Injecto Polymers Ltd Directors Report

Ramesh Kumar Rateria, aged 63 years, is one of the Promoters and the Chairman & Managing Director of our Company. He is a Fellow Member of the Institute of Chartered Accountants of India and a Commerce graduate from the University of Calcutta. He has an experience of over three decades in the Polymer Industry. As the Chairman and Managing Director

of the Company, he provides strategic direction and is responsible for the day-to-day management and operations of the Company.

Ashok Kumar Rateria, aged 70 years, is one of the Promoters and the Whole Time Director of our Company. He has an experience of over 30 years in the Polymer and Packaging Industry. Since his appointment, he is responsible for the Marketing and Business Development functions, playing a key role in shaping the companys growth strategy and expanding its market reach.

Sushil Kumar Sultania, aged 68 years, serves as one of the Independent Director on the Board of our Company. He is a Fellow Member of the Institute of Chartered Accountants of India and a Commerce graduate from the Bhagalpur University. With over three decades of experience in Finance, Accounting, and Taxation, he brings financial expertise and acumen to the Company. He also serves as the Chairman of the Audit Committee and is a member of the other committees of the Board.

Chandan Sengupta, aged 67 years, is an Independent Director of our Company. He holds a Masters Degree of Management Studies degree from the Birla Institute of Technology & Science at Pilani, Rajasthan and a Post Graduate degree in General Management from the Indian Institute of Management, Calcutta. He has experience in the polymer industry and has handled marketing of chemical products. He was also associated with Haldia Petrochemicals Limited.

Anupma Kashyap, aged 35 years, is one of the Independent Director of our Company. She is an Associate Member of the Institute of Company Secretaries of India and holds a Bachelors Degree in Information and Management from Kurukshetra University. She has an overall experience of 3 years in Corporate Governance, with a strong focus on compliance, regulatory affairs, and board advisory functions.

• None of our Directors is, or was, a director of any listed company, which has been or was delisted from any stock exchange during the term of their directorship in such company.

• None of our Directors have been identified as Wilful Defaulters or Fraudulent Borrowers or Fugitive Economic Offender as defined under the SEBI ICDR Regulations.

• Neither Company nor any of the Directors of the Company are declared as fugitive Economic Offenders as defined in Regulation 2(1)(p) of the SEBI ICDR Regulations, nor have been declared as a "Fugitive Economic Offender" under section 12 of the Fugitive Economic Offenders Act, 2018.

• None of the Directors of the Company are prohibited from accessing the capital markets or debarred from buying, selling or dealing in securities under any order or direction passed by the SEBI or any securities market regulator in any other jurisdiction or any other authority / court.

• No consideration, either in cash or shares or in any other form have been paid or agreed to be paid to any of our Directors or to the firms, or companies in which they have an interest in, by any person, either to induce any of our Directors to become or to help any of them qualify as a director, or otherwise for services rendered by them or by the firm, trust or company in which they are interested, in connection with the promotion or formation of our Company.

• Except as stated as follows, none of the Directors have any interest in any property acquired in the three years preceding the date of the Draft Red Herring Prospectus or proposed to be acquired by the Company or in any transaction by the Company for acquisition of land, construction of building or supply of machinery:

- Our manufacturing facility Unit - II situated at village- Panchpara, P.O.: Radhadasi, Andul Road, Howrah, West Bengal - 711317 is taken on leave and license basis from one of our Group Company namely - Hind Polyfabs Private Limited.

- One of our warehouse situated at Lebukhali, Liluah, Howrah is leased from one of our Promoters i.e., Ramesh Kumar Rateria on a leave and license basis.

- Our registered office situated at 5^th Floor, Room No. 2, Gate No. 3, Poddar Court, 18, Rabindra Sarani, Lalbazar, Kolkata 700001, West Bengal, India is leased from one of our Group Company namely Maruti Packagers Private Limited.

• None of our Directors are persons appearing in the list of directors of struck-off companies by the Registrar of Companies or the MCA under section 248 of the Companies Act, 2013.

• None of our Director is or was a Director of any listed company, whose shares have been or were suspended from being traded on any stock exchanges, in the last five years prior to the date of filing of this Draft Red Herring Prospectus, during the term of their directorship in such company.

• None of our director is, or was, a director of any listed company, which has been or was delisted from any stock exchange during the term of their directorship in such company.

Except as disclosed herein, none of our Director(s) are related to any of our Companys Directors within the meaning of

Section 2 (77) of the Companies Act, 2013:

There is no arrangement or understanding with major shareholders, customers, suppliers or others, pursuant to which any of the Directors or Key Managerial Personnel were selected as a director or Member of Senior Managerial Personnel.

