Bansisons Tea Industries Ltd Directors Report

To, The Members NOVYRA PHARMACHEM LIMITED

(FORMERLY KNOWN AS BANSISONS TEA INDUSTRIES LIMITED)

Your Directors here by present the 39 th Annual Report together with the Audited statements of Accounts for the financial year ended on 31 st March, 2026.

1) FINANCIAL RESULTS AND OPERATIONAL REVIEW:

(Amount in Rs. Lakhs)

Particulars	31 st March, 2026	31 st March, 2025
Income:
Revenue from Operations	10.44	0.00
Other Income	6.31	4.80
Total Revenue (A)	16.75	4.80
Expenditure:
Cost of Materials Consumed	0.00	0.00
Purchase of Trade	0.00	0.00
Employee Benefits Expenses	15.06	3.84
Depreciation and Amortization Expenses	2.89	3.34
Operating & Other Expenses	536.17	3.97
Total Expenses (B)	554.13	11.16
Profit Before Tax (A-B)	(537.38)	(6.36)
Tax Expenses:
(1) Current Tax	0.00	0.00
(2) Tax Expense for Earlier Year	0.00	0.00
Profit for the year	(537.38)	(6.36)
Appropriated as under:
Dividend proposed	0.00	0.00
Tax on Proposed Dividend	0.00	0.00
Balance carried to Balance sheet	(537.38)	(6.36)

2) NATURE OF BUSINESS:

Main object of the company has been amended during the year under review. Thereby the Company has three reportable business segments mainly, Pharma, Real Estate & Tea Estate. The Company is striving hard to establish in the market and very much hope after shifting of registered office from the state of West Bengal to the State of Gujrat. The main hurdles in the operations of business are banking finance only. In order to overcome from this hurdle, the Board of Directors of the Company has proposed the Scheme of Capital reduction at their meeting held on 16 th May, 2026 .

3) DIVIDEND:

Keeping in view the conservation of financial resources, the board of Directors of your company has not recommended any Dividend payment relating to the financial year ended on 31 st March, 2026.

4) TRANSFER TO RESERVES:

(Rs.5,37,38,196.65) was transferred to the reserves during the financial year ended 31 st March, 2026.

In view of the losses incurred during the financial year ended March 31, 2026, the Company does not have any profits available for appropriation. Accordingly, no amount has been transferred to the General Reserve.

The loss for the year amounting to Rs.537.38 Lakhs has been carried forward, resulting in a closing balance of accumulated losses of Rs.570.79 Lakhs in the Profit and Loss Account.

5) LIQUIDITY:

The Company manages its liquidity prudently to meet our strategic objectives. We clearly understand that the liquidity in the Balance Sheet is to ensure balance between earning adequate returns and the need to cover financial and business risks. Liquidity also enables the Company to position itself for quick responses to market dynamics.

6) REPORT ON PERFORMANCE AND FINANCIAL POSITION OF SUBSIDIARIES, ASSOCIATES AND JOINT VENTURE COMPANIES:

The Company does not have any subsidiaries, Associate and Joint Venture Companies. Hence, details for the same are not required to mention here.

7) CHANGE OF NAME:

During the year the Company has changed its name from Bansisons Tea Industries Limited to Novyra Pharmachem Limited through postal ballot notice dated 19 th November, 2025.

8) CHANGE OF REGISTERED OFFICE:

The Company has approved resolution for shifting of registered office from the state of west Bengal to the state of Gujarat through postal ballot notice dated 05 th February, 2025 and has received order from the RD vide order dated 28 th November, 2025. Hence now the registered office of the company is situated at R S No 432, T P Scheme No 3, F P No 89/A, City Survey No 3763, Plot No C, Palky Plot No A, Ground Floor, Back Side, Pavthawala Compound B/h Zenith Mill, Vastadevadi Road, Surat, Gujarat, 395004 w.e.f. 01 st December, 2025.

9) PARTICULARS OF EMPLOYEES:

The table containing the names and other particulars of employees in accordance with the provisions of Section 197(12) of the Companies Act, 2013, read with Rule 5(1) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, is provided as Annexure- A to the Boards report.

None of the top ten employees of the Company drew remuneration of Rs.1,02,00,000/- or more per annum or Rs. 8,50,000/- or more per month during the year as per amendment by Ministry of Corporate Affairs dated 30th June, 2016. Hence, no information is required to be furnished as required under Rule 5(2) and 5(3) of The Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014.

10) SHARE CAPITAL:

The issued, subscribed and Paid up Equity Share Capital of the Company as on March 31 st , 2026, is Rs.6,33,00,000/- divided into 63,30,000 equity shares of Rs.10/- each.

On 28 th March, 2025 and 9 th June, 2025, the Board of Directors of the Company has converted the partly paid-up equity shares of the Company having face value of 10/- each, on which 2.50 per share has already been paid-up, in respect of 1,76,600 partly paid-up shares issued by the Company and thereby the paid up share capital of the Company became fully paid-up share capital of the Company 6,33,00,000 (Rupees Six Crore Thirty-Three Lakh only) divided into 63,30,000 (Sixty-Three Lakh Thirty Thousand) equity shares of 10/- each.

A) Issue of equity shares with differential rights:

During the year under review, the Company has not issued any shares with differential voting rights. B) Issue of sweat equity shares During the year under review, the Company has not issued any sweat equity shares. C) Issue of employee stock options During the year under review, the Company has not issued any sweat equity shares. D) Provision of money by company for purchase of its own shares by employees or by trustees for the benefit of employees

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

11) FINANCE:

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

12) DETAILS PERTAINING TO SHARES IN SUSPENSE ACCOUNT:

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

13) INVESTOR EDUCATION AND PROTECTION FUND (IEPF)

There were no amounts which were required to be transferred to the Investor Education and Protection Fund by the Company

14) FIXED DEPOSIT:

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

15) PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS UNDER SECTION 186:

The Company has not given any loans or guarantees covered under the provisions of section 186 of the Companies Act, 2013.

