Acme Universal Safezone 9 Ltd Directors Report

In accordance with our Articles of Association, unless otherwise determined in a general meeting of the Company and subject to the provisions of the Companies Act, 2013 and other applicable rules, the number of Directors of the Company shall not be less than three (3) and not more than fifteen (15). As on the date of the Draft Red Herring Prospectus our Board has (5) Directors, out of which (1) is Managing Director, (1) is Executive Director, and (1) Director is women Director and (3) are Non-Executive Independent Director.

The following table sets forth details regarding our Board of Directors as on the date of the Draft Red Herring Prospectus.:

Name, DIN, Date of Birth, Designation, Address, Occupation, Current Term, Period of Directorship and Nationality	Age	Other Directorships
Name: Nitin Tiwari	53 years	Indian Companies:
DIN: 00852402
Date of Birth: June 17, 1972		Public Company: Nil
Designation: Managing Director
Address: 2001 BLDG 3 20th FLR Raheja Classique CHS L, Link		Private Company: Nil
Road, Mumbai, Andheri, Maharastra-400053
Occupation: Business		LLP: Nil
Current Term: Re-Appointed as Managing Director for a period of
Five (5) years with effect from January 19, 2026
Period of Directorship: Director Since Incorporation
Nationality: Indian
Name: Ruchi Tiwari	46 years	Indian Companies:
DIN: 00852457
Date of Birth: September 09, 1979		Public Company: Nil
Designation: Executive Director
Address: 2001 BLDG 3 20th FLR Raheja Classique CHS L, Link		Private Company: Nil
Road, Mumbai, Andheri, Maharashtra-400053
Occupation: Business		LLP: Nil
Current Term: Liable to be Retire by Rotation.
Period of Directorship: Director since incorporation
Nationality: Indian
Name: Alok Tripathi	34 years	Indian Companies
DIN: 11212906
Date of Birth: July 07, 1991		Public Company: Nil
Designation: Non-Executive Independent Director
Address 473/4 Adarsh Nagar, Unnao, Uttar Pradesh 209801		Private Company: Nil
Occupation: Professional
Current Term: For a Period of Five (5) Consecutive Years from		LLP: Nil
August 13, 2025
Period of Directorship: Director Since August 13, 2025
Nationality: Indian
Name: Imran Mohammad	41 years	Indian Companies
DIN: 11214183
Date of Birth: June 26, 1984		Public Company: Nil
Designation: Non-Executive Independent Director
Address 105/591, Flat No. 1 and 2 Chaman Ganj, new haleem market		Private Company: Nil
kanpur, Fahimabad, Uttar Pradesh 208001
Occupation: Business		LLP: Nil
Current term: For a Period of Five (5) Consecutive Years from
August 13, 2025
Period of Directorship: Director Since August 13, 2025
Nationality: Indian
Name: Gofran Ahmad Khan	60 years	Indian Companies:
DIN: 11404914
Date of Birth: June 03, 1965		Public Company: Nil
Designation: Non-Executive Independent Director
Address: 12A-5, Defence Colony, Gaushala, Jajmau, Shiwans,		Private Company: Nil
Tenray, Kanpur Nagar, Uttar Pradesh- 208010
Occupation: Professional		LLP: Nil
Current Term: For a Period of Five (5) Consecutive Years from
January 19, 2026
Period of Directorship: Director Since January 19, 2026
Nationality: Indian

BRIEF PROFILES OF OUR DIRECTORS:

Nitin Tiwari, Managing Director

Nitin Tiwari, aged 53 years, is the Promoter and Managing Director of our Company. He holds a Bachelors degree in Engineering

(Electronics & Telecommunication) from Jiwaji University, Gwalior obtained in the year 1994. He has over 30 years of experience in the leather and safety footwear industry. He commenced his entrepreneurial journey in 1994 with the establishment of M/s ACME Fabrik Co., a partnership firm engaged in the manufacturing of safety footwear. In 2016, the firm was converted into ACME Universal Safezone 9 Private Limited (thereafter converted into a public limited company), continuing its focus on the manufacturing of safety footwear, thereby marking his long-term commitment to the industry.

Nitin Tiwari was conferred with the Emerging Entrepreneur - Make in India Award presented by Smt. Nirmala Sitharaman (then Honble Minister of Commerce and Industry) in the year 2016. He has also been featured in The Dollar Business magazine (2017) for excellence in exports and innovation, and in Mint newspaper (2017) for his contributions towards industrial safety and manufacturing excellence.

He is responsible for formulating and overseeing the Companys strategies and policies, supervising overall business operations with direct oversight in the production activities ensuring efficient execution across departments. He has been re-appointed serving as the Managing Director of the Company as on January 19, 2026 and has been associated with the Company since its incorporation.

Ruchi Tiwari, Executive Women Director

Ruchi Tiwari, aged 46 years, is the Promoter and Director of our Company. She has done her Higher Secondary Education. She has over 20 years of experience in manufacturing Industry (Particularly in leather and safety footwear), business administration and organizational management. She plays an important role in the Company Strategic planning, policy formation and operational oversight. She contributes towards strengthening corporate governance practices and improving operational efficiency of the Company. As a director she provides guidance on organizational development and supports the management in achieving sustainable growth and maintaining quality standards. She has been associated with the Company as director since Inception.

Alok Tripathi, Non-Executive Independent Director

Alok Tripathi, aged 34 years is the Non-Executive Independent director of the company. He holds Master degree in commerce from Chhatrapati Shahu Ji Maharaj University Kanpur obtained in the year 2012. He is also a member of the Institute of Chartered Accountants of India (ICAI). He is presently employed as Manager Finance & Taxation at Superhouse Limited, where he has gained over 7 years of professional experience in finance and taxation. He has been appointed as an Independent director on the board of the company effective from August 13, 2025.

Imran Mohammad, Non-Executive Independent Director

Imran Mohammad aged 41 years is the Non-Executive Independent director of the company. He holds Bachelor degree in commerce from Chhatrapati Shahu Ji Maharaj University Kanpur obtained in the year 2006. He also holds a certificate in European

& Western Saddle Manufacturing course awarded by International Institute of Saddlery Technology and Export Management Leather Technology Park, Banthar, Unnao. With over 15 years of entrepreneurial experience as Managing Partner of Alia Impex (Footwear Division) and has lead overall operations of business of Alia Industries (as a Proprietor), he brings valuable industry and business expertise to the Board. He has been appointed as an Independent director on the board of the company effective from August 13, 2025.

Gofran Ahmad Khan, Non-Executive Independent Director

165

Gofran Ahmad Khan, aged 60 years, is the Non-Executive Independent Director of the Company. He holds a Bachelor of Science degree from PPN Degree College, Kanpur. He has an experience of three decades in the leather manufacturing and trading industry. He is presently associated with Superior International (formerly Superior LC), Kanpur, where he leads manufacturing, sourcing, and supply operations. He has been appointed as an Independent Director on the board of the company effective from January 19, 2026.

