Comfort Commotrade Ltd Directors Report.

To the Members of the Company,

Your Directors have pleasure in presenting the 14th (Fourteenth) Annual Report of Comfort Commotrade Limited (‘the Company’) along with the Audited Financial Statements (Consolidated and Standalone) of your Company for the financial year ended March 31, 2021.

1) FINANCIAL HIGHLIGHTS

A Summary of the consolidated and standalone financial performance of the Company, for the Financial Year ended March 31, 2021 ("the F.Y."), is as under: ( In Lakhs)

PARTICULARS

Standalone

Consolidated

March 31, 2021 March 31, 2020 March 31, 2021 March 31, 2020
Revenue from Operations 7,891.12 3,520.81 7,923.50 3,597.27
Other operating Income 125.36 37.62 125.90 38.85
Total Revenue 8,016.48 3,558.43 8,049.41 3,636.12
Total Expenses 6,612.16 3,301.17 6,656.43 3,389.73
Profit before Tax 1,404.31 257.25 1,392.98 246.39
Current Tax Expenses 206.92 86.05 206.92 86.05
Deferred Tax (0.39) (0.79) (0.39) (0.79)
Tax of earlier years 4.08 0.29 4.08 0.29
Profit for the Year 1,193.71 171.70 1,182.38 160.83
Earnings Per Share (EPS in ) 11.91 1.71 11.80 1.61

2) CONSOLIDATED FINANCIAL STATEMENTS

In accordance with the provisions of section 129 and 133 of Companies Act, 2013 (hereinafter referred to as "the Act") read with the Companies (Accounts) Rules, 2014 and Regulation 33 of the Securities and Exchange Board of India, SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (hereinafter referred to as "SEBI Listing Regulation") and applicable Accounting Standards, the Audited Consolidated Financial Statements of the Company for the F.Y., together with the Auditors’ Report form part of this Annual Report.

The Consolidated and Standalone Financial Statements of the Company for the F.Y. have been prepared in accordance with applicable Indian Accounting Standards and the relevant provisions of the Act.

3) FINANCIAL PERFORMANCE

At Standalone Level, the revenue from operations has increased to 7,891.12 Lakhs for the F.Y. as compared to 3,520.81 Lakhs in the Previous Year. The Net Profit for the F.Y. increased to 1,193.71 Lakhs against 171.70 lakhs reported in the Previous Year.

The Consolidated revenue from operations for the F.Y. has increased to 7,923.50 Lakhs as compared to 3,597.27 Lakhs in the Previous Year. The Net Profit for the F.Y. has increased to 1,182.38 Lakhs as against 160.83 Lakhs in the Previous Year.

In accordance with the provisions contained in section 136 of the Companies Act, 2013, the Annual Report of the Company, containing Notice of the Annual General Meeting, Consolidated and Standalone Financial Statements, Report of the Auditor’s and Board of Directors thereon are available on the website of the Company atwww.comfortcommotrade. com. Further, a detailed analysis of Company’s performance is included in the Management Discussion and Analysis Report ("MDAR"), which forms part of this Annual report.

4) DIVIDEND

Based on the Company’s financial performance for the year 2020-21 and in order to conserve resources to face the challenges and the contingencies due to current pandemic, the Board of Directors have not recommended any dividend on equity shares for the financial year 2020-21.

5) SHARE CAPITAL

During the year under review, there have been no changes in share capital of the Company. The issued, subscribed and paid-up Equity Share Capital of the Company as on March 31, 2021 was 10,02,00,000/- (Rupees Ten Crores Two Lakhs Only) divided into 1,00,20,000 Equity Shares of 10 each. Further, there was no public issue, rights issue, bonus issue or preferential issue, etc. during the year. The Company has not issued shares with differential voting rights or sweat equity shares, nor has it granted any stock options during the F.Y.

6) RESERVES AND SURPLUS

The Company has not transferred any amount to the Reserves for the financial year ended March 31, 2021. The closing balance of retained earnings of the Company for F.Y. 2020-21, after all appropriation and adjustments was 1,641.29 lakhs.

