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Vardhman Acrylics Ltd.

BSE: 531106 Sector: Industrials
NSE: VARDHACRLC ISIN Code: INE116G01013
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Vardhman Acrylics Ltd. (VARDHACRLC) - Director Report

Company director report

Dear Members

The Directors of your Company have pleasure in presenting their 31st AnnualReport of the business and operations of the Company along with the Audited FinancialStatements for the year ended 31st March 2021.

1. FINANCIAL RESULTS:

The financial performance of your Company for the ended 31st March 2021 isas under:

PARTICULARS 2020-21 2019-20
Revenue from operations (Net) 28018.82 33436.87
Other Income 1537.10 2660.74
Profit before Depreciation 6305.34 5338.36
Interest & Tax (PBDIT)
Interest and Financial expenses 53.02 29.67
Profit before Depreciation and 6252.32 5308.69
Tax (PBDT)
Depreciation 541.53 523.09
Profit before Tax (PBT) 5710.79 4785.60
Provision for Tax - Current 1450.59 1062.89
- Deferred Tax (Net of (31.46) (903.79)
Adjustment)
- Total tax expenses 1419.13 159.10
Profit after tax (PAT) 4291.66 4626.50
Other Comprehensive Income 2.84 (27.49)
Total Comprehensive Income for 4294.50 4599.02
the period
Earnings per share (H)
- Basic 5.34 5.76
- Diluted 5.34 5.76

2. MANAGEMENT DISCUSSIONS ANALYSIS REPORT:

Management Discussion and Analysis Report for the year under review as stipulated underRegulation 34(2) (e) of the SEBI (Listing Obligations and Disclosure Requirements)Regulations 2015 is presented as under:

A. ACRYLIC FIBER INDUSTRY-GLOBAL AND INDIAN

PERSPECTIVE:

World has been severely impacted by Covid 19 pandemic and its subsequent effects.Consumption logistics and manufacturing in 2020 have been worse than the forecasts orexpectations. Uncertainty prevails in world even now because of second wave of Covid 19mutation of virus into variants and vaccination drive still to catch-up in many countries.Big hope is hinging upon continuous research to develop vaccines for new variants. Chinaclaimed controlling Covid 19 in first half of 2020 itself and has seen rapid recoverysince then. Recovery in rest of the world has been tardy and asymmetric amongst differentregions and countries.

Crude oil took a big beating in 2020. Brent dropped to $9 per barrel and WTI dippedinto negative territory reflecting too much surplus and storage issues at one point. Sincethen on back of demand recovery and production controls by OPEC+ Crude oil has not onlyregained the lost ground but is moving towards the higher levels seen in 2014.

GDP growth rate of World USA China and India in year 2020 was lower as compared toyear 2019 at -3.3% -3.5% 2.27% and -7% respectively. Textile industry has been amongstthose worst affected world over due to lockdowns in 2020.

Globally Acrylic Fiber consumption is estimated to be lower by approximately 20% in2020 over 2019. Global capacity utilization has fallen to below 50% first time in severaldecades.

Acrylonitrile which is the primary raw material for Acrylic Fiber is a crude oilderivative. Volatility in crude level impacted Acrylonitrile prices causing steep declineand then rapid recovery. Acrylonitrile rates dropped from $1275 per MT in April 2020 toabout $ 800 per MT in August 2020 and then rose to

AND $ 2750 per MT by March 2021. Further asymmetric recovery between variousstages of crude oil chain coupled with plant operation issues of Propylene the rawmaterial for Acrylonitrile led to shortages and steep price rise in second half of 2020 ofAcrylonitrile thereby impacting demand for Acrylic Fiber.

Locally in India Acrylic Fiber consumption was adversely affected in earlier part ofthe FY21 but recovered in later part of the year as pandemic seems to have been controlledbefore the second wave hit the country. Consumption during the year in India remained byand large in line with previous years unlike global consumption. However adverse impactof global slowdown and high imports were clearly visible. Capacity utilization of domesticAcrylic Fiber industry was lower than previous years. Non imposition of Anti-Dumping Dutyon Acrylic Fiber imports from few countries despite recommendation by DGTR has putdomestic Acrylic Fiber producers at a disadvantage once again vis--vis exporters andthreat of dumping has become stronger and larger than in past. Such imports had an adverseimpact on both sales volume and margins of your Company as well as overall domesticAcrylic Fiber producing industry. Domestic Acrylic Fiber industry has now escalated thematter legally as per the provisions of law.