AS ON THE DATE OF THE DRAFT RED HERRING PROSPECTUS

1. None of the above-mentioned Directors are on the RBI List of Wilful Defaulters or Fraudulent Borrowers.

2. Neither Promoters nor persons forming part of our Promoter Group, our directors or persons in control of our Company or our Company are debarred from accessing the capital market by SEBI.

3. None of the Promoters, Directors or persons in control of our Company, has been or is involved as promoters, director or person in control of any other company, which is debarred from accessing the capital market under any order or directions made by SEBI or any other regulatory authority.

4. None of our Directors are/were director of any company whose shares were delisted from any stock exchange(s) during his/her tenure.

5. None of Promoters or Directors of our Company are a fugitive economic offender.

6. None of our Directors are/were director of any company whose shares were suspended from trading by stock exchange(s) or under any order or directions issued by the stock exchange(s)/ SEBI/ other regulatory authority in the last five years.

7. In respect of the track record of the directors, there have been no criminal cases filed or investigations being undertaken with regard to alleged commission of any offence by any of our directors and none of our directors have been charge- sheeted with serious crimes like murder, rape, forgery, economic offence.

DETAILS OF DIRECTORSHIP(S) IN LISTED COMPANIES WHOSE SHARES HAVE BEEN/WERE SUSPENDED FROM BEING TRADED ON ANY OF THE STOCK EXCHANGES, DURING HIS/HER TENURE:

None of our Directors is or was a director of any listed company, whose shares have been or were suspended from being traded on any Stock Exchanges, in the last five years prior to the date of the Draft Red Herring Prospectus, during the term of their directorship in such company.

Further, none of our directors is or was, a director of any listed company, which has been or was delisted from any Stock Exchange during the term of their directorship in such company.

RELATIONSHIP BETWEEN ANY OF THE DIRECTORS OR ANY OF THE DIRECTORS AND KEY MANAGERIAL PERSONNEL OR SENIOR MANAGEMENT:

Except as stated below, none of the Directors of the Company are related to each other as per Section 2(77) of the Companies Act, 2013:

S. No Name of Director/ Key Managerial Personnel/ Senior Management	Nature of Relationship
1. Nitin Tiwari	Spouse of Ruchi Tiwari
2. Ruchi Tiwari	Spouse of Nitin Tiwari

ARRANGEMENT OR UNDERSTANDING WITH MAJOR SHAREHOLDERS, CUSTOMERS, SUPPLIERS OR OTHERS:

None of our Key Managerial Personnel, Senior Management or Directors have been appointed pursuant to any arrangement or understanding with our major shareholders, customers, suppliers or others pursuant to which any of the directors was selected as a director or member of senior management. We confirm that there is no conflict of interest between the suppliers of raw materials and third-party service providers (crucial for operations of our Company) and our Company, Key Managerial Personnel, Directors and Senior Management.

SERVICE CONTRACTS ENTERED INTO BY THE DIRECTORS:

Our Company has entered into agreements dated January 19, 2026 with Nitin Tiwari, Managing Director for a period of 5 Years. The agreement provides for certain benefits upon completion of tenure/termination, including gratuity, leave encashment, and provident fund contributions. Except as stated above, none of our Directors have entered into a service contract with our Company pursuant to which they are entitled to any benefits upon termination of their employment.

BORROWING POWERS OF OUR BOARD:

Our Articles of Association, subject to applicable law, authorize our Board to raise or borrow money or secure the payment of any sum of money for the purposes of our Company. Pursuant to a resolution passed by our shareholders at their Extra Ordinary General Meeting held on December 15, 2025 our shareholders have authorized our Board to borrow any sum of money from time to time notwithstanding that the sum or sums so borrowed together with the monies, if any, already borrowed by the Company (apart from temporary loans obtained from the Companys bankers in the ordinary course of business) exceed the paid up capital and free reserves of the Company provided such amount does not exceed 200 Crore (Rupees Two Hundred Crore only) over and above the aggregate of the paid up share capital and free reserves which may have not been set apart for any purpose.

COMPENSATION AND REMUNERATIONS:

Compensation to Managing Director

Nitin Tiwari, Promoter and Managing Director, has been associated with our Company since the incorporation of the company. He was re-appointed as Managing Director pursuant to a resolution passed by the Board on January 19, 2026 and a special resolution passed by the shareholders on January 24, 2026 for a term of five years commencing from January 19, 2026. The table below presents the remuneration payable to managing director duly approved in accordance with the applicable provisions of the Companies Act 2013:

Particulars	Remuneration
Fixed Salary	15 Lakh Per month
Variable pay	NIL
Other Benefits	-Rent Free accommodation or in case of residence owned by the director, payment/ reimbursement of monthly society bill;
	-Payment/ reimbursement of expenditure of gas, electricity, water, telephone, furnishing at residence;
	-Payment/ reimbursement of medical/ hospital expenses for self and family members, furnishing, payment of premium on personal accident and health insurance;
	-Payment/ reimbursement of expenditure relating to education of children of director, and
	-Such other perquisites as may be approved by the Board or Nomination and Remuneration Committee of Directors, from time to time;
	-Provision of company-maintained car for official use;
	-Perquisites shall be valued as per Income Tax Rules.
Minimum Remuneration	-In any Financial Year, during the tenure of our Managing Director, if our Company has no profits or its profits are inadequate, then he will be paid in accordance with the provisions of Schedule V of the Act.
	-He shall be entitled to receive total remuneration including perquisites, etc., not exceeding the ceiling limits as approved by the Board of Directors and the members, as minimum remuneration.

Remuneration to Executive Directors

Ruchi Tiwari, Executive Director has been associated with the Company since its incorporation and currently serves as an Executive Director. The table below presents the remuneration payable to Executive Director duly approved in accordance with the applicable provisions of the Companies Act 2013:

Particulars	Remuneration
Fixed Salary	6 Lakh Per month
Variable pay	NIL
Other Benefits	- Rent Free accommodation or in case of residence owned by the director, payment/ reimbursement of monthly society bill;
	- Payment/ reimbursement of expenditure of gas, electricity, water, telephone, furnishing at residence;
	- Payment/ reimbursement of medical/ hospital expenses for self and family members, furnishing, payment of premium on personal accident and health insurance;
	- Payment/ reimbursement of expenditure relating to education of children of director, and
	- Such other perquisites as may be approved by the Board or Nomination and Remuneration Committee of Directors, from time to time;
	- Provision of company-maintained car for official use;
	- Perquisites shall be valued as per Income Tax Rules.
Minimum Remuneration	- In any Financial Year, during the tenure of our Managing Director, if our Company has no profits or its profits are inadequate, then he will be paid in accordance with the provisions of Schedule V of the Act.
	- He shall be entitled to receive total remuneration including perquisites, etc., not exceeding the ceiling limits as approved by the Board of Directors and the members, as minimum remuneration.

Sitting fees and commission to Non-Executive Directors and Independent Directors

Our Board appointed Alok Tripathi and Imran Mohammad as an Independent Directors pursuant to a board resolution dated August 13, 2025 and they were subsequently regularized by the members pursuant to a Shareholders resolution dated September 25, 2025. Further, Gofran Ahmad Khan was appointed as an Independent Director pursuant to board resolution dated January 19, 2026 and was regularized by the members pursuant to a Shareholders resolution dated January 24, 2026. Consequently, these Directors are entitled to receive sitting fees of 25,000/- (Rupees Twenty-Five Thousand Only) per annum for attending meeting of Board of Directors and the Committees of Board of Directors.

PAYMENT OR BENEFIT TO DIRECTORS OF OUR COMPANY TINGENT AND DEFERRED COMPENSATION PAYABLE

The details of remuneration paid to the Managing Director and executive Director for services rendered by them to the Company during the period ended as on March 31, 2025:

Nitin Tiwari:

Particulars	Remuneration
Designation	Managing Director
Term	Has been appointed as Managing director since Incorporation and reappointed as Managing Director with effect from January 20, 2021 for the period of five years and further re-appointed as Managing Director with effect from January 19, 2026 for a period of five (5) years.
Remuneration paid during the year ended on March 31, 2025	1,80,00,000 per annum
Ruchi Tiwari:
Particulars	Remuneration
Designation	Executive Director
Term	She has been appointed as Executive director since Incorporation and is liable to be retire by rotation
Remuneration paid during the year ended on March 31, 2025	72,00,000 per annum

Independent Director

Our Non-Executive Independent Directors were appointed in Fiscal 2026, and accordingly no sitting fees or commission or remuneration was paid by our Company to our Independent Directors for Fiscal 2025.

ARRANGEMENT OR UNDERSTANDING WITH MAJOR SHAREHOLDERS, CUSTOMERS, SUPPLIERS OR OTHERS

There is no arrangement or understanding with major shareholders, customers, suppliers or others, pursuant to which any of our directors have been appointed.

REMUNERATION PAID OR PAYABLE TO OUR DIRECTORS BY OUR SUBSIDIARY

There is no remuneration paid or payable to our directors by any subsidiary, as our company does not have any subsidiaries

CONTINGENT AND DEFERRED COMPENSATION PAYABLE TO THE DIRECTORS:

Our Company as on the date of the Draft Red Herring Prospectus, there is no contingent or deferred compensation payable to any of our directors.

BONUS OR PROFIT-SHARING PLAN FOR THE DIRECTORS:

Our Company as on the date of the Draft Red Herring Prospectus does not have any bonus or profit-sharing plan for our directors.

LOANS TO DIRECTORS

There are no loans that have been availed by the Directors from our Company that are outstanding as on the date of the Draft Red Herring Prospectus

SHAREHOLDING OF DIRECTORS IN OUR COMPANY:

Except as disclosed below, as on the date of the Draft Red Herring Prospectus, none of our directors hold any Equity Shares in our Company:

Name of the Director	No. of Equity Shares	Percentage of Share Capital (%)
Nitin Tiwari	1,02,23,250	72.85%
Ruchi Tiwari	30,60,000	21.81%

* Our Articles of Association do not require our directors to hold any qualification Equity Shares in the Company.

INTERESTS OF DIRECTORS:

All the Directors may be deemed to be interested to the extent of remuneration and reimbursement of expenses payable to them under the Articles, and to the extent of remuneration paid to them for services rendered as an officer or employee of the Company. For further details, please refer to chapter titled "Our Management" beginning on page 164 of this Draft Red Herring Prospectus.

Our directors may also be regarded as interested to the extent of their shareholding and dividend payable thereon, if any, and to the extent of Equity Shares, if any held by them in our Company or held by their relatives. Further our directors are also interested to the extent of unsecured loans, if any, given by them to our Company or by their relatives.

Except as stated otherwise in this Draft Red Herring Prospectus, our Company has not entered into any Contract, Agreements or Arrangements during the preceding two years from the date of the Draft Red Herring Prospectus in which the Directors are interested directly or indirectly and no payments have been made to them in respect of the contracts, agreements or arrangements which are proposed to be entered into with them.

Except as stated in the chapter titled "Our Management" or the section titled "Financial information of the Company Annexure

35- Related Party Disclosure" beginning on page 164 and 185 respectively of this Draft Red Herring Prospectus, and except to the extent of shareholding in our Company, our Directors do not have any other interest in our company.

Except as stated in the chapter titled "Our Promoters" beginning on page 178 of this Draft Red Herring Prospectus, our Directors do not have any interest in any property acquired by our Company within three years preceding the date of this Draft Red Herring Prospectus, or proposed to be acquired by our Company as on the date of filing, or in any transaction relating to acquisition of land, construction of buildings, or supply of machinery.

CHANGES IN OUR BOARD IN THE LAST THREE YEARS:

Details of the changes in our Board in the last three years are set forth below:

Name of Director	Date of Change	Reason
Nitin Tiwari	January 19, 2026	Re-appointed as a Managing Director
Satyam Gehlot	January 19, 2026	Resigned under section 168 of the Companies Act, 2013
Gofran Ahmad Khan	January 19, 2026	Appointment as an Additional Director (Independent)^
Vishal Saxena	January 19, 2026	Resigned under section 168 of the Companies Act, 2013
Alok Tripathi	August 13, 2025	Appointment as an Additional Director (Independent)*
Imran Mohammad	August 13, 2025	Appointment as an Additional Director (Independent)*
Vishal Saxena	August 13, 2025	Appointment as an Additional Director (Independent)*

*Regularized pursuant to resolution passed by the Shareholders on September 25, 2025 ^ Regularized pursuant to resolution passed by the Shareholders on January 24, 2026

MANAGEMENT ORGANIZATIONAL STRUCTURE

The following chart depicts our Management Organization Structure

CORPORATE GOVERNANCE:

Pursuant to the applicable provision of the Companies Act, 2013 and SEBI (LODR) Regulations, 2015 as amended from time to time with respect to corporate governance, will be applicable to some extent on our Company upon the listing of the Equity Shares with the Stock Exchange. As on date of the Draft Red Herring Prospectus, as our Company is coming with an issue in terms of Chapter IX of the SEBI (ICDR) Regulations, 2018 as amended from time to time, the compliance with corporate governance provisions as specified in regulations 17, 17A, 18, 19, 20, 21, 22, 23, 24, 24A, 25, 26, 26A, 27 and clauses (b) to (i) and (t) of sub-regulation (2) of regulation 46 and para C, D and E of Schedule V is not applicable to our Company, although we require to comply with requirement of the Companies Act, 2013 and Regulation 23 of SEBI (LODR) wherever applicable.

Our Company stand committed towards the good corporate governance and has complied with the corporate governance requirement, particularly in relation to appointment of independent directors including woman director on our Board, and constitution of an Audit Committee, Stakeholders Relationship Committee and Nomination and Remuneration Committee. Our

Board functions either on its own or through committees constituted thereof, to oversee specific operational areas.

As on the date of this Draft Red Herring Prospectus, our Board comprises 5 (Five) Directors (including 1 (one) woman Director), which includes 1 (one) Managing Director, 1 (one) Executive Directors, and 3 (three) Non-Executive Independent Directors. In compliance with Section 152 of the Companies Act, not less than two thirds of the Directors (excluding Independent Directors) are liable to retire by rotation.

