pte Ltd.
Param Mitra Coal Resources Pte. Two Limited (PMCR Pte. Two Ltd.) Param Mitra Coal Resources Pte. One Limited (PMCR Pte. One Ltd.) Unity Holding Business Singapore Pte. Ltd (UHBS Pte. Ltd.) Dragon Power Investment Limited (DPIL)
The paid up share capital of the company is USD 5530000 divided into 5530000 equity shares of USD 1/- each. The paid up share capital of the company is USD 14875000 divided into 14875000 equity shares of USD 1/- each. The paid up share capital of the Company is USD 1500 000 divided into 1500000 equity shares of USD 1/- each. The Paid up Share Capital of the Company is USD 1 divided into 1 Equity Share of USD 1/- each.
Param Mitra Coal Resources Pte Limited (Subsidiary of PMR Pte Ltd) is holding 100% of the share capital of DPIL.
Param Mitra Coal Resources Pte Limited (Subsidiary of PMR Pte Ltd) is holding 100% of the nominal share Param Mitra Coal Resources Pte Limited (Subsidiary of PMR Pte Ltd) is holding 100% of the nominal share Param Mitra Coal Resources Pte Limited (Subsidiary of PMR Pte Ltd) is holding

capital of PMCR Pte. Two capital of PMCR Pte. One 100% of the share capital of Ltd.Ltd. UHS Pte. Ltd.

Pt Rencana Mulia Baratama (Pt. RMB) Pt. Param Mitra Coal Movers(Pt. PMCM) (Earlier Pt. Mesra Prima Coal (Pt. mpc) Pt. Param Mitra Coal Resources (Pt. PMCR)
The paid up share capital of the company is IDR 5000000000 divided into 50000 equity shares of IDR 100000/- each. The paid up share capital of the company is IDR 50000000000 divided into 400000 equity shares of 125000 IDR each. The paid up share capital of the company is IDR 8932000000 divided into 1000000 equity shares of 8932 IDR each.
PMCR Pte. Two Ltd.(Subsidiary of PMCR Pte Ltd.) is holding 93.80 % of the share capital of Pt. RMB. PMCR Pte One Limited (Subsidiary of PMCR Pte Limited) is holding 99% of the share capital of Pt. PMCM. UHBS Pte. Ltd. (Subsidiary of PMCR Pte Ltd) is holding 99% of the share capital of Pt. PMCR.
Pt Rencana Mulia Baratama (Pt. RMB) Pt. Param Mitra Coal Movers(Pt. PMCM) (Earlier Pt. Mesra Prima Coal (Pt. mpc) Pt. Param Mitra Coal Resources (Pt. PMCR)
The paid up share capital of the company is IDR 5000000000 divided into 50000 equity shares of IDR 100000/- each. The paid up share capital of the company is IDR 50000000000 divided into 400000 equity shares of 125000 IDR each. The paid up share capital of the company is IDR 8932000000 divided into 1000000 equity shares of 8932 IDR each.
PMCR Pte. Two Ltd.(Subsidiary of PMCR Pte Ltd.) is holding 93.80 % of the share capital of Pt. RMB. PMCR Pte One Limited (Subsidiary of PMCR Pte Limited) is holding 99% of the share capital of Pt. PMCM. UHBS Pte. Ltd. (Subsidiary of PMCR Pte Ltd) is holding 99% of the share capital of Pt. PMCR.
Pt. Krida Makmur Bersama (Pt. KMB) Pt. Brillian Alam Sejahtera(Pt. BAS)
The paid up share capital of the Company is IDR 10000000000 divided into 10000 equity shares of 1000000 IDR each. The paid up share capital of the Company is IDR 10000000000 divided into 10000 equity shares of IDR 1000000 each.
Pt. PMCM (Subsidiary of PMCR Pte. One Ltd.) is holding 99.99% of the share capital of Pt. KMB. Pt. PMCM (Subsidiary of PMCR Pte. One Ltd.) is holding 99.99% of the share capital of Pt. BAS
PT Global Bumi Lumbung Indonesia (Pt. GBLI) PT Jaya Jasamandiri (Pt. JJ) PT Indo Bara Pratama (Pt. IBP)
The paid up share capital of the company is IDR 134600000000 divided into 134600 equity shares of IDR 1000000/- each. The paid up share capital of the company is IDR 131410000000 divided into 131410 equity shares of 1000000 IDR each. The paid up share capital of the company is IDR 1000000000 divided into 1000 equity shares of 1000000 IDR each.
DPIL (Subsidiary of PMCR Pte Ltd.) is holding 99.95 % of the share capital of Pt. GBLI. DPIL (Subsidiary of PMCR Pte Limited) is holding 99.92% of the share capital of Pt. jj. DPIL (Subsidiary of PMCR Pte Ltd) is holding 99.90% of the share capital of Pt. IBP.