B. FINANCIAL ANALYSIS AND REVIEW OF OPERATIONS:

PRODUCTION & SALES REVIEW:

Your Company has achieved a turnover of H 28018.82 lakhs against a turnover ofH 33436.87 lakhs in the previous year. After providing for depreciation of H 541.53lakhs

(previous year H 523.09 lakhs) and provision for current tax of H 1450.59 lakhs(previous year H 1062.89 lakhs) deferred tax of H (31.46) lakhs [previous year H(903.79) lakhs] Profit after Tax after considering Other Comprehensive Income of theCompany is H 4294.50 lakhs as against H 4599.02 lakhs in the previous year.

• RESOURCE UTILIZATION: (a) Fixed Assets:

The gross fixed assets (including work in-progress) as at March 31 2021 were H7684.82 lakhs as compared to H 8808.95 lakhs in the previous year.

(b) Current Assets:

The current assets as on March 31 2021 were H 37247.24 lakhs as against H 30589.85lakhs in the previous year. Inventory level was at H 6419.92 lakhs as against H 6047.02lakhs in the previous year.

FINANCIAL CONDITIONS & LIQUIDITY:

Liquidity & Capital Resources:

PARTICULARS 2020-21 2019-20
Cash & cash equivalents:
Beginning of the year 6279.64 176.70
End of the year 1857.47 6279.64
Net cash provided/
(used) by:
Operating Activities 3945.71 416.74
Investing Activities (8257.51) 8047.29
Financial Activities (110.37) (2361.09)

C. BUSINESS OUTLOOK

It is estimated that the year 2021-22 will witness growth of more than 10% after theGovt. has succeeded in controlling the second wave of Covid 19. Stable crude oil pricesforecast of a normal monsoon are positive for Acrylic Fiber consumption in India.

Global Acrylic Fiber demand is also likely to see a revival in 2021 after anexceptionally bad 2020. However it might still fall short of 2019 level of globalconsumption. Acrylic Fiber capacities in major producing countries outside India have beenrunning at lower operating rates even in 2021. Some of them are already in financialdifficulty. We expect intensified exports to India at less than market price especiallyby those dependent upon exports in FY22. With no Anti-Dumping duty in force Indianproducers have been denied a level playing field and this is likely to have an adverseimpact on margins of domestic Acrylic Fiber industry as also your Company.

D. MAJOR RISK AND AREA OF CONCERN

Uncertainty over control of Covid-19 adversely affecting consumption and dumping ofAcrylic Fiber by overseas producers are major risks in near future besides spikes and highvolatility in crude oil prices. Vaccination is a big hope and government seems to be fullyfocused on it. We are sanguine in our hopes that our country's economy will scale majorsurge upwards as our Hon'ble Prime Minister has launched an ambitious & timely drivefor accelerating exports and textile will get its due share of emphasis in the policyframework of the Govt. designed to achieve the target of USD one trillion exports by 2028.

E. INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY:

Your Company has adopted a strong and well-designed Internal Audit to review allsystems processes and controls of the Company. The Company reviews its Systems andProcesses periodically to assess their robustness and sufficiency in view of businessrequirements best industry practices corporate governance statutory compliancescontrols and audit purpose. This is supplemented by Self Audits done periodically and abi-annual Internal Audit to identify areas that might need further review and attention ofSenior Management. Recommendations of Internal and Statutory Auditors are viewed as anopportunity to look at our system from an independent view. Senior management of yourCompany is committed to make the operations system driven so as to minimise chances ofdeviations and taking timely corrective actions.

F. INTERNAL FINANCIAL CONTROL:

Your Company is committed to ensure not only compliances to all statutory requirementsbut also have requisite internal control aligned with best and sound industry practices.Compliance to statutory requirements is monitored on monthly basis. The monitoring systemand softwares are regularly updated to keep them in sync with current statutoryprovisions. External consultants of repute are also engaged towards this end. Noreportable material weakness in the design or operation was observed during the year.