Our Company undertakes to take all necessary steps to continue to comply with all the requirements of SEBI Listing Regulations and the Companies Act.

COMMITTEES OF OUR BOARD:

The following committees have been constituted in terms of SEBI (LODR) Regulations, 2015 and the Companies Act, 2013;

1. Audit Committee

2. Stakeholders Relationship Committee

3. Nomination and Remuneration Committee

4. Corporate Social Responsibility Committee

AUDIT COMMITTEE:

Our Company has formed the Audit Committee vide resolution passed in the meeting of Board of Directors held on October 28, 2025 as per the applicable provisions of the Section 177 of the Companies Act, 2013 read with the Companies (Meetings of Board and its Powers) Rules, 2014 (as amended) and the Committee was subsequently reconstituted pursuant to a resolution passed by the Board of Directors at its meeting held on January 19, 2026.

The Re-constituted Audit Committee comprises following members:

Name of the Director	Status in Committee	Nature of Directorship
Alok Tripathi	Chairman	Non-Executive Independent Director
Imran Mohammad	Member	Non-Executive Independent Director
Gofran Ahmad Khan	Member	Non-Executive Independent Director

The Company Secretary & Compliance Officer of our Company shall act as the Secretary to the Audit Committee.

Set forth below are the scope, functions and the terms of reference of our Audit Committee, in accordance with Section 177 of the Companies Act, 2013 and Regulation 18(3) of SEBI (LODR) Regulation, 2015;

A. Tenure

The Audit Committee shall continue to be in function as a committee of the Board until otherwise resolved by the Board, to carry out the functions of the Audit Committee as approved by the Board.

B. Quorum and meetings of the Audit Committee

The quorum necessary for a meeting of the Audit Committee shall either be two members or one third of the members of the Committee, whichever is greater, with at least two Independent Director. The Audit Committee shall meet at least four times in a financial year subject to the condition that the gap between two consecutive meetings shall not be more than one hundred and twenty days.

C. Power of the Committee

The Audit Committee shall have powers, including the following: - to investigate any activity within its terms of reference; - to seek information from any employee; - to obtain outside legal or other professional advice;

- to secure attendance of outsiders with relevant expertise, if it considers necessary as may be prescribed under the Companies Act, 2013 (together with the rules thereunder) and SEBI Listing Regulations; and

D. Role of the Committee

The Role of Audit Committee shall include the following:

- Oversight of the listed entitys financial reporting process and the disclosure of its financial information to ensure that the financial statement is correct, sufficient and credible; - recommendation for appointment, remuneration and terms of appointment of auditors of the listed entity; - approval of payment to statutory auditors for any other services rendered by the statutory auditors; - reviewing, with the management, the annual financial statements and auditors report thereon before submission to the board for approval, with particular reference to: a) matters required to be included in the directors responsibility statement to be included in the boards report in terms of clause (c) of sub-section (3) of Section 134 of the Companies Act, 2013; b) changes, if any, in accounting policies and practices and reasons for the same; c) major accounting entries involving estimates based on the exercise of judgment by management; d) significant adjustments made in the financial statements arising out of audit findings; e) compliance with listing and other legal requirements relating to financial statements; f) disclosure of any related party transactions; g) modified opinion(s) in the draft audit report; - reviewing, with the management, the quarterly financial statements before submission to the board for approval; - reviewing, with the management, the statement of uses / application of funds raised through an issue (public issue, rights issue, preferential issue, etc.), the statement of funds utilized for purposes other than those stated in the offer document / prospectus / notice and the report submitted by the monitoring agency monitoring the utilisation of proceeds of a [public issue or rights issue or preferential issue or qualified institutions placement], and making appropriate recommendations to the board to take up steps in this matter;

- reviewing and monitoring the auditors independence and performance, and effectiveness of audit process;

- approval or any subsequent modification of transactions of the listed entity with related parties; - scrutiny of inter-corporate loans and investments; - valuation of undertakings or assets of the listed entity, wherever it is necessary; - evaluation of internal financial controls and risk management systems;

- reviewing, with the management, performance of statutory and internal auditors, adequacy of the internal control systems; - reviewing the adequacy of internal audit function, if any, including the structure of the internal audit department, staffing and seniority of the official heading the department, reporting structure coverage and frequency of internal audit; - discussion with internal auditors of any significant findings and follow up there on; - reviewing the findings of any internal investigations by the internal auditors into matters where there is suspected fraud or irregularity or a failure of internal control systems of a material nature and reporting the matter to the board; - discussion with statutory auditors before the audit commences, about the nature and scope of audit as well as post-audit discussion to ascertain any area of concern; - to look into the reasons for substantial defaults in the payment to the depositors, debenture holders, shareholders (in case of non-payment of declared dividends) and creditors; - to review the functioning of the whistle blower mechanism; - approval of appointment of chief financial officer after assessing the qualifications, experience and background, etc. of the candidate;

- Carrying out any other function as is mentioned in the terms of reference of the audit committee;

- reviewing the utilization of loans and/ or advances from/investment by the holding company in the subsidiary exceeding rupees 100 crore or 10% of the asset size of the subsidiary, whichever is lower including existing loans / advances / investments existing as on the date of coming into force of this provision; - consider and comment on rationale, cost-benefits and impact of schemes involving merger, demerger, amalgamation etc., on the listed entity and its shareholders.

Further, the Audit Committee shall mandatorily review the following:

- Management discussion and analysis of financial condition and results of operations; - management letters / letters of internal control weaknesses Issued by the statutory auditors; - internal audit reports relating to internal control weaknesses;

- the appointment, removal and terms of remuneration of the chief internal auditor shall be subject to review by the audit committee; and - statement of deviations: 1. quarterly statement of deviation(s) including report of monitoring agency, if applicable, submitted to stock exchange(s) in terms of Regulation 32(1) of the SEBI (ICDR) Regulations; C. annual statement of funds utilized for purposes other than those stated in the Issue document/prospectus/notice in terms of

Regulation 32(7) of the SEBI (ICDR) Regulations.

STAKEHOLDERS RELATIONSHIP COMMITTEE:

Our Company has formed the Stakeholders Relationship Committee as per Section 178 of the Companies Act, 2013 and other applicable provisions of the Companies Act, 2013 read with the Companies (Meetings of Board and its Powers) Rules, 2014 (as amended) vide board resolution dated January 31, 2026.

The constituted Stakeholders Relationship Committee comprises of the following members:

Name of the Director	Status in Committee	Nature of Directorship
Gofran Ahmad Khan	Chairman	Non-Executive Independent Director
Imran Mohammad	Member	Non-Executive Independent Director
Alok Tripathi	Member	Non-Executive Independent Director

The Company Secretary & Compliance Officer of our Company shall act as the Secretary to the Stakeholders Relationship

Committee.

The Stakeholders Relationship Committee shall oversee all matters pertaining to investors of our Company. The scope and function of the Stakeholders Relationship Committee and its terms of reference shall include the following:

A. Tenure

The Stakeholders Relationship Committee shall continue to be in function as a committee of the Board until otherwise resolved by the Board, to carry out the functions of the Stakeholders Relationship Committee as approved by the Board.

B. Meetings of the Stakeholders Relationship Committee

The Stakeholder Relationship Committee shall meet at least once in a financial year and shall report to the Board on a quarterly basis regarding the status of redressal of complaints received from the shareholders of the Company.

C. Role of the Committee

The role of the Stakeholders Relationship Committee shall be as under:

-Redressing of shareholder and investor complaints such as non-receipt of declared dividend, annual report, transfer of Equity Shares and issue of duplicate /split/consolidated share certificates;

-Monitoring transfers, transmissions, dematerialization, re-materialization, splitting and consolidation of Equity Shares and other securities issued by our company, including review of cases for refusal of transfer/transmission of shares and debentures;

-Reference to statutory and regulatory authorities regarding investor grievances;

-To otherwise ensure proper and timely attendance and redressal of investor queries and grievances;

-And to do all such acts, things or deeds as may be necessary or incidental to the exercise of the above powers.

NOMINATION AND REMUNERATION COMMITTEE:

Our Company has formed the Nomination and Remuneration Committee as per Section 178 of the Companies Act, 2013 and other applicable provisions of the Companies Act, 2013 read with the Companies (Meetings of Board and its Powers) Rules, 2014 (as amended) vide board resolution dated October 28, 2025 and the Committee was subsequently reconstituted pursuant to a resolution passed by the Board of Directors at its meeting held on January 19, 2026.

The Re-constituted Nomination and Remuneration Committee comprises of the following members:

Name of the Director	Status in Committee	Nature of Directorship
Imran Mohammad	Chairman	Non-Executive Independent Director
Alok Tripathi	Member	Non-Executive Independent Director
Gofran Ahmad Khan	Member	Non-Executive Independent Director

The Company Secretary & Compliance Officer of our Company shall act as the Secretary of the Nomination and Remuneration Committee.

The scope and function of the Committee and its terms of reference shall include the following:

A. Tenure

The Nomination and Remuneration Committee shall continue to be in function as a committee of the Board until otherwise resolved by the Board.

B. Quorum and meetings of the Nomination and Remuneration Committee

The committee shall meet as and when the need arises, subject to at least once in a year. The quorum for the meeting shall be one third of the total strength of the committee or two members, whichever is higher, including at least one independent director in attendance. The Chairman of the Nomination and Remuneration Committee may be present at the annual general meeting, to answer the shareholders queries; however, it shall be up to the chairman to decide who shall answer the queries.

C. Role of the Committee:

The role of the Nomination and Remuneration Committee shall be as under:

-formulating the criteria for determining qualifications, positive attributes and independence of a director;

-Recommend to the Board a policy relating to the remuneration of the directors, key managerial personnel and Senior Management or other employees;

-Formulation of criteria for evaluation of independent director and board;

-Recommendation to the Board, appointment and removal of director, KMP, and Senior Management;

-To carry out any other functions as mandated by the board from time to time and/or enforced by any statutory notification, amendment or modification as may be applicable.

-To device a policy on the diversity of the board of directors;

CORPORATE SOCIAL RESPONSIBILITY COMMITTEE:

Our Company has formed the Corporate Social Responsibility Committee in accordance with the provisions of Section 135 of the Companies Act, 2013 read with the Companies (Corporate Social Responsibility Policy) Rules, 2014 (as amended) vide board resolution dated August 31, 2019 and the Committee was subsequently reconstituted pursuant to a resolution passed by the Board of Directors at its meeting held on January 19, 2026. The Re-constituted CSR Committee comprises of the following members:

Name	Status in Committee	Nature of Directorship
Nitin Tiwari	Chairman	Managing Director
Ruchi Tiwari	Member	Executive Director
Alok Tripathi	Member	Non-Executive Independent Director

The Company Secretary and Chief Financial Officer of the Company shall attend and participate at the meeting but shall not have the right to vote.

The scope and functions of the corporate social responsibility committee are in accordance with section 135 of the Companies Act, 2013 and its terms of reference are set forth below:

-formulate and recommend to the Board, a "Corporate Social Responsibility Policy" which shall indicate the activities to be undertaken by the Company as specified in Schedule VII of the Companies Act, 2013, as amended; -recommend the amount of expenditure to be incurred on the activities referred to in clause (a)of sub-section (3) of Section 135 of the Companies Act, 2013; -monitor the corporate social responsibility policy of the Company and its implementation from time to time; -any other matter as the Corporate Social Responsibility Committee may deem appropriate after approval of the Board or as may be directed by the Board from time to time and/or as may be required under applicable law, as and when amended from time to time

The Committee shall consider the permissible CSR activities relating to the following:

1. Eradicating extreme hunger and poverty

2. Promotion of education

3. Promoting gender equality and empowering women

4. Reducing child mortality and improving maternal health

5. Combating human immunodeficiency virus, acquired immune deficiency syndrome, malaria and other disease

6. Ensuring environmental sustainability

7. Employment enhancing vocational skills

8. Social business projects

9. Contribution to the Prime Ministers National Relief Fund or any other fund set up by the Central Government or the State

Government for socio-economic development relief and funds for the welfare of the scheduled casts, the schedules tribes, other backward classes, minorities and women 10. Such other matters as may be prescribed

COMPLIANCE WITH SME LISTING REGULATIONS

The provisions of the SEBI (Listing Obligation and Disclosures) Regulations, 2015 will be applicable to our Company, immediately upon the listing of Equity Shares of our Company on SME Platform of BSE (BSE SME).

OUR KEY MANAGERIAL PERSONNEL

Brief Profile of KMPs

In addition to our Managing Director, whose details have been provided under paragraph above titled Brief Profile of our Directors, set forth below are the details of our Key Managerial Personnel as on the date of filing of the Draft Red Herring Prospectus:

Name	Satyam Gehlot
Designation	Chief Financial Officer
Date of Appointment	January 19, 2026
	174
Age	50 Years
Service contracts including termination /	NA
retirement benefits
Term of Office	As per the Company rules
Expiration of Term	As per the Company rules
Qualification	B. Com, LLB
Overall Experience	30 years
Remuneration paid as on March 31, 2025	NIL
Name	Priya Darshil Mody
Designation	Company Secretary
Date of Appointment	January 19, 2026
Age	31 Years
Service contracts including termination /	NA
retirement benefits
Term of Office	As per the company rules
Expiration of Term	As per the company rules
Qualification	Company Secretary, BBA, MBA
Overall Experience	5 years
Remuneration paid as on March 31, 2025	NIL

Nitin Tiwari, Managing Director

For details, please refer Brief Profile of Directors mentioned in chapter titled "Our Management" beginning on page 164 of the Draft Red Herring Prospectus

Satyam Gehlot, Chief Financial Officer

Satyam Gehlot, aged 50 years, is the Chief Financial Officer of the Company and he holds a Bachelor of Commerce and Bachelor of Laws degree from Jiwaji University, Gwalior. He has been associated with the organization since 1994 and possesses over 30 years of experience in finance, accounts, taxation, and statutory compliances. He has played a pivotal role in the Companys transition from a partnership firm to a private limited company and subsequently into a public limited company. He oversees financial management, corporate governance and overall business development of the Organisation. His extensive knowledge of corporate laws and strong understanding of financial matters significantly contribute to the Companys growth and compliance framework.

Priya Darshil Mody, Company Secretary and Compliance officer

Priya Mody, aged 31 years, was appointed as the Company Secretary and Compliance Officer of our Company with effect from January 19, 2026. She is a Qualified Company Secretary and an Associate Member of the Institute of Company Secretaries of India since August 2018. She holds a Post Graduate Diploma in Business Administration (Finance) from Symbiosis Centre for Distance

Learning and a Bachelors degree in Business Administration from BKIMBA, Ahmedabad University. She has over 5 Years of post-qualification experience in corporate compliance, secretarial matters, and regulatory filings. She has worked with practicing company secretaries firms and corporates, including Vitrag Engineers Private Limited, Grovalue Private Limited and Pixon Green Energy Private Limited. She has been actively involved in handling Companies Act compliances, corporate governance matters, and coordination with regulatory authorities.

SENIOR MANAGEMENT PERSONNEL (SMP)

In addition to Directors and KMPs whose details have been provided under paragraph above titled Brief Profile of our Directors and Our Key Managerial Personnel, set forth below are the details of our Senior Management as on the date of filing of the Draft Red Herring Prospectus

Brief profile of Senior Management

Jeetendra Rajak, aged 35 years, is the Chief Administration Officer of the company. He holds a Bachelor degree in Commerce from Madhya Pradesh Bhoj (Open) university completed in the year 2014. With over 16 years of industrial experience, he supervise administrative systems, compliance-related matters, internal coordination, office management, and implementation of administrative policies of our company. He has been serving the company since its incorporation. He received a remuneration of

5.8 lakh from the Company in Financial Year 2025.

Manish Bhardwaj aged 49 years, is the Chief Production and the operations officer of the company. He holds a Bachelor degree in Commerce from Jiwaji University Gwalior obtained in the year 1997. He has 27 years of the experience in the production and operations management. His responsibilities include overseeing production planning, operational improvements, manpower 175 management, material handling, and ensuring compliance with quality and statutory norms. He has been associated with the company since the incorporation of the company. He received a remuneration of 12.9 lakh from the Company in Financial Year

2025.

Kirti Patel aged 35 years is serving as the Head- Marketing, Sales, Global Branding & Communication in the company. She holds a Masterss degree in Business Administration from Savitribai Phule Pune University obtained in the year 2014 and Bachelor degree in Management studies from University of Mumbai obtained in the year 2012. With over 7 years of experience, her role in the company pertains to Developing and implementing marketing and sales strategies, Managing key customer relationships, enhancing brand visibility, Overseeing sales targets, performance monitoring, and reporting. She has been serving the organisation from March 26, 2018. She received a remuneration of 10.89 lakh from the Company in Financial Year 2025.

STATUS OF KEY MANAGERIAL PERSONNEL AND SENIOR MANAGEMENT

All Key Managerial Personnel and Senior Management Personnel are permanent employees of our Company

CHANGES IN OUR KEY MANAGERIAL PERSONNEL AND SENIOR MANAGEMENT IN THE THREE IMMEDIATELY PRECEDING YEARS

Except as disclosed below, none of the changes in our Key Managerial Personnel, and Senior Management in the three immediately preceding years:

Name of KMP and SMP	Date of change	Reason for change
Priya Darshil Mody	January 19, 2026	Appointment as Company Secretary
Satyam Gehlot	January 19, 2026	Appointment as Chief Financial Officer
Nitin Tiwari	January 19, 2026	Re-appointment as Managing Director

EMPLOYEES STOCK OPTION PLAN

As on date of the Draft Red Herring Prospectus, our Company has not made any employee stock option plan or purchase schemes for our employees.

INTERESTS OF KEY MANAGERIAL PERSONNEL AND SENIOR MANAGEMENT

None of the Key Managerial Personnel or Senior Management of our Company have any interests in our Company other than to the extent of shareholding in our Company and the remuneration or benefits to which they are entitled to as per their terms of appointment and reimbursement of expenses incurred by them during the ordinary course of business.

ARRANGEMENT AND UNDERSTANDING WITH MAJOR SHAREHOLDERS/ CUTOMERS/SUPPLIERS

None of the above mentioned KMP has entered into any kind of arrangement and understanding with major shareholders, customers and suppliers as on the date of the Draft Red Herring Prospectus.

COMPENSATION AND BENEFITS TO KEY MANAGERIAL PERSONNEL AND SENIOR MANAGEMENT INCLUDING DEFERRED AND CONTINGENT COMPENSATION

None of our KMPs/SMPs has received or is entitled to receive any deferred and contingent compensation in the financial year ended March 31, 2025

BONUS OR PROFIT-SHARING PLANS FOR OUR KEY MANAGERIAL PERSONNEL AND SENIOR MANAGEMENT

Our Company does not have any bonus or profit-sharing plan for our Key Managerial Personnel and Senior Management.

SHAREHOLDING OF KEY MANAGERIAL PERSONNEL AND SENIOR MANAGEMENT IN OUR COMPANY

Except as disclosed below, none of our Key Managerial Personnel and Senior Management hold any Equity Shares.

Name of the KMP/SMP	No. of Equity Shares	Percentage of Share Capital (%)
Nitin Tiwari	1,02,23,250	72.85%

ATTRITION RATE OF KEY MANAGERIAL PERSONNEL AND SENIOR MANAGEMENT

The Attrition rate of Key Managerial Personnel and Senior Management of our Company is not higher than the industry attrition rate. 176

EMPLOYEE STOCK OPTION SCHEME AND EMPLOYEE STOCK PURCHASE SCHEME

Our Company has not granted any option or allotted any Equity shares under any Employee stock option scheme and Employee stock purchase scheme.

PAYMENT OR BENEFIT TO KEY MANAGERIAL PERSONNEL AND SENIOR MANAGEMENT OF OUR COMPANY

Except as disclosed in Draft Red Herring Prospectus, no amounts or benefits in kind have been paid or given, or are intended to be paid or given, to any of our Companys Key Managerial Personnel and Senior Management in the two years preceding the date of the Draft Red Herring Prospectus.

OUR PROMOTERS AND PROMOTER GROUP OUR PROMOTERS The Promoters of our Company are:

S. No.	Name of the Promoters	Category	Number of Equity Shares
1.	Nitin Tiwari	Individual Promoter	1,02,23,250
2.	Ruchi Tiwari	Individual Promoter	30,60,000
	Total		1,32,83,250

For details with respect to build-up of the Promoters Shareholding, please refer to the Chapter titled "Capital Structure" beginning on page 57 of the Draft Red Herring Prospectus.