We confirm that as of the date of this Draft Red Herring Prospectus, none of our Directors, KMPs, SMPs have any conflict of interest with the third-party service providers (crucial for operations of our Company).

Except for the terms set forth in the Appointment Letter, our Company has also entered into any service contracts with our Chairman & Managing Director and Whole Time Director in relation to their appointment which provide for benefits or payments of any amounts upon termination of their employment, other than statutory benefits.

In accordance with our Articles of Association and the applicable provisions of the Companies Act, and pursuant to a resolution of our Board dated January 10, 2025, and shareholders resolution dated February 07, 2025 our Board is authorized to borrow money by way of cash credit, loan, overdraft, discounting of bills, operating of letter of credit, for standing guarantee or counter-guarantee and any other type of credit line or facility whether secured or unsecured, granted by banks and financial institutions or otherwise, subject to an overall limit of Rs. 30,000 Lakhs.

SUSHIL KUMAR SULTANIA

Our Board, pursuant to its resolution dated June 12, 2025, has decided that each Non-Executive Director, including Independent Director, is entitled to receive sitting fees of Rs. 5,000 for attending each Board Meeting and Rs. 1,500 for attend each meeting of the Committee of the Board within the limit prescribed under the Companies Act, 2013 and rules made there under.

Except as disclosed in this Draft Red Herring Prospectus, no amount or benefit has been paid or given within the two preceding years or is intended to be paid or given to any of the Executive Directors except the normal remuneration for services rendered as a Director of our Company. Additionally, there is no contingent or deferred compensation payable to any of our Directors.

As on the date of this Draft Red Herring Prospectus, our Company does not have any Subsidiary.

None of our Directors are entitled to any bonus or profit-sharing plan of our Company.

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

There is no contingent or deferred compensation payable to our Directors which does not form part of their remuneration

As per our Articles of Association, our Directors are not required to hold any qualification shares.

Except as disclosed below, none of our other Directors hold any Equity Shares, as on the date of this Draft Red Herring Prospectus:

All the Executive Directors are interested to the extent of remuneration paid to them for services rendered to the Company. The Directors may be regarded as interested in the shares and dividend payable thereon, if any, held by or that may be subscribed by and allotted/ transferred to them or the Companies, Firms and Trust, in which they are interested as Directors, Members, Partners and or Trustees. All Directors may be deemed to be interested in the contracts, agreements/ arrangements to be entered into by our Company with any Company in which they hold Directorships or any Partnership or Proprietorship Firm in which they are Partners or Proprietors as declared in their respective declarations.

All the Non-Executive Independent Directors of the Company may be deemed to be interested to the extent of fees, payable to them for attending meetings of the Board or Committee, if any, as well as to the extent of other remuneration and/ or reimbursement of expenses payable to them as per the applicable laws.

Except as stated under "Note - 29: Related Party Transactions" under Chapter titled "Restated Financial Statements" beginning on page no. 194 of this Draft Red Herring Prospectus, our Company has not entered into any contracts, agreements or arrangements during the preceding two years from the date of the Draft Red Herring Prospectus in which our directors are interested directly or indirectly.

Except as stated in the section titled "Our Promoters and Promoter Group" beginning on page no. 181 our Directors have no interest in the promotion of our Company as of the date of this Draft Red Herring Prospectus, except in the ordinary course of business.

Except as stated in the chapter titled heading titled "Related Party Transactions " under chapter titled "Summary of Issue Document" beginning on page no. 20 of this Draft Red Herring Prospectus, our Directors have not entered into any contract, agreement or arrangements within a period of two (2) years preceding the date of this Draft Red Herring Prospectus in which the Directors are interested directly or indirectly and no payments have been made to them in respect of these contracts, agreements or arrangements or are proposed to be made to them. Further our directors do not have any interest in any immovable property to be acquired by the Company except otherwise disclosed in the heading titled "Our Properties" under the chapter titled "Our Business" beginning on page no. 145 of this Draft Red Herring Prospectus.

• Our manufacturing facility Unit - II situated at village- Panchpara, P.O.: Radhadasi, Andul Road, Howrah, West Bengal - 711317 is taken on leave and license basis from one of our Group Company namely - Hind Polyfabs Private Limited.

• One of our warehouse situated at Lebukhali, Liluah, Howrah is leased from one of our Promoters i.e., Ramesh Kumar Rateria on a leave and license basis.