G. MATERIAL DEVELOPMENTS IN HUMAN

RESOURCES/INDUSTRIAL RELATIONS:

Manufacturing process involves use of many hazardous chemicals. Therefore health andsafety of everyone working inside your factory always receives utmost importance whileframing Company policies and procedures. Acrylic fiber being a product with expectationsof well-defined performance

Company devotes time and resources to develop and nurture in-house talent. Your Companypromotes development of human resources by encouraging team Members to share innovativeideas without hesitation involving them in process improvement projects and rewardingthem for their contribution. Your Company has been continuously endeavoring onstrengthening culture of team work and commitment to excellence. The Company employed onan average 315 persons during the year.

H. Summary of Key Financial Ratios:

Particulars 2020-21 2019-20 % change
Debtors Turnover Ratio 20 10 100
(Days)
Inventory Turnover (Days) 84 66 27.27
Interest Coverage Ratio 92 175 -47.43
(Times)
Current Ratio (Times) 4.90 3.57 37.25
Debt Equity Ratio (Times) 0.00 0.00 0.00
EBIDTA Margin (%) 22.50 15.97 40.89
Net Profit Margin (%) 15.32 13.84 10.69
Return on Net Worth (%) 10.77 13.02 -17.28

The Financial ratios for the FY 2020-21 are not comparable with that of FY 2019-20 asthe business of the Company remained affected due to pandemic.

3. DIVIDEND:

The Board of Directors of your Company has not recommended any dividend for thefinancial year 2020-21.

4. CONSOLIDATED FINANCIAL STATEMENT:

As your Company does not have any subsidiary associate or joint venture Companytherefore the provisions of Companies Act 2013 & Indian Accounting Standards (IndAS) 110 111 112 in relation to consolidation of accounts do not apply.

5. SUBSIDIARIES JOINT VENTURES AND ASSOCIATE COMPANIES:

The Company does not have any subsidiary/ material subsidiary associate or jointventure Company.

6. DIRECTORS:

Liable to retire by rotation: In accordance with the provisions of the Articlesof Association of the Company Mr. Sachit Jain Director of the Company retires byrotation at the conclusion of the forthcoming Annual General Meeting and being eligibleoffers himself for reappointment. The Board recommended his appointment for theconsideration of the Members of the Company at the ensuing Annual General Meeting.

Cessation from Directorship: Mr. D.L. Sharma left for his heavenly abode on 10thSeptember 2020 after being infected from COVID-19.

Additional Director: During the year Mrs. Suchita Jain was appointed as anAdditional Director of the Company by the Board of Directors in its meeting held on 20thOctober 2020. Her appointment is to be approved by the Members in ensuing Annual GeneralMeeting.

Declaration by Independent Directors:

The Independent Directors have submitted their disclosures to the Board that theyfulfil all the requirements as stipulated in Section 149(6) of the Companies Act 2013 soas to qualify themselves to be appointed as Independent Directors under the provisions ofthe Companies Act 2013 and the relevant rules thereof.

Your Board confirms that in its opinion the Independent

Directors possess the requisite integrity experience expertise proficiency andqualifications. All the

Independent Directors on the Board of the Company are registered with the IndianInstitute of Corporate

Affairs Manesar Gurgaon (IICA) as notified by the Central

Government under Section 150(1) of the Companies Act

2013 and shall undergo online proficiency self-assessment test if applicable withinthe time prescribed by the IICA.

Company's Policy relating to Directors' appointment payment of remuneration anddischarge of their duties:

The Nomination & Remuneration Committee of the Company has formulated theNomination & Remuneration Policy on Director's appointment and remuneration whichincludes the criteria for determining qualifications positive attributes independence ofa director and other matters as provided under Section 178(3) of the Companies Act 2013.

The Nomination & Remuneration Policy is annexed hereto and form part of this reportas Annexure I.

Familiarization Programmes for Board Members:

Your Company has formulated Familiarization Programme for all the Board Members inaccordance with Regulation 25 of the SEBI (Listing Obligations and DisclosureRequirements) Regulations 2015 and the Schedule IV of the Companies Act 2013 whichprovides that the Company shall familiarize the Independent Directors with the Companytheir roles rights responsibilities in the Company nature of Industry in which theCompany operates business model of the Company etc. through various programs.

The Familiarization Programme for Board Members may be accessed on the Company'swebsite at the link: https://www.vardhman.com/user_files/investor/VAL_Familisation%20program.pdf

Annual Evaluation of the Board Performance:

The Meeting of Independent Directors of the Company for the Financial Year 2020-21 washeld on 20th March 2021 to evaluate the performance of the Non-IndependentDirectors Chairman of the Company and the Board as a whole.