DETAILS OF OUR PROMOTERS	Nitin Tiwari, aged 53 years, is the Promoter and Managing Director of our Company. He holds a Bachelors degree in Engineering (Electronics & Telecommunication) from Jiwaji University, Gwalior, obtained in the year 1993. He has over 30 years of experience in the leather and safety footwear industry. He commenced his entrepreneurial journey in 1994 with the establishment of M/s ACME Fabrik Co., a partnership firm engaged in the manufacturing of safety footwear. In 2016, the firm was converted into ACME Universal Safezone 9 Limited (initially incorporated as a private limited company), continuing its focus on the manufacturing of safety footwear, thereby marking his long-term commitment to the industry.
	Nitin Tiwari was conferred with the Emerging Entrepreneur - Make in India Award presented by Smt. Nirmala Sitharaman (then Honble Minister of Commerce and Industry) in the year 2016.He has also been featured in The Dollar Business magazine (2017) for excellence in exports and innovation, and in Mint newspaper (2017) for his contributions towards industrial safety and manufacturing excellence.
	He is responsible for formulating and overseeing the Companys strategies and policies, supervising overall business operations with direct oversight in the production activities ensuring efficient execution across departments. He has been re-appointed as the Managing Director of the Company since January 19,2026 and has been associated with the Company since its incorporation.
Name	Nitin Tiwari
Date of Birth	June 17, 1972
PAN	ABDPT2871L
Age	53 years
Educational Qualification	Bachelors degree in Engineering (Electronics & Telecommunication).
Personal Address	2001 BLDG 3 20th FLR Raheja Classique CHS L, Link Road, Mumbai, Andheri,
	Maharasthra-400053
Experience	Over 30 years of experience in the leather and safety footwear industry
Directorship & Other	Indian Companies:
Ventures
	Public Company: Nil
	Private Company: Nil
	LLP: Nil
	Ruchi Tiwari, aged 46 years, is a Promoter and Director of our Company. She has done her Higher Secondary education. She has over 20 years of experience in manufacturing Industry (particularly in leather and safety footwear), business administration and organizational management. She plays an important role in the Companys strategic planning, policy formulation and operational oversight. She contributes towards strengthening corporate governance practices and improving operational efficiency of the Company. As a director, she provides guidance on organizational development and supports the management in achieving sustainable growth and maintaining quality standards. She has been associated with the Company since Inception.
Name	Ruchi Tiwari
Date of Birth	September 09, 1979
PAN	ADTPT2676H
Age	46 years
Educational Qualification	Higher Secondary Education
Personal Address	2001 BLDG 3 20th FLR Raheja Classique CHS L, Link Road, Mumbai, Andheri,
	Maharasthra-400053
Experience	Over 20 years of experience in manufacturing Industry particularly in leather and safety footwear sector.
Directorship & Other Ventures	Indian Companies:
	Public Company: Nil
	Private Company: Nil
	LLP: Nil

For details pertaining to other ventures of our Promoters, refer chapter titled "Our Group Companies" beginning on page 183 of the Draft Red Herring Prospectus.

DECLARATION:

We declare and confirm that the details of the PAN, Bank Account Number(s), Aadhar Card Number, Driving License Number and Passport Number of our Promoters shall be submitted to the Stock Exchange i.e. SME Platform of BSE (BSE SME)., where the Equity shares of our Company are proposed to be listed at the time of filling the Draft Red Herring Prospectus.

CHANGE IN CONTROL OF OUR COMPANY

There has not been any change in the control of our Company in the five years immediately preceding the date of this Draft Red Herring Prospectus.

EXPERIENCE OF OUR PROMOTERS IN THE BUSINESS OF OUR COMPANY

Our Promoters have adequate experience in line of business, including any proposed line of business, of our company. For detail in relation of promoters in the business of our company, please refer to the chapter titled "Our Management" beginning on page 164 of the Draft Red Herring Prospectus.

RELATIONSHIP OF PROMOTERS WITH OUR DIRECTORS

Except as disclosed herein, none of our Promoter(s) are related to any of our Companys Directors within the meaning of Section 2 (77) of the Companies Act, 2013.

S. No	Name of Director	Name of Promoter	Nature of Relationship
1.	Nitin Tiwari	Ruchi Tiwari	Spouse of Ruchi Tiwari
2.	Ruchi Tiwari	Nitin Tiwari	Spouse of Nitin Tiwari

OTHER UNDERTAKING / CONFIRMATIONS

-.

-Our promoters are neither prohibited nor debarred from accessing or operating in the capital market or restrained from buying, selling or dealing in securities under any order or direction passed by SEBI or any other authority or

-Our Promoters have confirmed that they have not been identified as wilful defaulters or fraudulent borrower.

-Refused listing of any of the securities issued by such entity by any stock exchange, in India or abroad.

-No material regulatory or disciplinary action is taken by any or regulatory authority in the past one year in respect of our Promoters, Group Company and Company promoted by the Promoters of our company.

-There are no defaults in respect of payment of interest and principal to the debenture/ bond/ fixed deposit holders, banks, FIs by our Company, our Promoters, Group Company and Company promoted by the Promoter during the past three years.

-Our Company or any of our Promoters or Promoter Group or Group Company or Directors has not been declared as a fugitive economic offender under the provision of section 12 of the Fugitive Economic Offenders Act, 2018.

-No violations of securities laws have been committed by our Promoters in the past or are currently pending against them. None of our Promoters are debarred or prohibited from accessing the capital markets or restrained from buying, selling, or dealing in securities under any order or directions passed for any reasons by the SEBI or any other authority or refused listing of any of the securities issued by any such entity by any stock exchange in India or abroad.

INTERESTS OF OUR PROMOTERS

Interest of our Promoters:

1. Interest in promotion and shareholding of Our Company:

Our Promoters are interested in our Company to the extent that (i) they have promoted our Company; (ii) of their respective shareholding and the shareholding of their relatives in our Company (directly or indirectly, as the case may be, including the dividends payable and any other distributions in respect of their respective shareholding in our Company); and (iii) involvement in the operations of the Company. For further details of the interest of our Promoters in our Company, refer chapter titled "Capital Structure" beginning on page 57, chapter titled "Our Management" beginning on page 164 and the profiles of our Promoters under this chapter.

Our Promoters are also interested in our Company to the extent of remuneration and reimbursement of expenses payable to them in their capacity as Managing Director of our Company (See chapter titled "Our Management" beginning on page 164). Additionally, our Promoters may be interested in transactions entered into by our Company with them and with other entities (i) in which our Promoters hold shares; or (ii)controlled by our Promoters. For further details of interest of our Promoters in our Company, see

"Restated Financial Statement Note 31-Related Party Transactions" on page 185

-Interest of Promoters in the Property of our Company:

Except as disclosed below, our Promoters do not have any interest in any property acquired by our Company within three years preceding the date of this Draft Red Herring Prospectus or proposed to be acquired by our Company as on the date of filing of this Draft Red Herring Prospectus or in any transaction for acquisition of land, construction of buildings and supply of machinery:

(i) Our Registered Office is situated at Near Twelve Shops Girwai Naka, A. B. Road, Gwalior, Madhya Pradesh, India, 474001, is currently under the possession and used by our company pursuant to Rent agreement dated July 01, 2025, executed between our Company and our Promoter Nitin Tiwari. (ii) Our Factory is situated at 27B/2, Co Operative, Ind. Estate Dada Nagar, Kanpur, Uttar Pradesh, 208022, is currently under the possession and use by our company pursuant to Rent agreement date August 25, 2025, executed between our company and our Promoter Ruchi Tiwari. (iii) Our Corporate office is situated at 1209, Remi Commercio, Opp. Yash Raj Studios, Off Link Road, Andheri (W), Mumbai

400053, India, is currently under the possession and use by our company pursuant to Leave & Licence agreement dated July 01, 2025, executed between our company and our Promoters Nitin Tiwari and Ruchi Tiwari. (iv) Our Factory is situated at 27-B, Co Operative, Ind. Estate Dada Nagar, Kanpur, Uttar Pradesh, 208022, is currently under the possession and use by our company pursuant to Rent agreement date December 01, 2025, executed between our company and our Promoter Nitin Tiwari.

-In Transaction for acquisition of land, constructions, of building and supply of machinery:

Except as stated in the Draft Red Herring Prospectus, none of our promoters are interested in any transaction for the acquisition of land, construction of building or supply of machinery.

-Other Interest in our company:

For transactions in respect of loans and other monetary transactions entered in past please refer "Note 31" on "Related Party Transactions" on page 185 forming part of "Financial Information" of this Draft Red Herring Prospectus.

Further, our promoters may be interested to the extent of personal guarantees given by them in favour of the Company, for the details of Personal Guarantee given by Promoters towards Financial facilities of our Company please refer to "Financial

Indebtedness" and "Financial Information" on page 188 and 185 respectively of this Draft Red Herring Prospectus.

OTHER VENTURES OF OUR PROMOTERS

Save and except as disclosed in this section titled "Our Promoters & Promoter Group" beginning on page 178 and the chapter titled "Our Management" beginning on page 164 of this Draft Red Herring Prospectus, there are no other ventures, in which our Promoters have any business interests/ other interests

MATERIAL GUARANTEES

Except as disclosed in section "Financial Information" on page 185, of the Draft Red Herring Prospectus no Promoters has provided any material guarantees to third parties with respect to the Equity Shares of our Company as on the date of the Draft Red Herring Prospectus.

DISASSOCIATION BY PROMOTERS OF OUR COMPANY

Our Promoters have not disassociated themselves from any companies, firms or entities during the last three years preceding the date of this Draft Red Herring Prospectus.

LITIGATION DETAILS PERTAINING TO OUR PROMOTER:

For details on litigations and disputes pending against the Promoters and defaults made by the Promoters please refer to the section titled "Outstanding Litigations and Material Developments" beginning on page 203 of this Draft Red Herring Prospectus.

RELATED PARTY TRANSACTIONS

For details of related party transactions entered into by our Company, please refer to "Statement of Related Party Transactions", as Restated appearing in Note 31 of the section titled "Financial Information" beginning on page 185 of the Draft Red Herring Prospectus.

PAYMENT OF AMOUNTS OR BENEFITS TO OUR PROMOTERS OR PROMOTER GROUP

Except as disclosed in Section "Financial Information" on page 185, of the Draft Red Herring Prospectus there has been no payment or benefits by our Company to our Promoters or any of the members of the Promoter Group during the two years preceding the date of the Draft Red Herring Prospectus.

OTHER CONFIRMATIONS

As on the date of the Draft Red Herring Prospectus, our Promoters and members of our Promoter Group have not been prohibited by SEBI or any other regulatory or governmental authority from accessing capital markets for any reasons. Further, our Promoters were not and are not promoters or persons in control of any other company that is or has been debarred from accessing the capital markets under any order or direction made by SEBI or any other authority. There is no litigation or legal action pending or taken by any ministry, department of the Government or statutory authority against our Promoters during the last five (5) years preceding the date of the Draft Red Herring Prospectus, except as disclosed under chapter titled "Outstanding Litigations and Material Developments" beginning on page 203 of the Draft Red Herring Prospectus.

Our Promoters and members of our Promoter Group have neither been declared as a wilful defaulter nor as a fugitive economic offender as defined under the SEBI (ICDR) Regulations, and there are no violations of securities laws committed by our Promoters in the past and no proceedings for violation of securities laws are pending against our Promoters.

INFORMATION OF OUR GROUP COMPANIES

RMATION OF OUR GROUP COMPANIESRMATION OF OUR GROUP COMPANIES

For details related to our group companies please refer "Our Group Companies" on page 183 of the Draft Red Herring Prospectus

OUR PROMOTER GROUP

Our Promoters Group in terms of Regulation 2(1) (pp) of the SEBI (ICDR) Regulations includes the following individuals, body corporates, firms and LLP:

A. Individuals forming part of Promoters Group

Name of the Promoters	Name of the Immediate relatives	Relationships
	Ruchi Tiwari	Spouse
Nitin Tiwari
	Late Shri Ram Kumar Tiwari	Father
Name of the Promoters	Name of the Immediate relatives	Relationships
	Sushila Tiwari	Mother
	Prashant Tiwari	Brother
	Preeti Mishra, Niti Pande	Sister
	Aryan Tiwari, Rayhan Tiwari	Son
	Shashi Kumar Dixit	Spouses Father
	Usha Dixit	Spouses Mother
	Ravi Dixit	Spouses Brother
	Nitin Tiwari	Spouse
	Shashi Kumar Dixit	Father
	Usha Dixit	Mother
	Ravi Dixit	Brother
Ruchi Tiwari	Aryan Tiwari, Rayhan Tiwari	Son
	Late Shri Ram Kumar Tiwari	Spouses Father
	Sushila Tiwari	Spouses Mother
	Prashant Tiwari	Spouse Brother
	Preeti Mishra, Niti Pande	Spouses Sister

B. Entities forming part of our Promoter Group

As per Regulation 2(1)(pp)(iv) of the SEBI (ICDR) Regulations the following entities would become the part of our Promoter Group:

Relation	Name and Details of Entity
Any Body Corporate in which twenty percent or more of the equity share capital is held by promoter or an immediate relative of the promoter or a firm or HUF in which promoter or any one or more of his immediate relatives are a member.	1.ACME Protective Solutions Private Limited
Any Body corporate in which Body Corporate as provided above holds twenty percent or more of the equity share capital.	Nil
Any Hindu Undivided Family or Firm in which the	2. Nitin Tiwari & Sons HUF
aggregate shareholding of the promoter and his immediate	3. Nitin Tiwari (Proprietorship Firm)
relatives is equal to or more than twenty percent.	4. Ruchi Tiwari (Proprietorship Firm)

C. All persons whose shareholding is aggregated under the heading "shareholding of the Promoter Group":

None of the other persons forms part of promoter group for the purpose of shareholding of the Promoter Group under Regulation 2(1) (pp)(v) of SEBI (ICDR) Regulations 2018: Except Aryan Tiwari

COMMON PURSUITS OF OUR PROMOTERS

The promoter Group entities are having business objects similar to our business. Further, currently we do not have any non-compete agreement/arrangement with any of our Group Entities. Such a conflict of interest may have adverse effect on our business and growth. We shall adopt the necessary procedures and practices as permitted by law to address any conflict situations, as and when they may arise