CORPORATE SOCIAL RESPONSIBILITY

The Company has planned to undertake the various projects in accordancewith the Schedule VII of the Companies Act 2013. The details of the proposed CSRactivities to be undertaken by the company and the disclosures as per section 135 of theCompanies Act read with Companies ( Corporate Social Responsibility ) Rules2014 isdisclosed separately as Annexure -A.

NUMBER OF MEETINGS OF BOARD

During the year 2021-22 the Board of Directors met in each quarter andthe proceedings of the meeting are as per the provisions of the Companies Act 2013alongwith all other applicable provisions. The details of the meeting of the Board ofDirectors have been set out separately in Corporate Governance Report.

DECLARATION BY INDEPENDENT DIRECTORS

The Company has received necessary declaration from each IndependentDirector under section 149(7) of Companies Act 2013 that he/ she meets the criteria ofindependence laid down in section 149(6) of Companies act 2013 and as per the prescribedregulation of SEBI (Listing Obligations and Disclosure Requirements) regulations 2015.

DIVIDEND

Your Directors recommend no amount of dividend for the financial year2021-22. DETAILS OF DIRECTORS KEY MANAGERIAL PERSONNEL • Re-appointment of Director:

o Pursuant to the provisions of the Section 152 and other applicableprovisions if any of the Companies Act 2013 Mr. Rudra Sen Sindhu (DIN: 00006999)Director of the Company retire by rotation and being eligible have offered themselves forre-appointment. Your director recommends his re-appointment.

o Pursuant to the provisions of the Section 152 and other applicableprovisions if any of the Companies Act 2013 Mrs. Usha Sindhu (DIN: 00033930) Directorof the Company retire by rotation and being eligible have offered themselves forre-appointment. Your director recommends his re-appointment.

o Mr. Ajmer Singh (DIN 07472795) was appointed as additionalIndependent Director on 29th September 2021 and was regularised on 21stJanuary 2022 (EGM).

PUBLIC DEPOSITS

The Company has not invited/ accepted any deposits from the publicduring the year ended March 31 2022. There were no unclaimed or unpaid deposits as onMarch 31 2022.

AUDITOR'S REPORT

Auditors' Report on the financial statements for the year ended onMarch 31 2022 together with notes thereon is attached separately in this annual report. Aperusal of the statement reflects that it certifies true and fair view of state of affairsof the Company. Further the report also contains the prescribed annexure (known as CARO).In the said annexure Auditors are required to give their observations on prescribeditems. In the said Annexure Auditors while quoting the observations in respect of all theitems have not made any qualification in respect any item.

The observations made in the Auditors' Report are self-explanatory andtherefore do not call for any further comments.

AUDITOR

Statutory Auditor:

M/s Divyank Khullar & Associates Chartered Accountants (FRN No.025755N) holding office until the conclusion of the 30th Annual GeneralMeeting whose liable to retire at the ensuing AGM.

M/s NGC & Associates Chartered Accountants (Firm Registration No.033401N / N500351) has been recommended by the Board of Directors for the approval ofMembers to be appointed as the Statutory Auditors of the Company from the Conclusion ofthis Annual General Meeting to hold office till the thirty Fifth Annual General Meeting ofthe Company

Secretarial Auditor:

Pursuant to the provisions of Section 204 of the Companies Act 2013and the Companies (Appointment and Remuneration of Managerial Personnel) Rules 2014Secretarial Audit has been carried out by Anamika Bhola & Associates CompanySecretaries.

The Secretarial audit report does not contain any qualificationreservation and adverse remarks and the report is attached as "Annexure B".