The evaluation was done by way of discussions on the performance of the Non-Independent Directors Chairman and Board as a whole.

A policy on the performance evaluation of Independent Directors Board Committees andother individual Directors which includes criteria for performance evaluation ofnon-executive directors and executive directors has been formulated by the Company.

7. KEY MANAGERIAL PERSONNEL (KMP):

In compliance with provisions of Section 203 of the Companies Act 2013 following arethe KMPs of the Company as on 31st March 2021:

S. No. Name Designation
1. Bal Krishan Choudhary Managing Director
2. Vivek Gupta Chief Financial Officer
3. Satin Katyal Company Secretary

8. NUMBER OF BOARD MEETINGS:

During the year under review the Board met four (4) times and the intervening gapbetween any two meetings was within the period prescribed under the Companies Act 2013.The details of Board Meetings are set out in Corporate Governance Report which forms partof this Annual Report.

9. A UDITORS AND AUDITORS' REPORT:

S tatutory Auditors:

M/s. SCV & CO. LLP. (Formerly S.C. Vasudeva & Co.)

Chartered Accountants (Registration no. 000235N/

N500089) were appointed as Statutory Auditors of the

Company by the Members for a term of five consecutive years starting from theconclusion of 27th Annual General Meeting till the conclusion of 32ndAnnual General Meeting of the Company.

Further the Statutory Auditors of the Company have submitted Auditors' Report on theaccounts of the Company for the accounting year ended 31st March 2021.

This Auditors' Report is self-explanatory and requires no comments.

Secretarial Auditor:

M/s Ashok K. Singla & Associates Company Secretaries were appointed asSecretarial Auditors of the Company by the Board of Directors of the Company in itsmeeting held on 19th June 2020 for the Financial Year 2020-21.

The Secretarial Auditors of the Company have submitted their Report in Form No. MR-3 asrequired under Section 204 of the Companies Act 2013 for the Financial Year ended 31stMarch 2021. This Report is self-explanatory and requires no comments. The Report formspart of Directors' Report as Annexure II.

Cost Auditor:

The Company is maintaining the Cost Records as specified by the Central Governmentunder section

148(1) of the Companies Act 2013.

The Board of Directors has appointed Mr. R.A. Mehta Practising Cost Accountant as theCost Auditor of the Company to conduct Cost Audit of the Accounts for the financial year2021-22. However as per provisions of Section 148 of the Companies Act 2013 read withCompanies (Cost Records and Audit) Rules 2014 the remuneration to be paid to the CostAuditor is subject to ratification by Members at the Annual General Meeting.

Accordingly the remuneration to be paid to Mr. R.A.

Mehta Practising Cost Accountant for financial year 2021-22 is placed forratification by the Members.

10. A UDIT COMMITTEE:

Composition of Audit Committee:

The Audit Committee consists of three directors i.e.

Mr. Sanjit Paul Singh Mr. Munish Chandra Gupta and Mrs. Apinder SodhiIndependent Directors. Mr. Sanjit Paul Singh is the Chairman of the Committee and CompanySecretary of the Company is the Secretary of the Committee. All the recommendations madeby the Audit Committee were accepted by the Board.

11. VIGIL MECHANISM & SEXUAL HARASSMENT OF WOMEN AT WORKPLACE:

Vigil Mechanism:

Pursuant to the provisions of Section 177(9) of the Companies Act 2013 the Companyhas established a "Vigil Mechanism" incorporating Whistle Blower Policy in termsof the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 foremployees and Directors of the Company for expressing the genuine concerns of unethicalbehavior actual or suspected fraud or violation of the codes of conduct by way of directaccess to the Chairman/ Chairman of the Audit Committee.

The Company has also provided adequate safeguards against victimization of employeesand Directors who express their concerns.

The Policy on Vigil Mechanism and Whistle Blower

Policy as approved by the Board may be accessed on the Company's website at the link:

https://www.vardhman.com/user_files/investor/7_VAL_

Vigil%20Policy_updated.pdf

Se xual Harassment of Women at Workplace (Prevention Prohibition and Redressal) Act2013:

The Company has complied with the provisions relating to the constitution of InternalComplaints Committee under the Sexual Harassment of Women at Workplace (PreventionProhibition and Redressal) Act 2013.