7) LISTING WITH THE STOCk EXCHANGE(S)

Your Company’s equity shares are listed on The BSE Limited. Annual listing fees for the Financial Year 2020-21 and 2021-22 have been paid to BSE Limited (Scrip Code: 534691) where the shares of the company are listed.

8) SUBSIDIARIES, jOINT VENTURES AND ASSOCIATES COMPANIES

Your Company has One Wholly Owned Subsidiary Company namely, Anjali Tradelink FZE as on March 31, 2021. There are no associates or joint venture companies within the meaning of Section 2(6) of the Act. There has been no material change in the nature of the business of the subsidiary.

Pursuant to sub-section (3) of section 129 of the Act read with Rule 5 of the Companies (Accounts) Rules, 2014, the statement containing the salient features of the financial statement of a Company’s subsidiary in FORM AOC-1 is attached as Annexure-1 of this Report.

9) DEPOSITS

The Company has not accepted any deposits under Chapter V of the Act during the financial year and as such, no amount on account of principal or interest on deposits from public is outstanding as on March 31, 2021.

10) MATERIAL CHANGES AND COMMITMENTS AFFECTING THE FINANCIAL POSITION OF THE COMPANY

No material changes and commitments occurred after the close of the financial year 2020-21 till the date of this Report which affects the financial position of the Company. However, during the year, the Company has altered Main Object Clause and Incidental or Ancillary Object of Memorandum of Association ("MOA") of the Company vide resolution passed my members at Extra-ordinary General Meeting held on March 24, 2021. It is hereby confirmed that there has been no other change in the nature of business of the Company.

Further, the COVID-19 pandemic has emerged as a global challenge, creating disruption across the world. Inspite of the unprecedented situation, your Company has been successful in averting potential adverse impact on the business and on the contrary has grown; and continues to outperform most of the industry peers. Based on the facts and circumstances, the company has been operating in normal course and there have been no adverse impacts on the liquidity, revenues or operational parameters during the F.Y. Most of your Company’s costs are flexible; and have been managed prudently. In stark contrast to the general perception, this unprecedented crisis has hastened the adoption of digital processes and systems across the entire country and the industry.

11) CORPORATE GOVERNANCE

Pursuant to Regulation 34(3) read with Schedule V of the SEBI Listing Regulations, a separate section on Corporate Governance practices followed by the Company, together with a Certificate from Practicing Company Secretary confirming compliance conditions, forms an integral part of this Report.

A declaration with respect to the compliance with the Code of Conduct duly signed by the Wholetime Director & Chief Financial Officer of the Company also forms part of this Report.

12) BOARD OF DIRECTORS AND kEY MANAGERIAL PERSONNEL’S

The Company recognizes and embraces the importance of a diverse Board in its success. We believe that a truly diverse Board will leverage differences in thought, perspective, knowledge, skills, regional and industry experience, cultural and geographical backgrounds, age and ethnicity, that will help us to retain competitive advantage.

The details of the Directors, their meetings held during the year and the extracts of the Nomination and Remuneration Policy has been given in the Corporate Governance, which forms part of this report.

I. Board of Directors

Following were the Directors as on the date of Directors Report:

Sr. No. Name of the Person DIN Category
1. Mr. Rajeev Kumar Pathak 08497094 Whole-time Director
2. Mr. Ankur Agrawal 06408167 Non-executive Non-independent Director
3. Mr. Devendra Lal Thakur 00392511 Non-executive Independent Director
4. Mr. Milin Ramani 07697636 Non-executive Independent Director
5. Mrs. Apeksha Kadam 08878724 Additional Director (Non-executive Non Independent Woman Director)

Further, following changes took place in the Board of Directors during the F.Y.

a) Cessation of Directors

Ms. Divya Padhiyar (DIN: 08598655) – Independent Director of the Company has resigned with effect from February 12, 2021. Further, pursuant to Regulation 30 of SEBI Listing Regulations, she stated that there was no material reason other than personal and unavoidable circumstances mentioned in her resignation letter.

b) Appointment/Re-appointment of Directors

Pursuant to Regulation 17 of the SEBI Listing Regulations read with sections 149 and 161 of the Companies Act, 2013 and based on recommendation of Nomination and Remuneration Committee, the Board of Directors of the Company, appointed Mrs. Apeksha Santosh kadam (DIN: 08878724) as an Additional Woman Director w.e.f. February 12, 2021 to hold office up to the date of forthcoming Annual General Meeting ("AGM"). Further, the Nomination and Remuneration committee has recommended to regularise her as an Non-Executive Director of the Company at ensuing Annual General Meeting. The Company has received requisite declarations from her. The Board recommends the same for the approval of shareholders at ensuing AGM.