16) SIGNIFICANT ORDERS PASSED BY THE REGULATORS, COURTS OR TRIBUNALS IMPACTING GOING

CONCERN AND CO.S OPERATIONS:

To the best of our knowledge, the company has not received any such orders passed by the regulators, courts or tribunals during the year, which may impact the going concern status or companys operations in future.

17) EMPLOYEE RELATIONS:

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

18) BUSINESS RISK MANAGEMENT:

The Company has laid down a Risk Management Policy and identified threat of such events which if occurs will adversely affect either / or, value to shareholders, ability of company to achieve objectives, ability to implement business strategies, the manner in which the company operates and reputation as Risks. Further such Risks are categorized in to Strategic Risks, Operating Risks & Regulatory Risks. A detailed exercise is carried out to identify, evaluate, manage and monitoring all the three types of risks.

19) INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY:

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

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

20) VIGIL MECHANISM / WHISTLE BLOWER POLICY:

The Company has a vigil mechanism named Whistle Blower Policy to deal with instances of fraud and mismanagement, if any. The company has adopted a Whistle Blower Policy, which affords protection and confidentially to Whistle blowers. The Audit Committee Chairman is authorized to receive Protected Disclosures under this Policy. The Audit Committee is also authorized to supervise the conduct of investigations of any disclosures made whistle blowers in accordance with policy.

No personnel have been denied access to the Audit Committee. As of March 31, 2026, No Protected Disclosures have been received under this policy.

21) PREVENTION OF INSIDER TRADING:

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

The New Code viz. Code of Internal Procedures and Conduct for regulating, Monitoring and reporting of Trading by Insiders and Code of Practices and Procedures for fair Disclosure of Unpublished price Sensitive Information has been framed and adopted. The Code requires pre-clearance for dealing in the Companys shares and prohibits purchase or sale of Company shares by the Directors and designated employees while in possession of unpublished price sensitive information in relation to the Company and during the period when the Trading Window is closed. The Company is Responsible for implementation of the Code.

CODE OF CONDUCT FOR DIRECTORS AND SENIOR MANAGEMENT PERSONNEL

In terms of SEBI (Listing Obligations and Disclosure Requirement), Regulations, 2015, the Board of Directors of the Company has laid down a Code of Conduct for all Board Members and Senior Management Personnel of the Company. The said Code of Conduct has been posted on the website of the Company. The Board Members and Senior Management Personnel of the Company have affirmed compliance with the Code. The Chairman & Managing Director of the Company has given a declaration to the Company that all the Board Members and Senior Management Personnel of the Company have affirmed compliance with the Code. The Board of Directors and designated employees have confirmed compliance with the Code. 22) DIRECTORS: a) Composition of Board of Directors as on 31 st March, 2026:

1 Mr. Sandeep Agarwal	Whole-time Director
2 Mr. Amit Mitruka	Director
3 Mr. Jayanta Kundu	CFO
4 Mrs. Mamy Ghosh*	Non-Executive Independent Director
5 Mrs. Sushilaben Dipakkumar Shah	Non-Executive Independent Director
6 Mr. Chirag Kirtikumar Nanavati	Non-Executive Independent Director
7 Mr. Hiren Dhirajlal Shah	Non-Executive Independent Director
8 Mr. Anilkumar Mohanbhai Amreliya#	Executive Director

*Resigned on 19/11/2025 #appointed on 06/02/2026

None of the Director is a member in more than 10 Companies and Act as Chairman in more than 5 Companies across all Companies in which he/she is a director. b) Declaration By Independent Directors: The Company has received necessary declaration from each Independent Director under Section 149 (7) of the Companies Act, 2013, that they meet the criteria of independence laid down in Section 149(6) of the Companies Act, 2013. c) Meeting of Board of Directors and attendance thereon: The meetings of the Board of Directors are held at periodical intervals and are generally at the registered office of the Company. The meeting dates are decided well in advance and the agenda and notes on agenda are circulated in advance to the directors. All material information is incorporated in the notes on agenda for facilitating meaningful and focused discussion at the meeting. Where it is not perusable to attach supporting or relevant documents to the agendas, the same is tabled before the meeting. In case of business exigencies or urgency of matters, resolutions are passed by circulation. Senior Management persons are often invited to attend the Board Meetings and provide clarifications as and when required.

During the year 2025-26, 12 (Twelve) Board Meetings were convened and duly held on:

10/05/2025	28/05/2025	09/06/2025	12/08/2025	04/09/2025	06/09/2025
11/11/2025	19/11/2025	28/11/2025	29/12/2025	26/01/2026	06/02/2026

The Board of Directors of the Company was present at the following Board Meeting held during the year under review.

Name of Director	Board Meetings Held	Meetings attended	Attendance at last AGM i.e. 29/09/2025
Mr. Sandeep Agarwal	12	12	Yes
Mr. Amit Mitruka	12	12	Yes
Mr. Jayanta Kundu	12	12	Yes
Mrs. Mamy Ghosh*	7	7	Yes
Mrs. Sushilaben	12	12	Yes
Dipakkumar Shah
Mr. Chirag Kirtikumar	12	12	Yes
Nanavati
Mr. Hiren Dhirajlal Shah	12	12	Yes
Mr. Anilkumar Mohanbhai	0	0	No
Amreliya#

#appointed on 06/02/2026 d) Separate Meeting Of Independent Directors:

Schedule IV of the Act, Listing Regulations and Secretarial Standard 1 on Meetings of the Board of Directors mandates that the Independent Directors of the Company hold at least one meeting in a year, without the attendance of Non-Independent Directors. The Independent Directors Meeting was held on March 20, 2026. The Independent Directors, inter alia, discussed and reviewed performance of Non-Independent Directors, the Board as a whole, Chairperson of the Company and assessed the quality, quantity and timeliness of flow of information between the Companys management and the Board that is necessary for the Board to effectively and reasonably perform their duties. In addition to formal meetings, frequent interactions outside the Board Meetings also take place between the Independent Directors and with the Chairperson, and rest of the Board. e) Details of the last three Annual General Meetings:

					Special resolution Passed
Annual	2024-25	3 rd Floor Metro Plaza, S.F.	29 th September,	12:30 P.M.	No
General		Road, PO- Siliguri, Siliguri	2025
Meeting		Junction, Darjiling, Siliguri-
		34001, West Bengal, India
Annual	2023-24	264, M.G. Road, Siliguri,	30 th September,	11:00 A.M.	Yes
General		Darjeeling, West Bengal-	2024
Meeting		734405
Annual	2022-23	264, M.G. Road, Siliguri,	30 th December,	12:00 Noon	No
General		Darjeeling, West Bengal-	2023
Meeting		734405

Details for Special Resolution had passed in last AGM:

2024-2025

No Special Resolution was passed. 2023-2024 Following Special Resolutions were passed:

1) Regularisation of appointment of Mrs. Sushilaben Shah (DIN: 08234697) as a Non-Executive Independent Director of the Company.

2) Regularisation of appointment of Mr. Chirag Nanavati (DIN: 08196966) as a Non-Executive Independent Director of the Company.

3) Disposal of Undertaking/Asset of the company under section 180(1)(a) of the Companies Act, 2013.

4) To approve, confirm and ratify the appointment of Statutory Auditors of the Company to fill the casual vacancy caused due to the resignation.

5) To appoint the Statutory Auditors of the Company for the term of 5 consecutive years. 2022-2023 No Special Resolution was passed. Extra Ordinary General Meeting/Postal Ballot during the year under review:

One Extra Ordinary General Meeting through Postal Ballot was held on Monday, 29 th December, 2025 to pass following resolutions:

1) Change Of Object Clause Of The Memorandum Of Association Of The Company.

2) Change Of Name Of The Company From Bansisons Tea Industries Limited to Novyra Pharmachem Limited and, Consequential Amendment In Name Clause Of The Memorandum Of Association Of The Company.

3) Disposal Of Assets Of The Company Under Section 180(1)(A) Of The Companies Act, 2013. f) Changes in Directors and Key Managerial Personnel:

Mr. Sandeep Agarwal, Director of the Company is liable to retire by rotation at the ensuing Annual General Meeting and being eligible, offer himself for re- appointment.

During the year, the company has accepted resignation of Mrs. Mamy Ghosh form the Directorship of the Company w.e.f. 19 th November, 2025 and appointed Mr. Anilkumar Mohanbhai Amreliya (DIN: 11339148) has been appointed as Additional (Executive) Director of the Company w.e.f. 06 th February, 2026.

Further in the last Annual General Meeting held in 2025, the Company has appointed M/s. D.G.M.S & Co., Chartered Accountants (FRN: 0112187W) as the Statutory Auditors of the Company for the term of 5 years. Also the company has appointed Mrs. Manjula Poddar, Practicing Company Secretaries, as Secretarial Auditor of the Company for the term of 2 consecutive years.

g) Declaration by an Independent Director(s) and reappointment, if any:

All Independent Directors have given declarations that they meet the criteria of independence as laid down under Section 149(6) of the Companies Act, 2013 and SEBI (Listing Obligations and Disclosure Requirement), Regulations, 2015.

h) Formal Annual Evaluation:

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

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

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

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

i) Remuneration Policy:

The Board has, on the recommendation of the Nomination & Remuneration Committee framed a policy for selection and appointment of Directors, Senior Management and their remuneration. The Remuneration Policy is stated under the head Nomination and Remuneration Committee.

j) Number of Meetings of the Board of Directors and Audit Committee:

A calendar of Meetings is prepared and circulated in advance to the Directors.

During the year seven Board Meetings and One Independent Directors meeting and four Audit Committee Meetings were convened and held. The intervening gap between the Meetings was within the period prescribed under the Companies Act, 2013.

23) COMMITTEES OF BOARD OF DIRECTORS:

The Company had Three Board Committees. These are as under:

I. Audit Committee II. Remuneration Committee

III. Share Transfer & Shareholders/Investor Grievance Committee

Moving with various committees formed and reported in the previous Annual Report and in line with the requirements of SEBI and Stock Exchanges, the Board has formally constituted the following committees of Directors.

I. Audit Committee:

The Audit committee constituted by the Board of directors as per the Regulation 18 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as well as in Section 177 of the Companies Act, 2013. During the year, the committee has been changed due to appointment of resignation by the Company w.e.f. 19/11/2025. Hence, now the members of the Committee presently comprises of three Members Mr. Hiren Shah (DIN: 09842161) (Chairman), Mrs. Sushilaben Shah (DIN: 08234697) and Mr. Chirag Nanavati (DIN: 08196966), who are aware with finance, accounts, management and corporate affairs. Three independent members constitute the quorum of the said Audit Committee Meeting.

The Audit Committee of the Board of Directors of the Company, Inter-alia, provides assurance to the Board on the adequacy of the internal control systems and financial disclosures.

The audit committee while reviewing the Annual Financial Accounts ensures compliance of the Accounting Standard (AS) issued by the Institute of Chartered Accountants of India.

Review the financial reporting process and disclosure of its financial information; Review with the management, Annual financial statements before submission to the Board; Review with the management, statutory Auditors and Internal Auditors and adequacy of internal control systems; Review the companys accounting and risk management policies; Review the companys accounting and management reporting systems and updates the same from time to time; Recommend the appointment and removal of statutory and Internal Auditors and fixation of fees for the same; Review quarterly financial statement; Review internal investigations made statutory/ Internal Auditors; Scope of Statutory/ Internal Audit; Review fixed deposits/repayment systems etc.; Review related party transactions.