• Our registered office situated at 5^th Floor, Room No. 2, Gate No. 3, Poddar Court, 18, Rabindra Sarani, Lalbazar, Kolkata 700001, West Bengal, India is leased from one of our Group Company namely Maruti Packagers Private Limited

Our Directors may also be interested to the extent of Equity Shares, if any, held by them or held by the entities in which they are associated as Promoters, Directors, Partners, Proprietors or Trustees or Kartas or Coparceners or held by their relatives or that may be subscribed by or allotted to the Companies, Firms, Ventures, Trusts in which they are interested as Promoters, Directors, Partners, Proprietors, Members or Trustees, pursuant to the Issue. All of our Directors may also be deemed to be interested to the extent of any dividend payable to them and other distributions in respect of the said equity shares, if any. Except as disclosed in the "Note 29 - Related Party Transactions" in the section titled "Financial Information" and "Our Promoters and Promoter Group" beginning on page no. 194 and 181 respectively of this Draft Red Herring Prospectus and described herein above, our directors are not interested in any other Company, Entity or Firm.

Our Directors are interested to the extent of unsecured loans or personal guarantee, if any, given by them to our Company or by their relatives or by the Companies/ Firms in which they are interested as Directors/ Members/ Partners. For the details of unsecured loans given by Directors and personal guarantee given by Directors towards financial facilities of our Company please refer to Chapters titled ‘Financial Indebtedness and Restated Financial Information - Note 29 - Related Party Transactions" beginning on page no. 240 and 194 respectively of this Draft Red Herring Prospectus.

Further, save and except as stated otherwise in "Note 29 - Related Party Transactions" in the chapter titled "Restated Financial Statements " of this Draft Red Herring Prospectus, our Directors do not have any other interests in our Company as on the date of this Draft Red Herring Prospectus. Our directors are not interested in the appointment of Underwriters, Registrar and Bankers to the Issue, or any such intermediaries registered with SEBI.

No consideration in cash or shares or otherwise has been paid or agreed to be paid to any of our Directors or to the Firms or Companies in which any of our Directors are interested, by any person, either to induce him to become, or to qualify him as, a Director, or otherwise for services rendered by our Directors or by the Firm or company in which they are interested, in connection with the promotion or formation of our Company.

All the Directors may be deemed to be interested in the contracts, agreements/ arrangements entered into or to be entered into by our Company with any company which is promoted by them or in which they hold directorships or any Partnership Firm in which they are Partners.

No loans have been availed by the Directors from our Company and none of the beneficiaries of loans, advances and sundry debtors are related to the Directors of our Company, except to the extent of related party transactions already disclosed under "RelatedParty Transactions" beginning on page no. 194 of this Draft Red Herring Prospectus.

Except as mentioned below, there have been no changes in our directors in the last three years:

The provisions of the Companies Act, 2013, SEBI LODR Regulations and SEBI ICDR Regulations relating to corporate governance, will be applicable to our Company immediately upon the listing of our Companys Equity Shares on the Stock Exchange. We are in compliance to the extent applicable with the requirements of the SEBI LODR Regulations, the Companies Act, 2013 and other applicable regulations, in respect of corporate governance in respect of the constitution of the Board and Committees thereof, and formulation and adoption of policies.

As on the date of this Draft Red Herring Prospectus, we have five (5) Directors on our Board, comprising of two (2) Executive Directors and three (3) Non-Executive Directors, all of whom being Independent Directors. Out of five (5) Directors, we have one (1) Woman Director on our Board. The present composition of our Board and its committees is in accordance with the corporate governance requirements provided under the Companies Act and the SEBI Listing Regulations to the extent applicable in relation to the composition of our Board and constitution of committees thereof. Our Company undertakes to take all necessary steps to continue to comply with all applicable requirements of the SEBI Listing Regulations and the Companies Act.

The Board of Directors function either as a full board or through various committees constituted to oversee specific operational areas. In addition to the Committees detailed below, our Board of Directors may, from time to time constitute other committees for various functions as may be required.

In terms of the SEBI Listing Regulations and the provisions of the Companies Act, 2013, our Company has constituted the following committees of our Board:

• Audit Committee

• Stakeholders Relationship Committee

• Nomination and Remuneration Committee

• Corporate Social Responsibility (CSR) Committee

Our Company has constituted a committee of the Board of Directors of the Company called as the "Audit Committee" vide Board Resolution dated July 09, 2025 as per the provisions of Section 177 of the Companies Act, 2013, and all other applicable provisions of the Companies Act, 2013 and the Rules made thereunder (including any statutory modification(s) or re-enactment thereof for the time being in force), with the following members:

The Company Secretary and Compliance Officer of our Company shall serve as the Secretary to the Audit Committee. Terms of Reference:

The Role of Audit Committee not limited to but includes:

1. The recommendation for the appointment, re-appointment and, if required, the replacement or removal of the auditor, their remuneration and fixation of terms of appointment of the Auditors of the Company;

2. Review and monitor the auditors independence and performance, and effectiveness of audit process;

3. Examination of financial statement and auditors report thereon including interim financial result before submission to the Board of Directors for approval;

a. Changes, if any, in accounting policies and practices and reasons for the same.

b. Major accounting entries involving estimates based on the exercise of judgment by management.

c. Significant adjustments made in the financial statements arising out of audit findings.

d. Compliance with Listing and other legal requirements relating to financial statements.

e. Disclosure of any related party transactions.

f. Qualifications in the draft audit report.

4. Approval or any subsequent modification of transactions of the Company with related party;

Provided that the Audit Committee may make omnibus approval for related party transactions proposed to be entered into by the company subject to such conditions as may be prescribed under the Companies Act, 2013 or any subsequent modification(s) or amendment(s) thereof;

Provided further that in case of transaction, other than transactions referred to in section 188 of Companies Act 2013 or any subsequent modification(s) or amendment(s) thereof, and where Audit Committee does not approve the transaction, it shall make its recommendations to the Board;

Provided also that in case any transaction involving any amount not exceeding one crore rupees is entered into by a director or officer of the company without obtaining the approval of the Audit Committee and it is not ratified by the Audit Committee within three months from the date of the transaction, such transaction shall be voidable at the option of the Audit Committee;

5. Reviewing, with the management, and monitoring the statement of uses I application of funds raised through an issue (public issue, rights issue, preferential issue, etc.), the statement of funds utilized for purposes other than those stated in the Issue Document/ Prospectus/ Notice and the Report submitted by the Monitoring Agency monitoring the utilization of proceeds of a public or rights issue, and making appropriate recommendations to the Board to take up steps in this matter;

6. Scrutiny of Inter-corporate loans and investments;

7. Reviewing and discussing the findings of any internal investigations by the internal auditors into matters where there is suspected fraud or irregularity or a failure of internal control systems of a material nature and reporting the matter to the board;

8. To review the functioning of the Whistle Blower mechanism, in case the same is existing;

9. Valuation of undertakings or assets of the company, wherever it is necessary;

10. Evaluation of internal financial controls and risk management systems and reviewing, with the management, performance of internal auditors, and adequacy of the internal control systems; and

11. To look into the reasons for substantial defaults in the payment to the depositors, debenture holders, shareholders (in case of non-payment of declared dividends) and creditors;

12. Approval of appointment of CFO (i.e., the whole-time Finance Director or any other person heading the finance function or discharging that function) after assessing the qualifications, experience & background, etc. of the candidate; and

13. Carrying out any other function as assigned by the Board of Directors from time to time.

1. Management discussion and analysis of financial condition and results of operations;

2. Statement of significant related party transactions (as defined by the audit committee), submitted by management;

3. Management letters / letters of internal control weaknesses issued by the statutory auditors;

4. Internal audit reports relating to internal control weaknesses; and

5. The appointment, removal and terms of remuneration of the Internal Auditor.

6. Annual statement of funds utilized for purpose other than those stated in the Issue Document/ Prospectus.

1. To investigate any activity within its terms of reference;

2. To seek information from any employees;

3. To obtain outside legal or other professional advice; and

4. To secure attendance of outsiders with relevant expertise, if it considers necessary.

The audit committee shall meet four times in a year and approve the items included in its role. The quorum of the meeting of the Audit Committee shall be one third of total members of the Audit Committee or 2 members, whichever is higher, subject to minimum two Independent Director shall present at the Meeting.

Our Company has constituted the Stakeholders Relationship Committee as per the provisions of Section 178 of the Companies Act, 2013, and all other applicable provisions of the Companies Act, 2013 and the Rules made thereunder (including any statutory modification(s) or re-enactment thereof for the time being in force), vide Board Resolution dated July 09, 2025, with the following members:

The Company Secretary and Compliance Officer of our Company shall serve as the Secretary to the Audit Committee. Terms of Reference:

To supervise and ensure;

1. Efficient transfer of shares; including review of cases for refusal of transfer / transmission of shares;

2. Redressal of shareholder and investor complaints like transfer of Shares, non-receipt of balance sheet, non-receipt of declared dividends etc.;

3. Issue duplicate/split/consolidated share certificates:

4. Dematerialization/ Rematerialization of Share;

5. Review of cases for refusal of transfer I transmission of shares and debentures;

6. Reference to statutory and regulatory authorities regarding investor grievances and to otherwise ensure proper and timely attendance and redressal of investor queries and grievances; Provided that inability to resolve or consider any grievance by the Stakeholders Relationship Committee in good faith shall not constitute a contravention of Section 178 of Companies Act, 2013 or any subsequent modification(s) or amendment(s) thereof.