Pursuant to section 149 of the Companies Act, 2013 and based on the recommendation of Nomination and Remuneration Committee, the board of Directors, it is propose to re-appoint Mr. Devendra Lal Thakur (DIN: 00392511) as Non- Executive Independent director of the Company w.e.f. November 24, 2020. Further, the Company has received all the requisite declaration to re-appoint him as an Independent director of the Company.

c) Retirement by Rotation

Pursuant to provisions of section 152(6) of the Companies Act, 2013, Mr. Ankur Anil Agrawal is liable to retire by rotation at ensuing AGM and being eligible, has offered himself for re-appointment. The Board recommends the same for the approval of shareholders at ensuing AGM.

None of the Directors are disqualified for being appointed as the Director of the Company in terms of Section 164 of the Companies Act, 2013. The company has received declaration from all the Independent Directors confirming that they meet the criteria of Independence as prescribed under section 149(6) of the Companies Act, 2013 and Regulation 16 read with Regulation 25(8) of the SEBI Listing Regulations. The Independent Directors have confirmed that they are not aware of any circumstances or situation, which exists or reasonably anticipated that could impair or impact his/her ability to discharge his/her duties with an objective independent judgment and without any external influence.

In the opinion of the board, the independence directors possess the requisite expertise and experience and are the person of integrity and repute. They fulfill the Conditions specified in the Companies Act, 2013 and the rules made thereunder and are independent of the management. Further, all the independent directors on the Board of the Company have complied with the provisions of Section 150 of the Companies Act, 2013.

II. key Managerial Personnel’s (kMP’s)

The following are the Key Managerial Personnel’s of the Company as on the date of Directors Report:

Sr. No. Name of the kMP’s Designation
1 Mr. Rajeev Pathak Whole Time Director & Chief Financial Officer
2 Ms. Dolly Karia Company Secretary

Changes in key Managerial Personnel’s

During the year under review, Mr. Shrikant Tiwari has resigned as Chief Financial Officer of the Company with effect from October 26, 2020.

Post the Financial year under review, the Board of Directors of the Company, on recommendation of Nomination and Remuneration Committee had considered and approved the appointment of Mr. Rajeev Pathak as Chief Financial Officer of the Company with effect from June 21, 2021.

III. Director’s Evaluation

In terms of the requirement of the Companies Act, 2013, an annual performance evaluation of the Board is undertaken where the Board formally assesses its own performance with the aim to improve the effectiveness of the Board and the Committees.

The Board and the Nomination and Remuneration Committee reviewed the performance of individual directors on the basis of criteria such as the contribution of the individual director to the board and committee meetings like preparedness, on the issues to be discussed, meaningful and constructive contribution and inputs in meetings, etc. The performance evaluation of the Independent Directors was carried out by the entire Board excluding the independent director being evaluated.

In a separate meeting of Independent Directors held on February 12, 2021, the performance evaluation of the Board as whole, Chairman of the Company and the Non Independent Directors was evaluated. The Board of Directors expressed their satisfaction with the evaluation process based on the recommendation of the Nomination & Remuneration Committee.

IV. Familiarization program for Independent Director(s)

The familiarization program aims to provide the Independent Directors their roles, responsibilities in the Company, nature of the industry, business model, processes & policies and the technology and the risk management systems of the Company, the operational and financial performance of the Company, significant development so as to enable them to take well informed decisions in timely manner. The policy on Company’s familiarization program for independent directors is hosted on the Company’s website.

V. Meeting of the Board and Committees of the Board of Directors:

The Board has 3 established following Committees during the FY:

1) Audit Committee;

2) Nomination and Remuneration Committee and

3) Stakeholders’ Relationship Committee.

Details of the Board and its Committees along with their amended charters, composition, meetings held during the year are given under Corporate Governance Report appearing elsewhere as a separate section in this Annual Report.