The terms and reference of the Audit Committee covers the matters specified as per SEBI (Listing Obligations and Disclosure Requirement), Regulations, 2015 besides other terms as may be referred from time to time by the Board of Directors. The Audit Committee met four times during the year;

28/05/2025	12/08/2025	11/11/2025	26/01/2026

II. Remuneration Committee:

The Remuneration Committee shall act in accordance with the prescribed provisions of Section 178 of the Companies Act, 2013. Remuneration Committee reviews the overall compensation policy, service agreements and other employment conditions of Managing/Whole time Directors and Managing Director.

During the year, the committee has been changed due to appointment of resignation by the Company w.e.f. 19/11/2025. Hence, now the members of the Committee presently comprises of three Members Mr. Hiren Shah (DIN: 09842161) (Chairman), Mrs. Sushilaben Shah (DIN: 08234697) and Mr. Chirag Nanavati (DIN: 08196966).

Remuneration Committee constituted for the purpose of considering remuneration of executive and non-executive directors.

Non- Executive Director

The Company has not paid any sitting fees to any of the Directors of the Company.

Two Meeting of the Nomination and remuneration committee was held on 19/11/2025 and 06/02/2026 during the year under review.

Terms of reference of the Committee inter alia, include the following: Nomination of Directors / Key Managerial Personnel / Senior Management* i. To evaluate and recommend the composition of the Board of Directors; ii. To identify persons who are qualified to become Directors and who may be appointed in senior management in accordance with the criteria laid down by the Committee; iii. Consider and recommend to the Board appointment and removal of directors, other persons in senior management and key managerial personnel (KMP); iv. Determining processes for evaluating the effectiveness of individual directors and the Board as a whole and evaluating the performance of individual Directors; v. To administer and supervise Employee Stock Options Schemes (ESOS) including framing of policies related to ESOS and reviewing grant of ESOS; vi. Formulate the criteria for determining qualifications, positive attributes and independence of a Director; vii. To review HR Policies and Initiatives.

Role of the Committee:

The Committee shall: a. Formulate the criteria for determining qualifications, positive attributes and independence of a Director and recommend to the board of directors a policy relating to, the remuneration of the directors, key managerial personnel and other employees; b. Identify persons who are qualified to become Director and persons who may be appointed in Key Managerial and Senior Management positions in accordance with the criteria laid down in this Policy; c. Lay down the evaluation criteria for performance evaluation of Independent Director and the Board; d. Recommend to the Board, appointment, remuneration and removal of Director, KMP and Senior Management; e. To devise a Policy on Board diversity. f. Whether to extend or continue the term of appointment of the independent director, on the basis of the report of performance evaluation of independent directors.

Remuneration of Directors / Key Managerial Personnel / Senior Management*/ other Employees

Evolve the principles, criteria and basis of Remuneration policy and recommend to the Board a policy relating to the remuneration for all the Directors, KMP, Senior Management and other employees of the Company and to review the same from time to time.

The Committee shall, while formulating the policy, ensure the following:

The level and composition of remuneration is reasonable and sufficient to attract, retain and motivate Directors of the quality required to run the Company successfully; Relationship of remuneration to performance is clear and meets appropriate performance benchmarks; and

Remuneration to Directors, KMP and Senior Management involves a balance between fixed and incentive pay reflecting short and long term performance objectives appropriate to the working of the Company and its goals. *Senior Management for the above purpose shall mean personnel of the Company who are members of its core management team excluding Board of Directors comprising all members of management one level below the executive directors, including the functional heads.

NOMINATION & REMUNERATION POLICY:

Purpose of this Policy:

The company has adopted this Policy on appointment and remuneration of the Directors, Key Managerial Personnel and Senior Management (the Policy) as required by the provisions of Section 178 of the Companies Act, 2013 (the Act) and Regulation 19 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

The purpose of this Policy is to establish and govern the procedure applicable:

a) To evaluate the performance of the members of the Board. b) To ensure that remuneration to Directors, KMP and Senior Management involves a balance between fixed and incentive pay reflecting short and long-term performance objectives appropriate to the working of the Company and its goals. c) To retain, motivate and promote talent and to ensure long term sustainability of talented managerial persons and create competitive advantage.

The Committee should ensure that the level and composition of remuneration is reasonable and sufficient to attract, retain and motivate Directors of the quality required to run the Company successfully and the relationship of remuneration to performance is clear and meets appropriate performance benchmarks.

Definitions:

Independent Director means a director referred to in Section 149(6) of the Act and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to time.

Key Managerial Personnel (the KMP) shall mean Key Managerial Personnel as defined in Section 2(51) of the Act. Nomination and Remuneration Committee, by whatever name called, shall mean a Committee of Board of Directors of the Company, constituted in accordance with the provisions of Section 178 of the Act and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.

Remuneration means any money or its equivalent given or passed to any person for services rendered by him and includes perquisites as defined under the Income-tax Act, 1961.

Senior Management means personnel of the Company who are members of its core management team excluding Board of Directors. This would include all members of management one level below the Executive Directors, including all functional heads.

Words and expressions used and not defined in this Policy, but defined in the Act or any rules framed under the Act or the Securities and Exchange Board of India Act, 1992 and Rules and Regulations framed there under or in the SEBI (Listing Obligations and Disclosure Requirements)

Regulations, 2015 or the Accounting Standards shall have the meanings assigned to them in these regulations.

Criteria for Determining the followings:-

1 Qualifications for appointment of Directors (including Independent Directors) a) Persons of eminence, standing and knowledge with significant achievements in business, professions and/or public service; b) Their financial or business literacy/skills; c) Other appropriate qualification/experience to meet the objectives of the Company; d) As per the applicable provisions of Companies Act, 2013, Rules made there under and SEBI

(Listing Obligations and Disclosure Requirements) Regulations, 2015.

The Nomination and Remuneration Committee shall have discretion to consider and fix any other criteria or norms for selection of the most suitable candidate/s.

