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Suraj Industries Ltd.

BSE: 526211 Sector: Industrials
NSE: N.A. ISIN Code: INE170U01011
BSE 00:00 | 17 Aug 93.80 -3.65
(-3.75%)
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NSE 05:30 | 01 Jan Suraj Industries Ltd
OPEN 97.95
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VOLUME 704
52-Week high 180.60
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P/E 24.24
Mkt Cap.(Rs cr) 105
Buy Price 0.00
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Sell Price 0.00
Sell Qty 0.00
OPEN 97.95
CLOSE 97.45
VOLUME 704
52-Week high 180.60
52-Week low 2.46
P/E 24.24
Mkt Cap.(Rs cr) 105
Buy Price 0.00
Buy Qty 0.00
Sell Price 0.00
Sell Qty 0.00

Suraj Industries Ltd. (SURAJINDUSTRIES) - Director Report

Company director report

To

The Members

Suraj Industries Ltd

Your Directors hereby present the 29th Annual Report along with the AuditedStatement of Accounts for the Financial Year ended March 31 2021.

FINANCIAL PERFORMANCE OF THE COMPANY

The financial performance of the Company for the year under review and comparativefigures for the previous year are summarized below:

(in Rs.)

2020-2021 2019-2020
Total Income 70433703 13193840
Total Expenses 69801687 17833451
Profit/(Loss) before Extra-ordinary Items and Exceptional Items 632016 (4639611)
Profit/(Loss) before tax 632016 (4639611)
Tax Expenses
Current Tax -- --
Deferred Tax 3080337 --
Profit/(Loss) for the period 3712353 (4639611)
Other Comprehensive Income: Items that will not be reclassified to profit or loss Re-measurement of defined benefits plans (14364)
Total Comprehensive Income for the period 3697989 (4639611)

PERFORMANCE OF BUSINESS

During the financial year 2020-2021 the Company has made a profit of Rs. 3712353/-(Thirty Seven Lakh Twelve Thousand Three Hundred Fifty Three Only)as compared a loss ofRs. 4639611/- (Rupees Forty Six Lakh Thirty Nine Thousand Six Hundred Eleven Only) inthe previous financial year.

STATE OF COMPANY'S AFFAIRS AND FUTURE OUTLOOK

During the year under review the company scaled up its trading operations by venturinginto trading of edible oils in addition to Empty glass bottles and other products.

Further the Company has entered into an Agreement with Rajasthan State GanganagarSugar Mills Ltd. (RSGSM) for:

i. Bottling and packaging of alcoholic beverages (i.e. country liquor Rajasthan madeliquor and Indian made foreign liquor for RSGSM or third party at Ajmer Rajasthan;

ii. Bottling and packaging of alcoholic beverages (i.e. country liquor Rajasthan madeliquor and Indian made foreign liquor for RSGSM or third party at Dungarpur Rajasthan.

In June 2021 the Company acquired a bottling unit situated on the premises of RajasthanState Ganganagar Sugar Mills Ltd (RSGSM) at Ajmer Rajasthan-305001 for bottling andpackaging of alcoholic beverages for RSGSM in terms of the agreement executed with RSGSM.

The company expects to get steady returns on a long-term basis from the bottling andpackaging of alcoholic beverages.

DIVIDEND

Based on the Company's performance in the Current Year your Directors are unable torecommend any dividend for the year under review.

AMOUNT TRANSFERRED TO RESERVES

Due to inadequate profits the company has not transferred any amount to reserves.

DIRECTORS AND KEY MANAGERIAL PERSONNEL

The Board of Directors comprise of eminent and experienced professionals in theIndustry. The current composition of the Board of Directors (as on the date of Board'sReport) are as follows:

Sr. No. Name of Director Designation
1. Mr. Suraj Prakash Gupta Managing Director
2. Mr. Ashu Malik Whole Time Director
3. Mr. Alok Ranjan Non-Executive Independent Director
4. Mr. Syed Azizur Rahman Non-Executive Director
5. Mr. NazirBaig Non-Executive Independent director
6. Ms. Pooja Solanki Women Non-Executive Independent Director

None of the aforesaid Directors are disqualified under Section 164(2) of the CompaniesAct 2013. Further they are not debarred from holding the office of Director pursuant toorder of SEBI or any other authority.