13) NOMINATION AND REMUNERATION POLICY

The Company has a Nomination and Remuneration Policy for Directors and Senior Managerial Personnel approved by the Nomination and Remuneration Committee and the Board. The policy is available at the website of the Company at www.comfortcommotrade.com. The purpose of the said Policy is to establish and govern the procedure applicable:

To evaluate the performance of the members of the Board.

To ensure remuneration payable to Director’s KMP’s & other Senior Management strike appropriate balance and commensurate among others with the functioning of the Company and its long term objectives.

To retain, motivate and promote talent within the Company and to ensure long term sustainability of the managerial persons and create competitive advantage.

The policy inter-alia covers the Directors’ appointment and remuneration, Key Managerial Personnel’s and other senior management appointment and remuneration.

14) DIRECTOR’S RESPONSIBILITY STATEMENT

Pursuant to sub- section (5) of section 134 of the Companies Act, 2013 and to the best of their knowledge and belief and according to the information and explanations obtained / received from the operating management, your Directors make the following statement and confirm that-

i. In the preparation of the annual accounts for the year ended March 31, 2021, the applicable accounting standards have been followed and there are no material departures.

ii. The Directors have selected such accounting policies and applied them consistently and made judgments and estimates that were reasonable and prudent so as to give a true and fair view of the state of affairs of the Company at the end of the financial year and of the profit of the Company for the year under review.

iii. The Directors have taken proper and sufficient care for the maintenance of adequate accounting records in accordance with the provisions of this Act for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities.

iv. The Directors have prepared the annual accounts on a going concern basis.

v. The Directors had laid down internal financial controls to be followed by the company and that such internal financial controls are adequate and were operating effectively.

vi. The Directors had devised proper system to ensure compliance with the provisions of all applicable laws and that such system were adequate and operating effectively.

15) AUDITORS

a) Statutory Auditor

M/s. Gupta Shyam & Co. - Chartered Accountants, (FRN 103450W), was appointed as the statutory auditors of the Company to hold office for a period of five consecutive years i.e. from the conclusion of the 10th AGM of the Company till the conclusion of the 15th AGM to be held in the year 2022. The requirement for the annual ratification of auditors’ appointment at every AGM has been omitted pursuant to Companies (Amendment) Act, 2017 notified on May 7, 2018. During the year, the statutory auditors have confirmed that they satisfy the independence criteria as required under the Companies Act, 2013

Further, the Auditors have issued modified opinion on the Financial Statements for the financial year ended March 31, 2021 as mentioned below:

The Company has not provided for defined benefit obligation in the nature of gratuity based on the requirement of Ind AS 19 i.e. "Employee Benefit", which requires defined benefit obligation to be recognised based on actuarial valuation basis. In absence of valuation we are unable to quantify the impact of above on the net profit for the year and liabilities as on date.

Management’s Explanation:

For-payment of gratuity, it is accounted-for on payment basis.

Further, the Auditors of the Company have not reported any fraud as specified under Section 143(12) of the Companies Act, 2013.

b) Secretarial Auditor

Pursuant to the provisions of section 204 of the Companies Act, 2013 and Rules made thereunder, the Company has appointed M/s. Mitesh J. Shah & Associates, Practicing Company Secretaries as Secretarial Auditor to undertake the secretarial audit of the Company for financial year 2020-21.

The Secretarial Audit Report for the financial year ended March 31, 2021, in the prescribed Form MR-3 is annexed as Annexure-2 to this Report. The report is self-explanatory and does not have any qualifications.

Pursuant to circular No. CIR/CFD/CMD1/27/2019 dated 8th February, 2019, issued by the SEBI, the company has obtained Annual Secretarial Compliance Report for the year ended March 31, 2021, from Practicing Company Secretaries on compliance of all applicable SEBI Regulations/circulars/ guidelines issued thereunder and the copy of the same has been submitted with the Stock Exchange(s)within the prescribed time.

c) Internal Auditor

M/s. Siddhant Shah & Co., Practicing Chartered Accountants, Mumbai performed the duties of internal auditors of the company for the F.Y. 2020-21 and their report is reviewed by the Audit committee from time to time. Further, Board of Directors of the Company were informed that M/s. Siddhant Shah & Co. has integrated it’s Organization with M/s. AHSP & Co. LLP hence, the Company has appointed M/s. AHSP & Co. LLP, as an Internal Auditors of the company for the F.Y. 2021-22.