2 Positive attributes of Directors (including Independent Directors):

Directors are to demonstrate integrity, credibility, trustworthiness, ability to handle conflict constructively and the willingness to address issues proactively; Actively update their knowledge and skills with the latest developments in the railway/heavy engineering/infrastructure industry, market conditions and applicable legal provisions; Willingness to devote sufficient time and attention to the Companys business and discharge their responsibilities; To assist in bringing independent judgment to bear on the Boards deliberations especially on issues of strategy, performance, risk management, resources, key appointments and standards of conduct; Ability to develop a good working relationship with other Board members and contribute to the Boards working relationship with the senior management of the Company; To act within their authority, assist in protecting the legitimate interests of the Company, its shareholders and employees; Independent Directors to meet the requirements of the Companies Act, 2013 read with the Rules made there under and SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended from time to time.

3 Independence Standards

The following would be the independence review procedure and criteria to assist the Committee to evaluate the independence of Directors for recommending to the Board for appointment. A Director is independent if the Board affirmatively determines that the Director does not have a direct or indirect material relationship with the Company, including its affiliates or any member of senior management. Affiliate shall mean any company or other entity that controls, is controlled by, or is under common control with the Company.

Also, the candidate shall be evaluated based on the criteria provided under the applicable laws including Companies Act, 2013 read with Rules thereon and the Listing Agreement with the Stock Exchanges. In addition to applying these guidelines, the Board will consider all relevant facts and circumstances in making its determination relating to a directors independence.

Independence Review Procedures

1. Annual Review

The directors independence for the independent director will be determined by the Board on an annual basis upon the declaration made by such Director as per the provisions of the Companies Act, 2013 read with Rules thereon and the Listing Agreement.

2. Individual Directors Independence Determinations

If a director nominee is considered for appointment to the Board between Annual General Meetings, a determination of independence, upon the recommendation of the Committee, shall be made by the Board prior to such appointment.

All determinations of independence shall be made on a case-by-case basis for each director after consideration of all the relevant facts and circumstances and the standards set forth herein. The Board reserves the right to determine that any director is not independent even if he or she satisfies the criteria set forth by the provisions of the Companies Act, 2013 read with Rules thereon and the Listing Agreement.

3. Notice of Change of Independent Status

Each director has an affirmative obligation to inform the Board of any change in circumstances that may put his or her independence at issue.

Criteria for appointment of KMP/Senior Management

To possess the required qualifications, experience, skills & expertise to effectively discharge their duties and responsibilities; To practice and encourage professionalism and transparent working environment; To build teams and carry the team members along for achieving the goals/objectives and corporate mission; To adhere strictly to code of conduct

Term

The Term of the Directors including Managing / Whole time Director / Independent Director shall be governed as per the provisions of the Act and Rules made there under and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to time. Whereas the terms of the KMP (other than the Managing/Whole time Director) and Senior Management, shall be governed by the prevailing H R policies of the Company.

Evaluation

The Committee shall carry out evaluation of performance of every Director. The Committee shall identify evaluation criteria which will evaluate Directors based on knowledge to perform the role, time and level of participation, performance of duties, level of oversight, professional conduct and independence. The appointment / re- appointment / continuation of Directors on the Board shall be subject to the outcome of the yearly evaluation process.

Removal

Due to reasons for any disqualification mentioned in the Act or under any other applicable Act, Rules and Regulations there under and / or for any disciplinary reasons and subject to such applicable Acts, Rules and Regulations and the Companys prevailing HR policies, the Committee may recommend, to the Board, with reasons recorded in writing, removal of a Director, KMP or Senior Management.

Remuneration of Managing / Whole-time Director, KMP and Senior Management

The remuneration / compensation / commission, etc., as the case may be, to the Managing / Whole time Director will be governed by the relevant provisions of the Companies Act, 2013 and applicable Rules and Regulations and will be determined by the Committee and recommended to the Board for approval. The remuneration / compensation / commission, etc., as the case may be, shall be subject to the prior / post approval of the shareholders of the Company and Central Government, wherever required. Further, the Chairman & Managing Director of the Company is authorised to decide the remuneration of KMP (other than Managing / Whole time Director) and Senior Management based on the standard market practice and prevailing HR policies of the Company.

Remuneration to Non-executive / Independent Director

The remuneration / commission / sitting fees, as the case may be, to the Non-Executive / Independent Director, shall be in accordance with the provisions of the Act and the Rules made there under for the time being in force or as may be decided by the Committee / Board / shareholders. An Independent Director shall not be entitled to any stock option of the Company unless otherwise permitted in terms of the Act and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to time.

III. Share Transfer & Shareholders/Investor Grievance Committee:

During the year, the committee has been changed due to appointment of resignation by the Company w.e.f. 19/11/2025. Hence, now the members of the Committee presently comprises of three Members Mr. Hiren Shah (DIN: 09842161) (Chairman), Mrs. Sushilaben Shah (DIN: 08234697) and Mr. Chirag Nanavati (DIN: 08196966).

The committee is responsible for approving and monitoring transfers, transmission, splitting and consolidation of shares issued by the Company. In addition to that, the committee also monitors redressal of complaints from shareholders relating to transfer of shares, non-receipt of balance sheet etc., No sitting fees is paid to the committee members. The Committee reviewed redressal of investors Grievances pertaining to share transfer, dematerialization of shares, replacement of lost, mutilated and old share certificates, change of address etc. The committee has also taken steps to strengthening investors relations.