7. Such other matters as may be required by any statutory, contractual or other regulatory requirements to be attended to by such committee from time to time.

The Stakeholders Relationship Committee shall meet as and when require to discuss and approve the items included in its role. The quorum shall be one third of total members of the Stakeholders Relationship Committee or 2 members, whichever is higher.

NOMINATION AND REMUNERATION COMMITTEE Constitution:

Our Company has constituted the "Nomination and Remuneration Committee", vide Board Resolution dated July 09, 2025, as per the provisions of Section 178 of the Companies Act, 2013, and all other applicable provisions, of the Companies Act, 2013 and the Rules made thereunder (including any statutory modification(s) or re-enactment thereof for the time being in force), with the following members:

The Company Secretary and Compliance Officer of our Company shall serve as the Secretary to the Audit Committee. Terms of Reference:

1. Formulation of the criteria for determining qualifications, positive attributes and independence of a director and recommend to the Board a policy relating to the remuneration of the directors, key managerial personnel and other employees;

2. Formulation of criteria for evaluation of Independent Directors and the Board;

3. To ensure that the relationship of remuneration to performance is clear and meets appropriate performance benchmarks; and

4. Identifying persons who are qualified to become directors and who may be appointed in senior management in accordance with the criteria laid down, and recommend to the Board of Directors their appointment and removal and shall carry out evaluation of every directors performance.

The committee is required to meet at least once a year. The quorum necessary for a meeting of the Nomination and Remuneration Committee is one third of total members of the Nomination and Remuneration Committee or 2 members, whichever is higher.

Our Company has constituted the "Corporate Social Responsibility (CSR) Committee", vide Board Resolution dated July 22, 2025, as per the provisions of the Section 135 of the Companies Act, 2013 read with Sub-rule 5 of Rule 9 of the Companies (Corporate Social Responsibility Policy) Rules, 2014 (including any statutory modification(s) or re-enactment thereof for the time being in force), comprising of the following members:

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

The Corporate Social Responsibility (CSR) Committee be and is hereby authorized to formulate and recommend to the Board a CSR Policy, from time to time, outlining the activities to be undertaken by the Company in accordance with the applicable laws. The Committee shall also monitor the implementation of the CSR Policy and recommend the amount of expenditure to be incurred on such CSR activities.

The committee shall formulate an Annual Action Plan in pursuance of its CSR Policy, covering the below:

1. The list of CSR projects or programmes that are approved to be undertaken in areas or subjects specified in Schedule VII of the Act;

2. The manner of execution of such projects or programmes;

3. The modalities of utilisation of funds and implementation schedules for the projects or programmes;

4. Monitoring and reporting mechanism for the projects or programmes; and

5. Details of need and impact assessment, if any, for the projects undertaken by the company.

The following chart depicts our Management Organization Structure:

Apart from our Chairman & Managing Director and Whole Time Director respectively, whose details have been provided under the paragraph ‘Our Management: Brief profile of our Directors on Page no. 166, the details of our other Key Managerial Personnel as on the date of this Draft Red Herring Prospectus, are as follows:

Apart from our Chairman & Managing Director, other Executive & Non-Executive Directors, Chief Financial Officer and Company Secretary & Compliance Officer, whose details have been provided under paragraph above titled ‘ Brief Profile of our Directors and "Our Key Managerial Personnel on page no. 166 and 177 respectively, set forth below are the details of our Senior Managerial Personnel as on the date of filing of this Draft Red Herring Prospectus;

Except as mentioned below, there have been no changes in our Key Managerial Personnel and Senior Management Personnel in the last three years:

The attrition of the Key Managerial Personnel and Senior Management Personnel of our Company is reasonable. For details, see "Risk Factors - Our business is significantly dependent on our Promoters, key and senior management and other skilled personnel, and our inability to attract, retain, and manage such key personnel and senior management could adversely affect our business, financial condition, results of operations, and growth prospects" on page 29".

Except as disclosed below, none of our KMPs or SMPs hold any Equity Shares, as on the date of this Draft Red Herring Prospectus:

Except as disclosed under the heading ‘Relationship between our Directors none of our Key Managerial Personnel and Senior Management Personnel of our Company are related to each other or our Directors.