Further, Board of Directors of the Company have appointed M/s. RL Agrawal & Associates, as an Internal Auditors for Stock Broking Division of the company for the F.Y. 2021-22.

d) Cost Auditor

The Maintenance of the cost records, for the services rendered by the Company is not required pursuant to Section 148(1) of the Companies Act, 2013 read with Rule 3 of the Companies (Cost records and Audit) Rules, 2014 and accordingly it is not required to appoint Cost Auditor.

16) VIGIL MECHANISM/ WHISTLE BLOWER POLICY

In Compliance with Section 177(9) of the Companies Act, 2013 and Regulation 22 of SEBI Listing Regulation, the Company has adopted a Whistle Blower Policy. The Company’s vigil mechanism/ Whistle blower Policy aims to provide the appropriate platform and protection for Whistle Blowers to report instances of fraud and mismanagement, if any, to promote reporting of any unethical or improper practice or violation of the Company’s Code of Conduct or complaints regarding accounting, auditing, internal controls or suspected incidents of violation of applicable laws and regulations including the Company’s code of conduct or ethics policy or Code of Conduct for Prevention of Insider Trading in the Company, Code of Fair practices and Disclosure. The employees of the Company are encouraged to use guidance provided in the Policy for reporting all allegations of suspected improper activities. The Vigil Mechanism provides a mechanism for employees of the Company to approach the Chairman of the Audit Committee of the Company for redressal. The Company has disclosed the policy at the website at www.comfortcommotrade.com.

During the Financial Year 2020-21, no cases under this mechanism were reported to the Company.

17) CODE OF CONDUCT FOR PREVENTION OF INSIDER TRADING

The Company has adopted a Code of Conduct for Prevention of Insider Trading and Code for Fair Disclosure with a view to regulate trading in securities by the Directors and designated person of the Company in compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015. The code is available on website of the Company at web link http:// www.comfortcommotrade.com/Investorrelation

18) CONTRACTS AND ARRANGEMENTS WITH RELATED PARTIES

The Company has put in place a policy for Related Party Transactions i.e. Policies on determining materiality of related party transactions and also on dealing with Related Party Transactions, which has been reviewed and approved by the Audit Committee and Board of Directors. The Policy provides for the identification of Related Party Transactions, necessary approvals by the Audit Committee/Board/Shareholders, reporting and disclosure requirements in compliance with the Companies Act, 2013 and provisions of SEBI Listing Regulations.

All transactions undertaken by the Company during the financial year with related parties were on arm’s length basis & in ordinary course of business and in compliance with the applicable provisions of the Companies Act, 2013 and the SEBI Listing Regulations. All such related party transactions were placed before the Audit Committee for approval, wherever applicable. Pursuant to the provisions of Regulation 23 of the SEBI Listing Regulations, approval of the Members was obtained at the 13th Annual General Meeting for material related party transaction(s) entered/to be entered with the related party(ies), for the financial year 2021-22 and onwards. Omnibus approvals are also given by the Audit Committee for the transactions, which are foreseen and are repetitive in nature on yearly basis.

The details of contracts and arrangements with related parties of your Company for the financial year under review, are given in notes to the Financial Statements, forming part of this Annual Report.

Pursuant to Regulation 23(9) of the SEBI Listing Regulations, your Company has filed the half yearly reports on related party transactions with the Stock Exchanges.

The Company has not entered into any material transactions with related parties referred to in Section 188(1) of the Companies Act, 2013 and in compliance with the SEBI Listing Regulations. Accordingly, the details are not required to be given under AOC-2.

Further, Policies on determining materiality of related party transactions and also on dealing with Related Party Transactions has been posted on the website of the Company at www.comfortcommotrade.com.

19) INTERNAL FINANCIAL CONTROLS

The Internal Financial Controls with reference to financial statements as designed and implemented by the Company are adequate. During the year under review, no material or serious observation has been received from the Statutory Auditors and the Internal Auditors of the Company on the inefficiency or inadequacy of such controls apart from the observations mentioned by the Auditors, appearing elsewhere in this Report. Based on the framework of Internal Financial Controls and compliance systems established and maintained by the

Company, audit and reviews performed by the Internal, Statutory and Secretarial Auditors and the reviews undertaken by the Management and the Audit Committee, the Board is of the opinion that the Company’s Internal Financial Controls have been adequate and effective during the year under review.

20) PREVENTION OF SEXUAL HARASSMENT OF WOMEN AT WORkPLACE

The Company is committed to upheld and maintain the dignity of woman employees and to provide a safe and conducive work environment to all its employees and associates working in the Company. In Compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, your company has put in place Policy on Prevention of Sexual Harassment at Workplace. All employees (permanent, contractual, temporary, trainees) are covered under this policy.

The Company has complied with provisions relating to the constitution of Internal Complaints Committee (ICC) in accordance with the requirements of the said Act.

Your Directors further state that during the financial year 2020-21, there were no complaints received pursuant to Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

21) ANNUAL RETURN

Pursuant to Section 92(3) of the Act and Rule 12 of the Companies (Management and Administration) Rules, 2014, the Annual Return for F.Y. 2020-21 is available on Company’s website at htttp://www.comfortcommotrade. com/Admin/File/Form_MGT_7_CCL.pdf

22) PARTICULARS OF LOANS, GUARANTEES AND INVESTMENTS

Particulars of loans and/or Guarantees given and investments made and or security provided form part of the notes to the financial statements provided in this Annual Report.

23) CORPORATE SOCIAL RESPONSIBILITY

As per the provisions of section 135 of the Companies Act, 2013, during the year under review the Company is not required to spend any amount on CSR. However, considering net profit of the Company for the F.Y. 2020-21, the Company is required to comply with the provisions of Section 135 of the Companies Act, 2013 from F.Y 2021-22 onwards. Further, the Board of directors in its meeting held on June 21, 2021, has constituted the CSR Committee and the Company is in due process of complying with the other relevant provisions of section 135 of the Act.

24) CHIEF FINANCIAL OFFICER CERTIFICATION

Certification from Chief Financial Officer and Whole-time Director as required under Regulation 17 (8) read with Part B of Schedule II of the SEBI Listing Regulations, certifying that the financial statements do not contain any untrue statement and these statements represent a true and fair view of the Company’s affairs has been obtained.

25) INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY

The Company has adequate system of internal control to safeguard and protect from loss, unauthorized use or disposition of its assets. All the transactions are properly authorized, recorded and reported to the Management. The Company is following all the applicable Indian Accounting Standards for properly maintaining the books of accounts and reporting financial statements. The Internal Auditor of the company checks and verifies the internal control and monitors them in accordance with policy adopted by the Company. The Company continues to ensure proper and adequate systems and procedures commensurate with its size and nature of its business.

26) SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS

During the Financial Year 2020-21, there were no significant or material orders passed by the Regulators or Courts or Tribunals impacting the going concern status and operations of the Company in the future.

27) BUSINESS RISk MANAGEMENT

The Company has in place a mechanism to identify, assess, monitor and mitigate various risks to key business objectives. Major risks identified by the businesses and functions are systematically addressed through mitigating actions on a continuing basis. The company has been addressing various risks impacting the company and brief view of the company on risk management is provided elsewhere in this annual report in Management Discussion and Analysis Report.

28) MANAGEMENT DISCUSSION AND ANALYSIS REPORT

Management Discussion and Analysis Report as stipulated under the SEBI Listing Regulations, is presented in a separate section forming part of this Report. It provides information about the overall industry structure, global and domestic economic scenarios, developments in business operations/ performance of the Company’s various businesses, internal controls and their adequacy, risk management systems, human resources and other material developments during the financial year 2020–21.

29) CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION, FOREIGN EXCHANGE EARNINGS AND OUTGO

The Company continued to give major emphasis for conservation of Energy, and the measures taken during the previous years were continued. The Company regularly reviews power consumption patterns across its units and implement requisite improvements / changes in the process in order to optimize power consumptions.

Further, the Company’s operations do not require significant import of technology.

Foreign Exchange Earnings and Outgo –

Total Foreign Exchange used and earned by the Company is as follows:

Particulars Year Ended 31 March, 2021 Year Ended 31 March, 2020
Foreign Exchange Used - -
Foreign Exchange Earned - -

30) REMUNERATION TO DIRECTORS, PARTICULARS OF EMPLOYEES AND HUMAN RESOURCES(HR)

Your Company had 12 employees as on March 31, 2021. The statement containing particulars of employees as required under Section 197(12) of the Companies Act, 2013 read along with Rule 5(2) and 5(3) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 is not applicable to the Company as no employees were in receipt of remuneration above the limits specified in Rule 5(2) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014.

The Directors wish to place on record their appreciation and acknowledgment of the efforts, efficient and loyal service rendered, dedication and contributions made by employees at all levels during the year under review. The Company continues to focus on attracting new talent & help them to acquire new skills, explore new roles and realize their potential. The ratio of the remuneration of each Director to the median employee’s remuneration and other details in terms of Section 197(12) of the Companies Act, 2013 read along with Rule 5(1) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, is annexed herewith as Annexure-3 to this Report.

31) REPORTING OF FRAUDS BY AUDITORS

During the year under review, neither the statutory auditors nor the secretarial auditor has reported to the audit committee, under Section 143 (12) of the Companies Act, 2013, any instances of fraud committed against the Company by its officers or employees, the details of which would need to be mentioned in the Board’s report

32) SECRETARIAL STANDARDS

Your Company has complied with the applicable Secretarial Standard SS-1 and SS-2 with respect to Board Meetings and General Meetings respectively specified by the Institute of Company Secretaries of India.

33) TRANSFER OF AMOUNTS TO INVESTOR EDUCATION AND PROTECTION FUND

Pursuant to the applicable provisions of the Companies Act, 2013 read with Investor Education and Protection Fund Authority (Accounting, Audit, Transfer and Refund) Rules, 2016, (including any statutory modification(s) and / or reenactment(s) thereof for the time being in force), the Members may note that the Company will be transferring unpaid/ unclaimed dividend and the shares to the IEPF Authority for its Dividend Account of financial year 2013-14 which is due in October, 2021. The Company will be sending individual correspondence to respective shareholders and will be publishing newspaper advertisement for claiming the unpaid/unclaimed dividend in respect of which dividend has not been en-cashed or claimed by the members for 7 consecutive years or more. The shareholders are once again requested to claim their unpaid/unclaimed dividend to avoid the transfer to IEPF Authority.

Members who have not yet en-cashed their Final Dividends from financial year 2013-14 and 2014-15 and thereafter are requested to make their claims to the Company / RTA. Members are requested to quote folio numbers / DP ID – Client ID in all their correspondence.

34) ACkNOWLEDGEMENTS

Our business is largely dependent on our relationships with stakeholders. It is imperative to connect with them for better understanding of their expectations and create sustainable value. We strive to build rewarding relationships with our stakeholders – clients, employees, shareholders, business partners, communities and regulators – for achieving our long-term vision aligned with our stakeholders’ interests. Your Board takes this opportunity to express their sincere appreciation for the excellent patronage received from the Banks, customers, business partners, vendors, bankers, financial institutions, regulatory, government authorities and Financial Institutions and for the continued enthusiasm, total commitment, dedicated efforts of the executives and employees of the Company at all levels during the year under review. The Directors also thank the Government of India, Governments of various states in India and concerned Government departments and agencies for their co-operation. The Directors hereby acknowledge the dedication, loyalty, hard work, cooperation, solidarity and commitment rendered by the employees of the Company and their families during the year

The Directors deeply regret the losses suffered due to the Covid-19 pandemic and place on record their sincere appreciation to all the front-line workers and those who have gone beyond their duties in battling against the pandemic.

BY ORDER OF THE BOARD OF DIRECTORS OF COMFORT COMMOTRADE LIMITED
SD/- SD/-
RAjEEV PATHAk APEkSHA kADAM
DIRECTOR CHAIRMAN & DIRECTOR
DIN: 08497094 DIN: 08878724
Date :August 11, 2021
Place : Mumbai