The meetings of the members of Share Transfer and Share Holder Grievance Committee were held on below mentioned date, met four times during the year;

28/04/2025	17/07/2025	30/10/2025	29/01/206

The status of shareholders complaints received so far/number not solved to the satisfaction of shareholders/number of pending share transfer transactions (as on 31 st March, 2026) is given below:-

Complaints Status: 01.04.2025 to 31.03.2026

Number of complaints received so far: 19 Number of complaints solved: 19 Number of pending complaints: 0

IV. Compliance Officer:

Ms. Nisha Gattani is Compliance Officer of the company for the purpose of complying with various provisions of Securities and Exchange Board of India (SEBI), Listing Agreement with Stock Exchanges, Registrar of Companies and for monitoring the share transfer process etc. a) Share Transfer System: All the transfers are received and processed by share Transfer agents and are approved by share transfer committee. Share Transfer requests received in physical form are registered within 30 days and demat requests are confirmed within 15 days.

b) Dematerialization of shares and liquidity: Details of Registrar and Share Transfer agent of the Company for dematerialization of shares: Name : M/s. S. K. Infosolutions Pvt. Ltd Address : D/42, Katju Nagar (Near South City Mall), Ground Floor, Katju Nagar Bazar, Jadavpur, Kolkata -700032. Tel : +91-9608398301, Email : contact@skcinfo.com

24) STATEMENT CONCERNING DEVELOPMENT AND IMPLEMENTATION OF RISK MANAGEMENT POLICY

OF THE COMPANY:

Risk management is embedded in your companys operating framework. Your company believes that managing risk helps in maximizing returns. The companys approach to addressing business risk is comprehensive and includes periodic review of such risks and a framework for mitigating controls and reporting mechanism of such risks. The risk management framework is reviewed periodically by the Board and the Audit Committee. Some of the risks that the company is exposed to are:

Commodity Price Risks

The Company is exposed to the risk of price fluctuation of raw material as well as finished goods. The company proactively manages these risks through forward booking, Inventory management and proactive vendor development practices. The Companys reputation for quality, product differentiation and service, coupled with existence of powerful brand image with robust marketing network mitigation the impact the impact of price risk on finished goods.

Regulatory Risks

The company is exposed to risks attached to various statues and regulations including the company Act. The company is mitigating these risks through regular review of legal compliances carried out through internal as well as external compliance audits.

Human Resources Risks

Retaining the existing talent pool and attracting new talent are major risks. The company has initialled various measures including rolling out strategic talent management system, training and integration of learning and development activities.

Strategic Risks

Emerging businesses, capital expenditure for capacity expansion, etc., are normal strategic risk faced by the company. However, the company has well-defined processes and procedures for obtaining approvals for investments in new business and capacity expansion etc.

25) AUDIT TRAIL APPLICABILITY (AUDIT AND AUDITORS) RULES 2014 - RULE 11 OF THE COMPANIES ACT, 2013:

The Company has used accounting software for maintaining its books of account for the financial year ended March 31, 2026 which has a feature of recording audit trail (edit log) facility and the same has operated throughout the year for all relevant transactions recorded in the softwares.

26) CORPORATE GOVERNANCE:

SEBI vide its circular no. CIR/CFD/POLICY CELL/2/2014 dated 17th April, 2014 had amended Erstwhile Regulation 27(2) and made it applicable to all the listed Companies. Further, SEBI vide its circular no. CIR/CFD/POLICY CELL/7/2014 dated 15 th September, 2014 read with Regulation 34(3) read with Schedule V of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 had made the provisions of Corporate Governance non-mandatory to the following class of Companies:

a) Companies having paid up equity share capital not exceeding Rs.10 crores and Net worth not exceeding Rs.25 crores, as on the last day of the previous financial year; Provided that where the provisions of Regulation 27(2) becomes applicable to a company at a later date, such company shall comply with the requirements of Regulation 27(2) within six months from the date on which the provisions became applicable to the company.

b) Companies whose equity share capital is listed exclusively on the BSE Platform. Accordingly the paid up capital and net worth is below the prescribed limit for mandatory applicability of Corporate Governance clause. The Company has decided not to opt for compliance of Erstwhile Regulation 27(2) for the time being.

27) DIRECTORS RESPONSIBILITY STATEMENT:

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

a. That in the preparation of the annual financial statements for the year ended March 31, 2026, the applicable accounting standards have been followed along with proper explanation relating to material departures, if any; b. That such accounting policies have been selected and applied consistently and judgment and estimates have been made that are reasonable and prudent so as to give a true and fair view of the state of affairs of the Company as at March 31, 2026 and of the profit of the Company for the year ended on that date; c. that proper and sufficient care has been taken for the maintenance of adequate accounting records in accordance with the provisions of the Companies Act, 2013 for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities; d. that the annual financial statements have been prepared on a going concern basis; e. that proper internal financial controls were in place and that the financial controls were adequate and were operating effectively; f. that systems to ensure compliance with the provisions of all applicable laws were in place and were adequate and operating effectively.

28) CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE:

The details of conservation of energy, technology absorption etc. as required to be given under Section 134(3)(m) of the Companies Act, 2013 read with Rule, 8 of The Companies (Accounts) Rules, 2014, are not applicable to Company, as our Company has not carried out in the manufacturing activities. The foreign exchange earnings on account of the operation of the Company during the year is Rs. Nil.

29) RELATED PARTY TRANSACTIONS:

There were no materially significant related party transactions made by the Company with Promoters, Directors, Key Managerial Personnel or other designated persons which may have a potential conflict with the interest of the Company at large.

30) SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS:

There are no significant material orders passed by the Regulators / Courts which would impact the going concern status of the Company and its future operations.

31) DETAIL OF FRAUD AS PER AUDITORS REPORT:

There is no fraud in the Company during the Financial Year ended 31 st March, 2026. This is also being supported by the report of the auditors of the Company as no fraud has been reported in their audit report for the financial year ended 31 st March, 2026.

32) BOARDS COMMENT ON THE AUDITORS REPORT:

There were no qualifications, reservations or adverse remarks made by Auditors in their respective reports. Observation made by the Statutory Auditors in their Report are self- explanatory and therefore, do not call for any further comments under section 134(3) (f) of the Companies Act, 2013.