CONSERVATION OF ENERGY TECHNOLOGY ABSORPTION & FOREIGN EXCHANGEEARNINGS AND OUTGO

The details of conservation of energy technology absorption &foreign exchange earnings and outgo are as follows:

(A) Conservation of energy:

Your Company carries out its operations in an environmental friendlymanner and is on the look-out for different ways & means to reduce the consumption ofenergy in its operations. Fuel & electricity consumption in different stages weremonitored regularly and suitable corrective actions were taken wherever possible.

(B) Technology Absorption:

The Company continues to use the latest technologies for improving theproductivity and quality of its services and products. The Company's operations do notrequire significant import of technology.

(C) Foreign exchange earnings and Outgo:

During the financial year the Foreign Exchange outflow is Rs.172867355.16/- and the inflow of Foreign exchange is Rs. 255327496/- .

PARTICULARS OF EMPLOYEE

Information as required under the provisions of Rules 5(2) & 5(3)of the Companies (Appointment and Remuneration of Managerial Personnel) Rules 2014 isset out in Annexure C to the Directors' Report.

DIRECTORS' RESPONSIBILITY STATEMENT

Pursuant to the requirement under section 134(3)(C) of the CompaniesAct 2013 with respect to Directors' Responsibility Statement it is hereby confirmedthat:

• in the preparation of the annual accounts for the financial yearended 31st March 2022 the applicable accounting standards had been followed along withproper explanation relating to material departures;

• the directors had selected such accounting policies and appliedthem consistently and made judgments and estimates that are reasonable and prudent so asto give a true and fair view of the state of affairs of the company as at March 31 2022and of the profit and loss of the company for that period.

• the directors had taken proper and sufficient care for themaintenance of adequate accounting records in accordance with the provisions of theCompanies Act 2013 for safeguarding the assets of the company and for preventing anddetecting fraud and other irregularities;

• the directors had prepared the annual accounts on a goingconcern basis;

• the directors have laid down internal financial controls to befollowed by the Company and such internal financial controls are adequate and wereoperating effectively; and

• the directors had devised proper systems to ensure compliancewith the provisions of all applicable laws and that such systems were adequate andoperating effectively.

RISK MANAGEMENT COMMITTEE: OVERVIEW

In terms of SEBI (LODR) Regulation 2015 the Company has constituted aRisk Management Committee on 13 November 2014 for framing implementing and monitoringthe risk management policy of the Company.

The Committee has adopted a Charter that outlines the roleresponsibilities and power of the Committee and the procedure for organizing the meetingof the Committee. Further Risk Management Plans and Policies of the Company stimulatesthe development review and revision of the organization's practices and protocols inlight of identified risks and chosen loss prevention and reduction strategies. Principlesof the Plan provide the foundation for developing key policies and procedures forday-to-day risk management activities.

VIGIL MECHANISM/ WHISTLE BLOWER POLICY

In accordance with the section 177(9) of the Act read with Regulation22 of the SEBI (Listing Obligations and Disclosure Requirements) Regulation 2015 Companyhas formulated a Vigil Mechanism / Whistle Blower Policy for its Directors and employeesto report concerns about unethical behaviour actual or suspected fraud or violation ofthe Company's fundamental code of conduct. The details of the same are made available onthe Company's website www.sindhutrade.com.

BOARD EVALUATION

The board of directors has carried out an annual evaluation of its ownperformance Board committees and Individual directors pursuant to the provisions of theCompanies Act 2013 and the corporate governance requirements as prescribed under SEBI(Listing Obligations and Disclosure Requirements) Regulation 2015 which has been set outin the Corporate Governance Report.

COMPANYS' POLICY ON DIRECTORS' APPOINTMENT AND REMUNERATION INCLUDINGCRITERIA FOR DETERMINING QUALIFICATIONS POSITIVE ATTRIBUTES INDEPENDENCE OF A DIRECTORAND OTHER MATTERS PROVIDED UNDER SUB-SECTION (3)OF SECTION178

A brief report on the criteria of selection of Executive andNon-executive Directors / Chairman CEO Senior Management employees their Remunerationpolicy including criteria for determining qualifications positive attributesindependence of director and other matters provided under sub-section (3) of section 178has been set out separately in Corporate Governance Report.

PARTICULARS OF LOANS GUARANTEE OR INVESTMENTS UNDER SECTION 186

Particulars of loans guarantees given and investments made during theyear in accordance with Section 186 of the Companies Act 2013 is annexed to this reportas "Annexure D".