Your Directors further state that during the year under review there were nocomplaints filed pursuant to the

Sexual Harassment of Women at Workplace (Prevention Prohibition and Redressal) Act2013.

12. CORPORATE GOVERNANCE:

The Company has in place a system of Corporate Governance. Corporate Governance isabout maximizing shareholder value legally ethically and sustainably. A separate reporton Corporate Governance forming part of the Annual Report of the Company is annexedhereto.

A certificate from the Practising Company Secretary regarding compliance of conditionsof Corporate Governance as stipulated under Corporate Governance

Clauses of the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015is annexed to the report on Corporate Governance.

13. CORPORATE SOCIAL RESPONSIBILITY (CSR):

Vision & core areas of CSR: Your Company is committed to and fully aware ofits Corporate Social Responsibility (CSR) the guidelines in respect of which were moreclearly laid down in the Companies Act 2013. The Company's vision on CSR is that theCompany being a responsible Corporate Citizen would continue to make a serious endeavorfor a quality value addition and constructive contribution in building a healthy andbetter society through its CSR related initiatives and focus on education environmenthealth care and other social causes.

CSR Policy: The Corporate Social Responsibility (CSR) Policy of the Companyindicating the activities to be undertaken by the Company as approved by the Board maybe accessed on the Company's website at the link:

h t t p s : / / w w w . v a r d h m a n . c o m / u s e r _ f i l e s /investor/61a990114df67d8501b530691cbe89070be5 39571436265843.pdf

During the year the Company has spent H 118.30 lakhs on

CSR activities.

The disclosures related to CSR activities pursuant to Section 134(3) of the CompaniesAct 2013 read with Rule 9 of Companies (Accounts) Rules 2014 and Companies (CorporateSocial Responsibility) Rules 2014 are annexed hereto and form part of this report as AnnexureIII.

14. RISK MANAGEMENT:

The risk management policy required to be formulated under the Companies Act 2013 andSEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 has been dulyformulated and approved by the Board of Directors of the Company. The aim of riskmanagement policy is to maximize opportunities in all activities and to minimizeadversity. The policy includes identifying types of risks and its assessment riskhandling monitoring and reporting which in the opinion of the Board may threaten theexistence of the Company.

The Risk Management policy may be accessed on the Company's website at the link:

h t t p s : / / w w w . v a r d h m a n . c o m / u s e r _ f i l e s /investor/8c586426f23ba3ac0445c849743b72c67c19 d6fd1436265890.pdf

15. BUSINESS RESPONSIBILTY REPORT (BRR):

SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 mandate theinclusion of the BRR as part of the Annual Report for top 1000 listed entities based onmarket capitalization. In compliance with the Listing Regulations we have integrated BRRdisclosure into our Annual Report.

16. INTERNAL FINANCIAL CONTROLS & ITS ADEQUACY:

The Company has in place adequate internal financial controls with reference tofinancial statements. During the year such controls were tested and no reportablematerial weakness in the design or operation was observed.

A report on the Internal Financial Controls under clause (i) of sub-section 3 ofsection 143 of the Companies Act 2013 as given by the Statutory Auditors of the Companyforms part of Independent Auditor's Report on Financial Statements as Annexure B.

17. P ARTICULARS OF CONTRACTS OR

ARRANGEMENTS MADE WITH RELATED PARTIES:

All contracts/arrangements/transactions entered by the Company during the financialyear with related parties were in the ordinary course of business and on an arm's lengthbasis. The particulars of Contracts or Arrangements made with related parties as requiredunder Section 134(3) (h) of the Companies Act 2013 in specified form AOC-2 forms part ofDirectors' report as

Annexure IV.

The Policy on dealing with related party transactions as approved by the Board may beaccessed on the Company's website at the link:

https://www.vardhman.com/user_files/investor/VAL_ RPT%20Policy.pdf

18. PARTICULARS OF LOANS GUARANTEES OR INVESTMENTS MADE UNDER SECTION 186 OF THECOMPANIES ACT 2013:

Particulars of loans given investments made guarantees given and securities providedalong with the purpose for which the loan or guarantee or security is proposed to beutilized by the recipient are provided in the financial statement (Please refer to Note 45 9 and 12 to the financial statement).