33) COST AUDITOR AND COST AUDIT REPORT: Cost Audit is not applicable to your Company. 34) AUDITORS: A. Statutory Auditors:

In terms of Section 139 of the Companies Act, 2013 (the Act), and the Companies (Audit and Auditors) Rules, 2014, made thereunder, the present Statutory Auditors of the Company M/s. D.G.M.S & Co., Chartered Accountants (FRN: 0112187W), has been appointed, confirmed and ratified as the Statutory Auditors of the Company for the term of 5 years from the conclusion of this 38 th Annual General Meeting until the conclusion of the 43 rd Annual General Meeting to be held in the year 2030 on such remuneration plus applicable taxes, and out of pocket expenses, as may be recommended by the Audit Committee and as may be mutually agreed between the Board of Directors of the Company and the Statutory Auditors from time to time.

B. Internal Auditor

The Company has appointed internal auditors of the company.

C. Secretarial Audit:

Pursuant to the provisions of Section 204 of the Companies Act, 2013 and The Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, the Company has appointed Mrs. Rupal Patel (FCS - 6275), Practicing Company Secretary, to undertake the Secretarial Audit of the Company. The Secretarial Audit Report is annexed herewith as Annexure -B.

Reply to the qualification Remarks in Secretarial Audit Report:

Sr. No. Remarks	Reply
1. The Company has not published notice of meeting of the board of directors where financial results shall be discussed and financial results, as required under Regulation 47 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.	The company has take note of the same and company is in process of compliance of the same.
2. BSE Limited has imposed fines for Delayed Submission of compliances under various regulations of SEBI LODR during the year under review.	The Company has started to comply with all pending compliances and planning to apply for waiver of the fine. It was held due to certain technical issues.
3. The Company is SDD (Database of designated Persons) non-compliant during the year under review.	The Company has installed designed software, entered all data and complied with the same as on date of this Report.
4. The Exchange vide email dated September 8, 2023, has requested all listed entities to submit the details of its Statutory Auditors by September 18, 2023. It has been observed that the Company has still not submitted the said details.	The company has taken serious note of the same and complied with as on date of this Report.
5. 100% promoter holding is not in demat form as required under Regulation 31(2) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.	The company has taken serious note of the same and company is in process of compliance with the dematerialization of the shares of the promoters.
6. It has been observed that there are partly paid up shares in the audited books of accounts of the Company, which become fully paid up during the year under review	On 28 th March, 2025 and 9th June, 2025, the Board of Directors of the Company has converted the partly paid-up equity shares of the Company having face value of 10/- each, on which 2.50 per share has already been paid- up, in respect of 1,76,600 partly paid-up shares issued by the Company and thereby the paid up share capital of the Company became fully paid-up share capital of the Company 6,33,00,000 (Rupees Six Crore Thirty- Three Lakh only) divided into 63,30,000 (Sixty-Three Lakh Thirty Thousand) equity shares of 10/- each.

35) PROCEEDINGS UNDER INSOLVENCY AND BANKRUPTCY CODE, 2016:

During the year under review, there were no proceedings that were filed by the Company or against the Company, which are pending (except the previous years which was already disclosed) under the Insolvency and Bankruptcy Code, 2016 as amended, before National Company Law Tribunal or other Courts.

36) DETAILS OF DIFFERENCE BETWEEN VALUATION AMOUNT ON ONE TIME SETTLEMENT AND

VALUATION WHILE AVAILING LOAN FROM BANKS AND FINANCIAL INSTITUTIONS:

During the year under review, there has been no one time settlement of loans from the Bank or Financial Institutions

37) MANAGEMENT DISCUSSION AND ANALYSIS:

Management discussion and analysis Report, pursuant to Schedule V of the SEBI (Listing Obligations and Disclosure Requirement), Regulations, 2015, forms part of this Report and the same is annexed hereto as Annexure-C.

38) SEGMENT:

Your Company is engaged in a single segment only.

39) EXTRACT OF THE ANNUAL RETURN:

Pursuant to Sub-section 3(a) of Section 134 and Sub-section (3) of Section 92 of the companies Act 2013, read with Rule 12 of Companies (Management and Administration) Rules, 2014, the copy of the Draft Annual Return of the Company for the Financial year ended on March, 31 st 2026 in Form MGT-9 is uploaded on website of the company and can be accessed at www.bansisonstea.in

40) DISCLOSURE AS PER SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (PREVENTION, PROHIBITION

AND REDRESSAL) ACT, 2013:

The Company has zero tolerance for sexual harassment at workplace and has adopted a policy against sexual harassment in line with the provisions of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the rules framed there under.

Since there are no women employees in the Company, hence during the financial year 2025-26, the company has not received any complaints on sexual harassment and hence no complaints remain pending as of 31 st March, 2026.

41) MATERNITY BENEFIT PROVIDED BY THE COMPANY UNDER MATERNITY BENEFIT ACT 1961:

The Company declares that it has duly complied with the provisions of the Maternity Benefit Act, 1961. All eligible women employees have been extended the statutory benefits prescribed under the Act, including paid maternity leave, continuity of salary and service during the leave period, and post-maternity support such as nursing breaks and flexible return-to-work options, as applicable. The Company remains committed to fostering an inclusive and supportive work environment that upholds the rights and welfare of its women employees in accordance with applicable laws.

42) DISCLOSURE UNDER SECTION 197(12) OF THE COMPANIES ACT, 2013 AND OTHER DISCLOSURES AS

PER RULE 5 OF COMPANIES (APPOINTMENT & REMUNERATION) RULES, 2014:

Pursuant to Section 197(12) of the Companies Act, 2013 and Rule 5 of Companies (Appointment & Remuneration) Rules, 2014, every Listed Company mandates to disclose in the Boards Report the ratio of the remuneration of each director to the permanent employees remuneration. However, since there is no permanent employee in the Company, no disclosure under the said provision has been furnished.

43) DISCLOSURES:

a) Materially significant related party transactions:

The same are appropriate disclosed in the note forming parts of the financial statement.

b) During the last three Years, there were no penalties, strictures imposed by either SEBI or stock Exchange or any statutory authority for non- Compliance of any matter related to the capital market.

Share Transfer System:

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

Dematerialization of shares and liquidity:

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

Name:	S. K. INFOSOLUTIONS PVT. LTD.
Address:	34/1A Sudhir Chatterjee Street, Kolkata, West Bengal,700006.
Tel:	033-22194815,22196797
Fax:	033-22194815
Email:	skcdilip@gmail.com ; contact@skcinfo.com
Date, Time and venue of	: 25 th June, 2026 at 11.00 A.M.
Annual General Meeting	:Through Video Conferencing/ Other Audio-Visual Means
	(VC/OAVM). The venue of the Meeting shall be deemed to
	be at its registered office.

44) MEANS OF COMMUNICATIONS:

The half Yearly and quarterly results of the Company were not published in any newspaper but regularly forwarded to the Bombay Stock Exchange where the Companys share are listed. The Company has not considered it necessary to circulate half yearly results at the residence of shareholders as there is no significant up and down in the activities of the company having material impact on the shareholders interest.

The Companys financial results and officials news releases are displayed on the Companys website i.e. www.bansisonstea.in

Further the Company has not made any presentation to any financial institutional Investors/analysts or banks during the year.

Listing of Equity Shares on Stock Exchanges: BSE Limited: a. Stock Code: BSE 519353 b. Demat ISIN number: INE856E01019

c. Market price data :

High / Low of Monthly Market Price of the Companies Equity Shares traded on Bombay Stock Exchange during the financial year 2025-26:-

Month	BSE		BSE SENSEX
	High (Rs.)	Low (Rs.)	High (Rs.)	Low (Rs.)
April 2025	5.60	5.60	80,661.31	71,425.01
May 2025	--	--	82,718.14	78,968.34
June 2025	5.60	5.60	84,099.53	80,354.59
July 2025	--	--	83,935.01	80,575.45
August 2025	--	--	82,231.17	79,741.76
September -2025	--	--	83,141.21	79,818.38
October -2025	8.23	5.88	85,290.06	80,159.9
November 2025	13.35	8.64	86,055.86	82,670.95
December 2025	15.55	13.60	86,159.02	84,150.19
January 2026	15.86	15.86	85,883.5	81,088.59
February 2026	15.86	15.86	85,871.73	79,899.42
March 2026	16.55	14.97	80,632.55	71,774.13

d. Registered and Transfer Agent: The Company has Appointed S. K. Infosolutions Private Limited as the common agency both in respect of demat shares.

e. Share Transfer System: Valid Share transfer in physical form and complete in all respects were approved and registered within the stipulated period. Dividend Payment Date (Proposed): Dividend, if any will be paid within the stipulated period after its declaration by the members at the AGM. No dividend proposed for FY 2025-2026.

Shareholding pattern as on 31 st March, 2026:-

Category	No. of share held	% of Holding
a) Promoters and persons who may be deemed to be acting	14,65,700	23.15
in concert including promoter/directors group Companies
b) Financial Institutions/ Banks	0	0
Other Bodies Corporate	18,800	0.30
c) NRI, HUF, Firm	500	0.01
d) Any other	22,700	0.36
e) Indian public	48,22,300	76.19
Total	63,30,000	100.00

Dematerialization of shares: As on 31-03-2026, Demat shares accounted for 4,82,505 Equity Shares of total equity.

Listing on Stock Exchanges : BSE Limited

Phiroze

Jeejeebhoy Towers, Dalal Street, Mumbai 400023

Address for Correspondence:

Novyra Pharmachem Limited (Formerly Known As Bansisons Tea Industries Limited, R S No 432, T P Scheme No 3, F P No 89/A, City Survey No 3763, Plot No C, Palky Plot No A, Ground Floor, Back Side, Pavthawala Compound B/h Zenith Mill, Vastadevadi Road, Surat, Gujarat, 395004, India Website: www.bansisonstea.in Email: bansisonstea@gmail.com Tel.: +91 92654 53481

S. K. Infosolutions Private Limited

34/1A Sudhir Chatterjee Street, Kolkata, West Bengal,700006. Tel.: 033-22194815,22196797 Fax: 033-22194815 Email: skcdilip@gmail.com; contact@skcinfo.com

Financial Calendar:

1 st quarterly results Second week of August, 2026 2 nd quarterly results Second week of November, 2026 3 rd quarterly results Second week of February, 2027 4 th quarterly results Second week of May, 2027

Date of Book Closure: June 19 th 2026 to June 25 th 2026 (both days inclusive)

45) MATERIAL CHANGES AND COMMITMENT:

No material changes and commitments affecting the financial position of the company occurred between the ends of the financial year to which these financial statements relate on the date of this report.

46) CORPORATE SOCIAL RESPONSIBILITY (CSR):

The Company has not developed and implemented any Corporate Social Responsibility initiative under the provisions of Section 135 of the Companies Act, 2013, read with Rule 9 of Companies (Corporate Social Responsibility Policy) Rules, 2014, as the said provisions are not applicable.

47) DETAILS IN RESPECT OF ADEQUACY OF INTERNAL FINANCIAL CONTROLS WITH REFERENCE TO THE

FINANCIAL STATEMENTS:

The Company has adequate of internal financial controls with reference to the Financial Statements during the year under review.

48) SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (POSH):

Though the Company has less than 10 employees and it is not required to constitute Internal Complaints Committee (ICC) pursuant to the legislation Prevention, Prohibition and Redressal of Sexual Harassment of Women at Workplace Act 2013, it has adopted a policy

49) SECRETARIAL STANDARDS:

The Directors State that applicable Secretarial Standards i.e. SS-1 and SS-2 relating to Meetings of the Board of Directors and General Meetings, respectively, have been duly followed by the Company.

50) ACKNOWLEDGEMENT:

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

	By Order of the Board of Directors
	For Novyra Pharmachem Limited
	(Formerly known as Bansisons Tea Industries Limited)
Date: 16/05/2026
Place: Surat
	Sandeep Agarwal	Anilkumar Amreliya
	Whole-time Director	Managing Director
	DIN: 00688647	DIN: 11339148