RELATED PARTY TRANSACTION

All related party transactions entered during the year were on arm'slength basis and in the ordinary course of business. Prior omnibus approval was taken atthe audit committee for the transactions which are foreseen and/or repetitive in nature.The policy on the related party transactions duly approved by the Board is uploaded oncompany's website and can be accessed at www.sindhutrade.com.

During the year under review all the transactions with the relatedparty Particulars of the contracts or arrangements with related parties referred to insub-section (1) of section 188 read with Rules as applicable is annexed herewith as"Annexure E".

EXTRACT OF ANNUAL RETURN

The extract of Annual Return (MGT - 9) has been uploaded at the websiteof the Company i.e. www.sindhutrade.com

FAMILARIZATION PROGRAMME FOR INDEPENDENT DIRECTORS

The Company keeps its Directors informed of the activities of theCompany its management and operations and provides an overall industry perspective aswell as issues being faced by the industry. The details of various familiarizationprogrammes provided to the Independent Directors of the Company is available on theCompany's website www.sindhutrade.com.

INTERNAL CONTROL SYSTEMS AND THIR ADEQUACY

The Company has an Internal Control System which ensures that alltransactions are authorised recorded and reported correctly and assets are safeguardedand protected against loss from unauthorized use or disposition. In addition there areoperational controls and fraud risk controls covering the entire spectrum of internalfinancial controls. The Internal Audit is being done by the independent CharteredAccountants who monitors and evaluates the efficacy and adequacy of internal controlsystem in the Company its compliance with operating systems accounting procedures andpolicies at all locations of the Company and its subsidiaries. All these measuresfacilitate timely detection of any irregularities and early remedial steps.

No significant audit observations and recommendations have beenreceived from the Internal Auditors of the Company.

PREVENTION OF SEXUAL HARASSMENT OF WOMEN AT WORKPLACE

The company has formulated and adopted a Sexual harassment policy inline with the provisions of the Sexual Harassment of Women at Workplace (PreventionProhibition and Redressal) Act 2013 and the Rules thereunder to redress and prevent allthe complaints of sexual harassment at workplace. An Internal Complaints Committee hasbeen set up to redress complaints received regarding sexual harassment. All femaleemployees (permanent contractual temporary trainees) as well as any woman visiting theCompany's office premises or women service providers are covered under this policy.

During the year 2021-22 no complaints were received by the Companyrelated to sexual harassment.

INSIDER TRADING REGULATIONS

The Company has adopted a Code of Conduct for Prevention of InsiderTrading with a view to regulate the trading in securities by the Directors and designatedemployees of the Company. The purpose of the Code is to prevent the misuse of any pricesensitive information through dealing in the shares of the company by directors officersand employees of the company. Further the company has adopted the trading window closurepolicy to prevent the directors officers and employees of the company from trading inthe securities when there is unpublished price sensitive information.

All Board Directors and the designated employees have confirmedcompliance with the Code

CORPORATE GOVERNANCE REPORT

The company firmly believes in the principles of the good CorporateGovernance A detailed report on corporate governance in accordance with the ListingAgreement separately forms part of this annual report.

MANAGEMENT DISCUSSION AND ANALYSIS STATEMENT

The Management Discussion and Analysis Statement as required underRegulation 34 of the SEBI (Listing Obligations and Disclosure Requirements) Regulation2015 is disclosed separately in this annual report.

LISTING OF SHARES

The Equity Shares of the Company is listed on Bombay Stock Exchange.These shares were traded during the year under review at the Exchange. The Status ofListing of shares at these Stock Exchanges is given in the Corporate Governance Report.

ACKNOWLEDGEMENTS

Your Directors place on record their deep appreciation to theshareholders business associates and financial institutions at all levels for theirconsistent support and encouragement of the Company. The enthusiasm and beneficent effortsof the employees have enabled the Company to remain at the leading- edge of the Industry.Your Directors would also like to acknowledge the constructive suggestions from thestatutory auditors for ensuring the accurate and authentic compliances for the Company.

By Order of the Board of Directors
For Sindhu Trade Links Limited
Sd/- Sd/-
Place: New Delhi (Satya Pal Sindhu) (Rudra Sen Sindhu)
Dated: 29.08.2022 Managing Director Director
Din no.-00218355 Din No.-00006999

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