19. CONSERVATION OF ENERGY TECHNOLOGY ABSORPTION FOREIGN EXCHANGE

EARNINGS AND OUTGO:

Energy conservation continues to be an area of major emphasis in our Company. Effortsare made to optimize the energy cost while carrying out the manufacturing operations.Particulars with respect to conservation of energy and other areas as per Section134(3)(m) of the Companies Act 2013 read with the Companies (Accounts) Rules 2014 areannexed hereto and forms part of this report as Annexure V.

20. ANNUAL RETURN:

Pursuant to the provisions of Section 134 (3) (a) of the Companies Act 2013 the webaddress of the Annual Return of the Company is https://www.vardhman.com/user_files/investor/VAL_MGT9_2020-21.pdf

21. HUMAN RESOURCES /INDUSTRIAL RELATIONS:

Human resource is considered as the most valuable of all resources available to theCompany. The Company continues to lay emphasis on building and sustaining an excellentorganization climate based on human performance. The Management has been continuouslyendeavoring to build high performance culture on one hand and amiable work environment onthe other hand. During the year the Company employed around 315 employees on permanentrolls.

Pursuit of proactive policies for industrial relations has resulted in a peaceful andharmonious situation on the shop floors of the plant.

22. P ARTICULARS OF EMPLOYEES

RELATED DISCLOSURES:

The disclosures in respect of managerial remuneration as required under section 197(12)read with Rule 5(1) of the

Companies (Appointment & Remuneration of Managerial Personnel) Rules 2014 areannexed hereto and forms part of this report.

A statement showing the names and other particulars of the employees drawingremuneration in excess of the limits set out in Rule 5 (2) and 5 (3) of Companies(Appointment & Remuneration of Managerial Personnel) Rules 2014 is annexed heretoand forms part of this report.

In terms of section 197(14) of the Companies Act 2013 the details regardingremuneration or commission received from any holding or subsidiary Company by any Managingor Whole Time Director are annexed hereto and form part of this report.

All the above details are provided in Annexure VI.

23. MA TERIAL CHANGES AND COMMITMENT IF

ANY AFFECTING THE FINANCIAL POSITION OF THE COMPANY OCCURRED BETWEEN THE END OF THEFINANCIAL YEAR TO WHICH THE FINANCIAL STATEMENTS RELATE AND THE DATE OF THE REPORT:

No material changes and commitments affecting the financial position of the Companyoccurred between the end of the financial year to which these financial statements relateand the date of this report.

24. DIRE CTORS RESPONSIBILITY STATEMENT:

Pursuant to provisions of Section 134 (5) of the Companies Act 2013 the Board herebysubmits its responsibility Statement:

a. In the preparation of the annual accounts the applicable Accounting Standards havebeen followed along with the proper explanation relating to material departures;

b. Appropriate accounting policies have been selected and applied consistently andhave 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 as at 31st March 2021 and ofthe profit of the Company for the year ended on 31st March 2021;

AND c. 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 other irregularities;

d. The annual accounts have been prepared on a going concern basis;

e. The Internal financial controls have been laid down to be followed by the Companyand that such internal financial controls are adequate and are operating effectively; and

f. Proper systems have been devised to ensure compliance with the provisions of allapplicable laws and such systems are adequate and operating effectively.

25. GENERAL DISCLOSURES:

Y our Directors state that no disclosure or reporting required in respect of thefollowing items as there were no transactions on these items during the year under review:

1. Details relating to deposits covered under Chapter V of the Act.

2. Issue of equity shares with differential rights as to dividend voting or otherwise.

3. Significant or material orders passed by the

Regulators or Courts or Tribunals which impact the going concern status and Company'soperations in future.

4. Transfer of unclaimed/unpaid Dividend to Investor Education and Protection Fund.

5. Change in nature of Business of Company.

6. No fraud has been reported by the Auditors to the Audit Committee or the Board.

7. There is no Corporate Insolvency Resolution process initiated under the Insolvencyand Bankruptcy Code 2016.

26. ACKNOWLEDGEMENT:

Y our Directors are pleased to place on record their sincere gratitude to theGovernment Bankers Business Constituents and Shareholders for their continued andvaluable co-operation and support to the Company and is look forward to their continuedsupport and co-operation in future too.

They also take this opportunity to express their deep appreciation for the devoted andsincere services rendered by the employees at all levels of the operations of the Companyduring the year.

FOR AND ON BEHALF OF THE BOARD
Sd/-
Place: Ludhiana (S.P. Oswal)
Dated: 8th May 2021 Chairman

.