• Except the statutory payments made by our Company, our Company has not paid any sum to the Key Managerial Personnel and Senior Management Personnel in connection with superannuation payments and ex-gratia/ rewards and has not paid any non-salary amount or benefit to them.

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

• There is no arrangement or understanding with the major shareholders, customers, suppliers or others, pursuant to which any of our other Key Managerial Personnel or Senior Management Personnel was selected as Key Managerial Personnel or Senior Management Personnel.

• Except for the terms set forth in the appointment letters, the Key Managerial Personnel and Senior Management Personnel have not entered into any other contractual arrangements or service contracts (including retirement and termination benefits) with our Company.

• Our Company does not have any Bonus / Profit sharing plan for any of the Key Managerial Personnel and Senior Management Personnel, except as stated in the terms of their appointment.

• None of our Key Managerial Personnel and Senior Management Personnel has been granted any benefits in kind from our Company, except to the extent of perquisites as provided under the Companys Human Resource / Employee Policy.

• No benefits are granted upon their termination from employment other than statutory benefits provided by our Company.

• In respect of all above mentioned Key Managerial Personnel and Senior Management Personnel, there has been no contingent or deferred compensation accrued for the financial year ended March 31, 2025.

As on date of this Draft Red Herring Prospectus, our Company does not have any Employee Stock Options and other Equity-Based Employee Benefit Schemes.

None of our Key Managerial Personnel and Senior Management Personnel have any interest in our Company, other than to the extent of (i) the remuneration or benefits to which they are entitled in accordance with the terms of their appointment or reimbursement of expenses incurred by them during the ordinary course of business, and (ii) the Equity Shares held bythem, if any, and any dividend payable to them and other benefits arising out of such shareholding.

Other than as disclosed in this section and as disclosed in "Financial Information -Related Party Transactions (Note 29) " beginning on page no. 194, our Company has not paid any compensation or granted any benefit to any of our Key Managerial Personnel and Senior Management Personnel in all capacities in Fiscal 2025.

For further details of the interest of our Directors in our Company, see "Interests of Directors on page no. 171.

The Promoters of our Company are Ramesh Kumar Rateria, Ashok Kumar Rateria, Suman Financial Advisory Private Limited, Suman Towers Private Limited, Vinayak Tie-Up Private Limited, Nivedeeka Commercial Private Limited and Bhagyashri Trading Private Limited. As on the date of this Draft Red Herring Prospectus, our Promoters Shareholding in our Company are stated as follows:

For details of the build-up of the Promoters shareholding in our Company, please see "Capital Structure - Capital Build Up " of our Company on page no. 85 of this Draft Red Herring Prospectus.

Suman Financial Advisory Private Limited was incorporated on August 10, 2010 under the Companies Act, 1956 and a Certificate of Incorporation was issued by the Deputy Registrar of Company, West Bengal. The registered office of the Company is situated at 132 Cotton Street, 1^st Floor, Kolkata- 700007, West Bengal, India. The corporate identity number of the Company is U74999WB2010PTC152121. It holds 14.23% of the Equity Share Capital in our Company. It is engaged in providing loans and advance to the other Companies in the group.

The Promoters of Suman Financial Advisory Private Limited are Ramesh Kumar Rateria and Ashok Kumar Rateria. Board of Directors:

As on the date of this Draft Red Herring Prospectus, the Directors of Suman Financial Advisory Private Limited are Ramavatar Kankani and Vijendra Choudhary.

There has been no change in control of Suman Financial Advisory Private Limited during the five (5) years preceding the date of filing of this Draft Red Herring Prospectus.

Suman Towers Private Limited was incorporated on February 03, 2011 under the Companies Act, 1956 and a Certificate of Incorporation was issued by the Deputy Registrar of Companies, West Bengal. The registered office of the Company is situated at 132, Cotton Street, 1^st Floor, Kolkata 700007, West Bengal, India. The Corporate Identity Number of the Company is U45400WB2011PTC158473. It holds 14.23% of the Equity Share Capital of our Company. It is engaged in the business of providing loans and advance to the other Companies in the group.

* ST Associates is an Association of Persons, holding Equity Shares in Suman Towers Private Limited through Bonamite Merchants Private Limited and through Adhipati Distributors Private Limited.

The Promoter of Suman Towers Private Limited is Ramesh Kumar Rateria.

As on the date of this Draft Red Herring Prospectus, the directors of Suman Towers Private Limited are Ramavatar Kankani and Vijendra Choudhary.

There has been no change in control in Suman Towers Private Limited during the five (5) years preceding the date of filing of this Draft Red Herring Prospectus.