Changes in the composition of the Board of Directors

The following changes occurred during FY 2020-2021 till the date of this Report:

During the year under review the Board of Directors pursuant to the applicableprovisions of the Companies Act 2013 read with the rules made thereunder (including anystatutory modification (s) or re-enactment thereof for the time being in force) SEBI(Listing Obligation & Disclosure Requirements) Regulations 2015 and on therecommendation of Nomination and Remuneration Committee accorded its approval to thefollowing:

i. Appointment of Ms. Pooja Solanki (DIN: 09039846) as an Additional Director to holdoffice up to the date of ensuing AGM and as a Women Non-Executive Independent Director fora period of 5 (five) years effective from January 23 2021 on the Board subject to theapproval of members of the Company. Considering her integrity expertise and proficiencythe Board noted that her appointment would be of benefit to the company.

ii. Appointment of Mr. Ashu Malik (DIN: 07998930) as an Additional Director of theCompany w.e.f. 27.06.2021 to hold office up to the date of ensuing AGM further he wasappointed as Whole Time Director of the Company w.e.f. 27.06.2021 for a period of One(1)year effective from 27.06.2021 subject to approval of Members of the Company;

iii. Resignation of Ms. Shuchi Bahl as Women Director of the Company w.e.f. 23.01.2021.

Pursuant to the provisions of Section 152 of the Companies Act 2013 read with theCompanies (Appointment and Qualification of Directors) Rules 2014 executive directorsand non-executive directors except the Independent Directors are subject to retire byrotation. Based on the terms of appointment and the Articles of Association of yourCompany Mr. Syed Azizur Rahman(DIN: 00242790) who is the longest serving member in thecurrent term and is liable to retire by rotation and he being eligible offer himself forreappointment. Appropriate resolution for his re-appointment is being placed for yourapproval at the ensuing Annual General Meeting.

Key Managerial Personnel

In accordance with Section 203 of the Companies Act 2013 the Company has followingKey Managerial Personnel at the end of the financial year and as on date of the BoardReport.:

Sr. No. Name of KMP Designation
1. Mr. Suraj Prakash Gupta Managing Director
2. Mr. Ashu Malik Whole Time Director
3. Mr. Sujeet Gupta Chief Financial Officer
4. Ms. Bhanumathy Ramachandran Company Secretary

DIRECTORS RESPONSIBILITY STATEMENT

In terms of Section 134 (5) of the Companies Act 2013 the directors would like tostate that:

i) In the preparation of the Annual Accounts for the financial year ended March 312021 the applicable Accounting standards have been followed and that there are nomaterial departures.

ii) The directors have selected such accounting policies and applied them consistentlyand made judgments and estimates that were reasonable and prudent so as to give a true andfair view of the state of affairs of the Company as at March 31 2021 and of the profit ofthe Company for the Financial year ended March 31 2021.

iii) The directors have taken proper and sufficient care for the maintenance ofadequate accounting records in accordance with the provisions of the Companies Act 2013for safeguarding the assets of the Company and for preventing and detecting fraud andother irregularities.

iv) That accounts for the year ended March 31 2021 have been prepared following thegoing concern basis.

v) The directors had laid down internal financial controls to be followed by thecompany and that such internal financial controls are adequate and were operatingeffectively.

vi) The directors had devised proper system to ensure compliance with the provisions ofall applicable laws and that such systems were adequate and operating effectively.

CORPORATE SOCIAL RESPONSIBILITY

The Company was not required to constitute corporate social responsibility committeepursuant to section 135 of the Companies Act 2013.

MATERIAL CHANGES AND COMMITMENTS

No material changes and commitments affecting the financial Position of your Companyhave occurred between the end of the financial year of the Company to which the financialstatements relate and upto the date of this report.

AUDIT COMMITTEE

In compliance with the provisions of Section 177 of the Companies Act 2013 andRegulation 18 of the SEBI (LODR) Regulations 2015 as on 31 March 2021 the AuditCommittee of the Company comprises of following 3 (Three) Members and two third of themembers of the Audit Committee are Independent Directors:

S. No. Name of Member Category Designation Held Attended
1. Mr. Alok Ranjan Non-Executive Independent Director Member 4 4
2. Mr. Syed Azizur Rahman Non-Executive Non Independent Director Member 4 4
3. Mr. NazirBaig Non-Executive Independent Director Member 4 4

Further as per section 177(8) of the Companies Act 2013 there was not any case duringthe period under review that any recommendation is made by the Audit Committee and theBoard has not accepted it.

STATUTORY AUDITORS & THEIR REPORT

Pursuant to the provisions of Section 139 of Companies Act 2013 and rules framedthereunder the Company in its 25th Annual General Meeting held on September 27th2017 had appointed M/s Satendra Rawat & Company Chartered Accountants (FirmRegistration Number: 008298C)as Statutory Auditors of the company for a term of fiveconsecutive years i.e. till the conclusion of Annual General Meeting of the Company to beheld in the year 2022.

The Notes on financial statement referred to in the Auditors' Report areself-explanatory and do not call for any further comments. The Auditors' Report does notcontain any qualification reservation or adverse remark. The Auditor's Report is enclosedwith the Financial Statements in this Annual Report.

During the financial year there have been no instances of fraud reported by theStatutory Auditors under Section 143(12) of Companies Act 2013 read with rules framedthereunder either to the Company or to the Central Government.

SECRETARIAL AUDITOR & THEIR REPORT

Pursuant to provisions of section 204 of the Companies Act 2013 read with Companies(Appointment and Remuneration of Managerial Personnel) Rules 2014 the company hadappointed Ms. Monika Kohli Company Secretary in Practice to undertake the SecretarialAudit of the Company for financial year 20202021.

The Secretarial Audit Report in prescribed form MR-3 for Financial Year 2020-2021 formspart of the Directors' Report as "Annexure A".

Further Secretarial Auditor had pointed out one observation to which the reply of theBoard of Directors is hereunder:

Secretarial Auditors Remark - 1

 

It is observed that the 100% promoter's holding of equity shares in the company are notin demat form which is in non-compliance of Regulation 31 of SEBI (Listing Obligation andDisclosure Requirement) Regulations 2015.

Board's Reply

The promoter's Shareholding upto the extent of 99.99 % has already been dematerializedonly 10 shares are in physical mode. The Company has made request to the concernedpromoter shareholder to dematerialize his shares at the earliest.

INTERNAL AUDITOR

Pursuant to the provisions of Section 138 of the Companies Act 2013 read with relevantapplicable rules your company was required to appoint an Internal Auditor. Further theBoard of Directors at its meeting held on September 02 2020 has appointed M/s Mohan Gupta& Co. Chartered Accountants as Internal Auditor of the Company.

ANNUAL RETURN

In accordance with the provisions of section 134(3)(a) & 92(3) of Companies Act2013 read with rules made thereunder the Annual Return will be available on the websiteof the Company once filed with the Ministry of Corporate Affairs and can be accessedthrough the link (www.surajindustries.org)..

SHARE CAPITAL

During the year the Authorised Share capital has been increased from Rs.100000000/- (Rupees Ten Crore) divided into 10000000 (One Crore) Equity Shares ofRs. 10/- (Rupees Ten) each to Rs. 150000000/- (Rupees Fifteen Crore Only) divided into15000000 (One Crore Fifty Lakh) equity shares of Rs. 10/- (Rupees Ten Only) each.

Further the Paid up Share Capital of the Company has been increased from Rs.72860000/- (Rupees Seven Crore Twenty Eight Lakh Sixty Thousand Only) divided into7286000 (Seventy Two Lakh Eighty Six Thousand) Equity Shares of Rs. 10/- (Rupees Ten)each to Rs. 86500000/- (Rupees Eight Crore Sixty Five Lakh Only) divided into 8650000(Eighty Six Lakh Fifty Thousand) Equity shares of Rs. 10/- (Rupees Ten) each.

Further During the financial year 2020-2021 the Company has issued and allotted1989000 Fully Convertible Warrants ('Warrants') at an issue price of Rs. 10/- perWarrant aggregating to Rs. 19890000/- (Rupees One Crore Ninety-Eight Lakh NinetyThousand Only) convertible into equivalent number of Equity Shares of face value Rs. 10/-each within a period of 18 months from the date of allotment on a preferential basis(‘Preferential Allotment') to the person belonging to the ‘Promoter &Promoter group' category.

INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY

The Company has in all material respects an adequate internal financial control systemover financial reporting and such internal financial controls over financial reportingwere operating effectively as at March 31 2021.

DETAILS OF SUBSIDIARIES/ JOINT VENTURE AND ASSOCIATES COMPANY

The Company has no subsidiary/ Joint Venture and Associate Company during the year.

NUMBER OF BOARD MEETINGAND ATTENDANCE BY EACH DIRECTOR

During the financial year 2020-2021 Five (5) Board Meetings were held on 29.07.202002.09.2020 13.11.2020 23.01.2021 and 04.02.2021. The intervening gap between any twomeetings did not exceed the time prescribed under Companies Act 2013 and the SEBI(Listing Obligations& Disclosure Requirements) Regulations 2015 as amended. Thedetails of composition of Board and presence of each director in the meeting is mentionedhereunder.

S. No Name of Director Designation No. of Board Meetings Held No. of Board Meetings Attended
1. Mr. Suraj Prakash Gupta Managing Director 5 5
2. Mr. Alok Ranjan Non-Executive- Independent Director 5 5
3. Mr. Syed Azizur Rahman Non-Executive Non Independent Director 5 5
4. Mrs. ShuchiBahl* Non-Executive Non Independent Director 4 2
5. Ms. Pooja Solanki** Women Non Executive - Independent Director 1 0
5. Mr. NazirBaig Non-Executive - Independent Director 5 5

*Ms. Shuchi Bahl relinquished the office of Women Director w.e.f. 23.01.2021. Duringthis period i.e. April 01 2020 to January 23 2021 Four (4) meetings of Board ofDirectors were held.

** Ms. Pooja Solanki was appointed w.e.f. January 23 2021. After her appointment asDirector One (1) meeting of Board of Directors was held.

CORPORATE GOVERNANCE DISCLOSURE

As per the provisions of Regulation 15(2) of SEBI (LODR) Regulations 2015 the listedentity having paid up equity share capital not exceeding rupees ten crore and net worthnot exceeding rupees twenty five crore as on the last day of the previous financial yearshall not be required to comply with the Corporate Governance provisions as specified inregulations 17 17A 18 19 20 21 22 23 24 24A 25 26 27 and clauses (b) to (i)and (t) of sub-regulation (2) of regulation 46 and para C D and E of Schedule V.

Hence the Company is not required to report on Corporate Governance in accordance withregulation 34(3) and schedule V(C) to the SEBI (Listing Obligations and DisclosureRequirements) Regulations 2015 and therefore the disclosure is not given in the AnnualReport.

CODE OF CONDUCT

The Board of Directors has approved a Code of Conduct which is applicable to theMembers of the Board and all Employees in the course of day to day business operations ofthe Company.

The Code lays down the standard procedure of business conduct which is expected to befollowed by the Directors and the designated Employees in their business dealings and inparticular on matters relating to integrity in the work place in business practices andin dealing with Stakeholders.

The Company has adopted a Code of Conduct for Prevention of Insider Trading with a viewto regulate trading in securities by the Directors and designated Employees of theCompany. The Code requires preclearance for dealing in the Company's Shares and prohibitsthe purchase or sale of Company Shares by the Directors and the designated Employees whilein possession 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.

The Board Members have affirmed compliance with the Code of Conduct for the year endedMarch 31 2021. The code of conduct is available on our website www. suraj industries.org.

PREVENTION OF SEXUAL HARRASSMENT OF WOMEN AT WORKPLACE

The Company is committed to provide a protective environment at workplace for all itswomen employees. To ensure that every woman employee is treated with dignity and respectand as mandated under "The Sexual Harassment of Women at Workplace (PreventionProhibition and Redressal) Act 2013" the Company has in place a formal policy forprevention of sexual harassment at work place and the Company has also constituted theInternal Complaint Committee in compliance with the requirement of the Act.

During the year under review the company has not received any complaint of sexualharassment.

DECLARATION BY INDEPENDENT DIRECTOR(S)

The Company has received necessary declaration from each independent director underSection 149(7) of the Companies Act 2013 that they meet the criteria of independence laiddown in Section 149(6) of the Companies Act 2013 and qualify to act as IndependentDirector of the Company confirming that:

• They meet the criteria of independence as prescribed under the provisions of theAct read with the Schedules and Rules issued thereunder as well as of Regulation 16 ofthe SEBI Listing Regulations.

• In terms of Rule 6(3) of the Companies (Appointment and Qualification ofDirectors) Rules 2014 they have registered themselves with the Independent Director'sdatabase maintained by the Indian Institute of Corporate Affairs Manesar.

MEETING OF INDEPENDENT DIRECTORS)

In terms of requirements under Schedule IV of the Companies Act 2013 a separatemeeting of the Independent Directors was held on January 23 2021.

The Independent Directors at the meeting reviewed the following:-

• Performance of non-independent Directors and the Board as a whole

• Assess the quality quantity and timeliness of flow of information between themanagement of the listed entity and the board of directors that is necessary for the boardof directors to effectively and reasonably perform their duties.

• Performance of the Chairperson of the Company

COMMITTEE

Pursuant to the requirement under Companies Act 2013 and the Board of Directors hasconstituted the following Committees:

1. Audit Committee;

2. Nomination & Remuneration Committee;

3. Stakeholders Relationship Committee; and

4. Independent Directors Committee.

The Composition of the Committee(s) as on March 31 2021are mentioned hereunder:

1) Audit Committee

S. No Name of Director Category Designation
1. Mr. Alok Ranjan Non-Executive Independent Director Member
2. Mr. Syed Azizur Rahman Non-Executive Non-Independent Director Member
3. Mr. Nazir Baig Non-Executive Independent Director Member

2) Nomination & Remuneration Committee

S. No Name of Director Category Designation
1. Mr. Nazir Baig Non-Executive Independent Director Member
2. Ms. Pooja Solanki Non-Executive Independent Director Member
3. Mr. Alok Ranjan Non-Executive Independent Director Member

3) Stakeholders Relationship Committee

S. No Name of Director Category Designation
1. Mr. Alok Ranjan Non-Executive Independent Director Member
2. Mr. Syed Azizur Rahman Non-Executive Non Independent Director Member
3. Mr. Nazir Baig Non-Executive Independent Director Member

4) Independent Directors Committee

S. No Name of Director Category Designation
1. Mr. Alok Ranjan Non-Executive Independent Director Member
2. Mr. Nazir Baig Non-Executive Independent Director Member
3. Ms. Pooja Solanki Non-Executive Independent Director Member

NOMINATION & REMUNERATION POLICY

The Company has framed a Nomination and Remuneration Policy pursuant to the provisionsof Section 178 of the Companies Act 2013

There is no change in the policy since the last financial year. The Policy is availableon our website http://www. suraj industries. org.

PARTICULARS OF LOAN(S). GUARANTEE! S) OR INVESTMENT (S) UNDER SECTION 186 OF THECOMPANIES ACT 2013

During the year under review the Company has neither made any investment(s) nor givenany loan(s) or guarantee(s) which is covered under the provisions of Section 186 of theCompanies Act 2013.

PARTICULARS OF CONTRACTS OR ARRANGEMENTS WITH RELATED PARTIES

During the year the Company had not entered into any contract arrangement andtransaction with related parties which could be considered material in accordance with theCompany's Policy on materiality of and dealing with related party transactions (the"Policy") and accordingly the disclosure of Related Party Transactions in FormAOC-2 is not applicable on the Company.

DEPOSITS

The Company has neither accepted nor renewed any deposits during the Financial Year2020-2021 in terms of Chapter V of the Companies Act 2013. Further the Company is nothaving any unpaid or unclaimed deposits at the end of the Financial Year.

CONSERVATION OF ENERGY TECHNOLOGY ABSORPTION FOREIGN EXCHANGE EARNINGS & OUTGO:

The Company is not engaged in any activity where conservation of energy and technologyabsorption is required. Further during the year there were no foreign exchange earningsor outgo. Hence the details required under Section 134(3) (m) of the Companies Act 2013read with rule 8(3) Companies (Accounts) Rule 2014 are not given.

RISK MANAGEMENT

The Company has in place comprehensive risk assessment and minimization procedureswhich are reviewed by the Board periodically. Board has prepared Risk Management planwhich is reviewed and monitored on regular basis to identify and review critical risks.

PERFORMANCE EVALUATION

The Companies Act 2013 read with the SEBI (Listing Obligations and DisclosureRequirements) Regulations 2015 as applicable provides that the Board needs to undertake aformal Annual Evaluation of its own performance and that of its Committees and individualDirectors. The Schedule IV of the Companies Act 2013 read with the Rules issued thereunderstates that the performance evaluation of Independent Directors shall be done by theentire Board of Directors excluding the Director being evaluated.

The Board has carried out the annual evaluation of its own performance performance ofthe Directors individually as well as the performance of the working of its AuditNomination & Remuneration and other Committees of the Board. The evaluation wascarried out taking into consideration various aspects of the Board's functioning such asadequacy of the composition of the Board and its Committees execution and performance ofspecific duties obligations and governance etc.

The Directors expressed their satisfaction with the evaluation process.

THE CHANGE IN THE NATURE OF BUSINESS IF ANY

There was no change in the nature of business during the financial year 2020-2021.

SIGNIFICANT AND MATERIAL ORDERS

There are no significant and material orders passed by the regulators or courts ortribunals impacting the going concern status and Company's operations in future.

VIGIL MECHANISM/ WHISTLE BLOWER POLICY

The Board has Vigil Mechanism/Whistle Blower Policy a mechanism for employees toreport to the management concerns about unethical behavior actual or suspected fraud orviolation of the Company's code of conduct. The mechanism also provides for adequatesafeguards against victimization of employees who avail the mechanism and also provide fordirect access to the Chairman of the Audit Committee in exceptional cases. The Policy isalso available on our website http://www.surajindustries.org.

During the year under review no personnel has been denied access to the auditcommittee. There is no change in the policy during the financial year 2020-2021.

LISTING OF SHARES

The Company's shares are listed on the below mentioned Stock Exchange: -

BSE Limited (BSE)

Phiroze Jeejeebhoy Towers

25th Floor Dalal Street

Mumbai - 400 001

DEPOSITORY SYSTEMS

Your Company has established connectivity with both depositories-National SecuritiesDepository Limited (NSDL) and Central Depository Services (India) Limited (CDSL). In viewof the numerous advantages offered by the depository system members holding Shares inphysical mode are requested to avail of the dematerialization facility with either of thedepositories.

Your Company has appointed M/s. BEETAL Financial & Services Private Limited aCategory-I SEBI registered R&T Agent as its Registrar and Share Transfer Agent acrossphysical and electronic alternative.

PARTICULARS OF MANAGERIAL REMUNERATION AND EMPLOYEES

1. Disclosure in terms of Rule 5 (1) of The Companies (Appointment and Remuneration ofManagerial Personnel) Rules 2014:-

i. The ratio of the remuneration of each director to the median remuneration of theemployee of the Company for the financial year:

Sr. No. Name of Director Category of Director Ratio to Median Remuneration
1. Mr. Suraj Prakash Gupta Executive Director 5.09:1
2. Mr. Alok Ranjan Non-Executive Director Nil
3. Mrs. Shuchi Bahl Non-Executive Director Nil
4. Mr. Nazir Baig Non-Executive Director Nil
5. Mr. Syed Azizur Rahman Non-Executive Director Nil
6. Ms. Pooja Solanki Non-Executive Director Nil

ii. The percentage increase in remuneration of each Director Chief Executive OfficerChief Financial Officer Company Secretary in the financial year:

Sr. No. Name Category % increase/ decrease in the remuneration in the financial year
1. Mrs. Bhanumathy Ramachandran Company Secretary -
2. Mr. Sujeet Gupta Chief Financial Officer -

iii. The percentage increase in remuneration in the median remuneration of employee inthe financial year: NIL

iv. The Company had only three permanent employees.

v. Average Percentile Increase already made in the Salaries of Employees other than theManagerial Personnel in the last Financial Year and its Comparison with the PercentileIncrease in the Managerial Remuneration: NA (no remuneration other than managerialremuneration was paid in the last financial year ending on 31.03.2021)

Percentage increase in the managerial remuneration for the year: NIL

vi. Affirmation that the remuneration is as per the remuneration policy of the Company:

The Company affirms remuneration is as per the remuneration policy of the Company.

2. Disclosure in terms of Rule 5 (2) of The Companies (Appointment and Remuneration ofManagerial Personnel) Rules 2014:-

There was no employee who has drawn salary as mentioned in the aforesaid rule.

MANAGEMENT DISCUSSION & ANALYSIS REPORT

In terms of the provisions of Regulations 34 and Part B of Schedule V of the Securitiesand Exchange Board of India (Listing Obligations and Disclosure Requirement) Regulations2015 the Management's discussion and analysis report has been given separately and formspart of the Directors' Report as Annexure "B".

INDUSTRIAL RELATIONS

The Industrial Relations have continued to be stable and harmonious during the courseof the year. DISCLOSURES UNDER SECRETARIAL STANDARDS

The directors state that applicable Secretarial Standards i.e SS-1 and SS-2 relatingto ‘Meeting of the board of Directors' and ‘General Meetings' respectivelyhave been duly followed by the company.

DISCLOSURE ABOUT MAINTENANCE OF COST RECORDS

As there was no manufacturing activity during the period under review thereforeCompany was not required to maintain cost records as per Section 148 of Companies Act2013.

ACKNOWLEDGEMENTS

It is our strong belief that caring for our business constituents has ensured oursuccess in the past and will do so in future. The Board acknowledges with gratitude theco-operation and assistance provided to your company by the government as well asNon-Government agencies. The Board wishes to place on record its appreciation to thecontribution made by employees of the company during the year under review. Your Directorsgives their sincere gratitude to the customers clients vendors and other businessassociates for their continued support to the Company.

Your Directors also place on record their deep sense of appreciation for the devotedservices rendered by all the employees of the company and for the continued co-operation& support received from shareholders of the Company.

Place: New Delhi

Date: 03.09.2021

By Order of the Board For Suraj Industries Ltd
Sd/- Sd/-
Suraj Prakash Gupta Ashu Malik
Managing Director Whole Time Director
DIN: 00243846 DIN: 07998930
Address: W-15/40 W-15 Address: Flat No. 1 First Floor
Western Avenue Sainik Farms Plot No.-18 Prem Homes Maya Kunj
PushpaBhawan Delhi-110062 Avantika Ghaziabad Uttar Pradesh-201002

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