Vinayak Tie-Up Private Limited was incorporated on September 08, 1995 under the Companies Act, 1956 and a Certificate of Incorporation was issued by the Registrar of Companies, West Bengal. The Company is a Registered NonBanking Financial Company u/s 45IA of Reserve Bank of India registered with the Reserve Bank of India vide certificate of Registration dated May 16, 1998.The registered office of the Company is situated at 132, Cotton Street, Kolkata 700007, West Bengal, India. The Corporate Identity Number of the Company is U51909WB1995PTC074144. It is an RBI Registered Non Deposit taking NBFC engaged in investment and making of loans and advances. This Company is engaged in investing in the shares of group companies and providing short term loans and finances.

The Promoter of Vinayak Tie-Up Private Limited is Ramesh Kumar Rateria.

As on the date of this Draft Red Herring Prospectus, the directors of Vinayak Tie-Up Private Limited are Ramesh Kumar Rateria and Ramavatar Kankani.

There has been no change in control in Vinayak Tie-Up Private Limited during the five (5) years preceding the date of filing of this Draft Red Herring Prospectus.

Nivedeeka Commercial Private Limited was incorporated on July 17, 1995 under the Companies Act, 1956 and a Certificate of Incorporation was issued by the Registrar of Companies, West Bengal. The Company is a Registered as a Non Deposit taking Non-Banking Financial Company u/s 45IA of Reserve Bank of India with the Reserve Bank of India vide certificate of Registration dated October 15, 2001. The registered office of the Company is situated at 132, Cotton Street, 1^st Floor, Kolkata 700007, West Bengal, India. The Corporate Identity Number of the Company is U51909WB1995PTC072954. It is categorised as an Investment and Credit Company (ICC) by the RBI and has invested in the Equity Share Capital of the other Companies in the group and provides loans and advances to them.

The Promoter of Nivedeeka Commercial Private Limited is Ramesh Kumar Rateria.

As on the date of this Draft Red Herring Prospectus, the directors of Nivedeeka Commercial Private Limited are Rajeev Malik, Ramesh Kumar Rateria and Ramavatar Kankani.

There has been no change in control in Nivedeeka Commercial Private Limited during the five (5) years preceding the date of filing of this Draft Red Herring Prospectus.

Bhagyashri Trading Private Limited was incorporated on August 30, 1995 under the Companies Act, 1956 and a Certificate of Incorporation was issued by the Registrar of Companies, West Bengal. The Company is a Non Deposit taking Non-Banking Financial Company u/s 45IA of Reserve Bank of India registered with the Reserve Bank of India vide certificate of Registration dated August 27, 2023. The registered office of the Company is situated at 132, Cotton Street, 1^st Floor, Kolkata 700007, West Bengal, India. The Corporate Identity Number of the Company is U51109WB1995PTC073905. It is categorised as an Investment and Credit Company (ICC) by the RBI and is engaged in investment and making of loans and advances. It mainly invests in the shares of the other Companies in the group and provides short term loans and finances to them.

The Promoter of Bhagyashri Trading Private Limited is Ramesh Kumar Rateria.

As on the date of this Draft Red Herring Prospectus, the directors of Bhagyashri Trading Private Limited are Ramavatar Kankani and Vijendra Choudhary.

There has been no change in control in Bhagyashri Trading Private Limited during the five (5) years preceding the date of filing of this Draft Red Herring Prospectus.

Both of our individual promoters are experienced in the line of businesses in which are our Company operates. For details in relation to the experience of our Promoters in the business of our Company, please see " Our Management" on page no. 165 of the Draft Red Herring Prospectus.

Our Promoters are interested in our Company to the extent (i) that they have promoted our Company (ii) of their respective shareholding directly or indirectly, along with that of their relatives in our Company, (iii) their directorship in our Company (wherever applicable), and (iv) the dividends payable, if any, and any other distributions in respect of their shareholding in our Company or the shareholding of their relatives in our Company. For further details of our Promoters shareholding, see "Capital Structure"" on page no. 72 of this Draft Red Herring Prospectus. For further details of interest of our Promoters in our Company, see "Capital Structure", "Our Management - Interest of Directors" and "Related Party Transactions"" on page no. 72, 171 and 194 of this Draft Red Herring Prospectus.

Except as stated below, our Promoters & Promoter Group are not interested in any transactions for the acquisition of land, construction of building or supply of machinery, except in ordinary course business and as disclosed in "Restated Financial Information - Related Party Transactions" beginning on page no. 194.

• The Manufacturing Unit II of our Company situated at Village - Panchpara, P.O - Radhadasi, Andul Road, Howrah, West Bengal-711317, has been taken on Leave and License by our Company from our Group Company i.e., Hind

Polyfabs Private Limited. Our Promoters, Ramesh Kumar Rateria and Ashok Kumar Rateria and members of our Promoter Group i.e., Rupam Rateria and Rajat Rateria are interested to the effect of their shareholding in Hind Polyfabs Private Limited in the aforesaid transaction.

• One of the godowns of the Company situated at Uttar Panchpara, Lebukhali Math, Howrah 711317, West Bengal, India has been taken by our Company on Leave and License from one of our Promoters i.e., Ramesh Kumar Rateria.

• Our registered office situated at 5^th Floor, Room No. 2, Gate No. 3, Poddar Court, 18, Rabindra Sarani, Lalbazar, Kolkata 700001, West Bengal, India is leased from one of our Group Company namely Maruti Packagers Private Limited.

Our Promoters, Ramesh Kumar Rateria is the Chairman and Managing Director and Ashok Kumar Rateria is the Wholetime Director of our Company, therefore, they may be deemed to be considered interested to the extent of any remuneration which shall be payable to them in such capacity. Except as stated in this section and the section titled "Our Management", "Financial Indebtedness" and "Restated Financial Information"" beginning on page no. 165, 240 and 194, respectively, our Promoters do not have any interest in our Company other than as Promoters.

Our Promoters are also Directors on the Board, or shareholders, proprietors, members or parties or related to persons in control of such entities with which our Company has had related party transactions and may be deemed to be interested to the extent of the payments made by our Company, if any, to those entities.

For details of related party transactions entered into by our Company with our Promoters during the financial year immediately preceding the date of this Draft Red Herring Prospectus, please see "Other Financial Information —Related Party Transactions"" beginning on page no. 194.

There has been no payment of benefits to our Promoters or the Promoter Group since incorporation nor is there any intention to pay or give any benefit to our Promoter or any member of the Promoter Group by the Company as on the date of this Draft Red Herring Prospectus except remuneration received by Ashok Kumar Rateria as disclosed herein and as stated in "Restated Financial Statements" beginning on page no. 194.

Our Company has not entered into any contract, agreement or arrangements since incorporation and does not propose to enter into any such contract in which our Promoters or the Promoter Group are directly or indirectly interested and no payments have been made to them in respect of the contracts, agreements or arrangements which are proposed to be made other than as disclosed in "History and Certain Other Corporate Matters—Shareholders Agreements and Other Agreements", "Our Management" and "Other Financial Information —Related Party Transactions" on page no. 159, 165 and 194, respectively.

Except as stated below, our Promoters have not disassociated themselves from any company or firm in the three years immediately preceding the date of this Draft Red Herring Prospectus;

Other than as disclosed in "Financial Indebtedness - Guarantee" on page no. 240, our Promoters have not given any material guarantees to any third parties with respect to the Equity Shares of our Company, as on the date of this Draft Red Herring Prospectus.

Save and except as disclosed in this section titled "Our Promoters & Promoter Group beginning on page no. 181 of this Draft Red Herring Prospectus, there are no ventures promoted by our Promoters in which they have any business interests/ other interests.

For details on litigations and disputes pending against the Promoters and defaults made by the Promoters please refer to the section titled "Outstanding Litigations and Material Developments beginning on page no. 269 of this Draft Red Herring Prospectus.

• Our Promoters and members of our Promoter Group have not been declared willful defaulters or fraudulent borrowers by any bank or financial institution or consortium thereof, in accordance with the guidelines on willful defaulters or fraudulent borrowers issued by Reserve Bank of India or any other Government Authority.

• Our Promoters and members of our Promoter Group have not been prohibited from accessing or operating in capital markets under any order or direction passed by SEBI or any other regulatory or Government Authority.

• Our Promoters have not been declared as a Fugitive Economic Offender under the provisions of Section 12 of the Fugitive Economic Offenders Act, 2018.

• Our Promoters and Member of our Promoter Group are in compliance with the Companies (Significant Beneficial Ownership) Rules, 2018.

• Our Promoters and members of our Promoter Group is not and has never been promoter, director, or person in control of any other company which is prohibited from accessing or operating in capital markets under any order or direction passed by SEBI or any other regulatory or Government Authority.

In addition to our Promoters, individuals and entities that form part of the Promoter Group of our Company in terms of Regulation 2(1) (pp) of the SEBI ICDR Regulations are set out below:

As per Regulation 2(1) (pp)(iv) of the SEBI (ICDR) Regulations, 2018, the following entities would form part of our

1 QH

Promoter Group: