JSW Ispat Special Products Ltd Management Discussions.

MIEL is a primary steel producer that manufactures and sells sponge iron, steel, ferro alloys, along with billets and pellets. The Company has an integrated steel plant at Raigarh in Chattisgarh, India with a capacity of ~1 MTPA, with the ability to scale up to 1.5

MTPA on completion of balance steel making facilities. It also has a pellet production capacity of 2.2 MTPA with the capability to scale up to 2.5 MTPA at the same location. MIEL also has another unit for steel production at Raipur with 0.25 MTPA capacity.

In FY 2017-18, MIEL underwent a Corporate Insolvency

Resolution Process (CIRP), and pursuant to CIRP the majority of equity stake and control was acquired by a consortium of AION Investments Private II Limited (AION) and JSW Steel Limited in August 2018. Subsequent to the said acquisition, the new management has taken various steps to restart and stabilise the operations at Raigarh works, while the Raipur works continues to function normally.


The world GDP growth for CY2019 stood at 2.9%, compared to a 3.6% growth in CY2018. The slower growth in 2019 was a result of a broad-based slowdown in global manufacturing and trade on the back of uncertainty around trade measures and tariffs. However, just as CY2020 was beginning to show signs of a modest recovery, the world was hit hard by the unprecedented COVID-19 pandemic. Subsequently lockdowns, shelter in place, stay at home orders, etc. were imposed across various countries, which brought an abrupt halt to the economic activities across the globe.

According to the International Monetary Fund (IMF), global economic growth is likely to witness a steep de-growth of -4.9% in CY 2020, amidst ‘The Great Lockdown led by COVID-19. The contraction in growth seeps down to over 170 nations, and for several of them, this comes as a double whammy as they were already fighting existing headwinds in their economy. That said, there is a co-ordinated policy measures being undertaken across the world, as most nations have responded with various stimulus measures and economic packages to mitigate the impact of this slowdown. Mankind seems to have found a new level of resolve to adapt and overcome this temporary shock. This also sets the stage for innovation, the aspects of which are being reflected across industries and all walks of life. Together, these establish the tone for a ‘new normal.

Advanced economies

The advanced economies are mostly experiencing widespread outbreak, especially the US, the UK, Germany, France, Italy and

Spain, and are therefore deploying containment measures that extract a sizable toll on economic activity. Additionally, adverse market sentiments are also likely to impact economic prospects. Some partial lifting of lockdown measures has been witnessed in recent weeks.

Emerging market and developing economies

The emerging markets and developing economies are under pressure to balance their public health scenario with their economic development goals. However, emerging and developing Asia group is expected to be the only region with some growth rate in CY2020 due to significant domestic demand and policy responses.


Global economic prospects solely rest on the pandemic fading eventually and the stimulus that governments will be able to provide their economies. So far, China appears to have overcome its initial shock after COVID-19 ravaged its Wuhan and Hubei provinces, while others are evaluating the spread of the disease and assessing impact and placing possible mitigation measures in action.

Despite the pandemic having a more negative impact on global economic activities in CY 2020, the IMF estimates gradual recovery in CY 2021 with global growth forecast of 5.4%.

Region-wise growth estimates (%)

Region 2018 2019 2020 2021
(Projected) (Projected)
World 3.6 2.9 -4.9 5.4
AME 2.2 1.7 -8.0 4.8
US 2.9 2.3 -8 4.5
Euro Area 1.9 1.2 -10.2 6.0
Japan 0.3 0.7 -5.8 2.4
EME 4.5 3.7 -3.0 5.9
China 6.7 6.1 1.0 8.2
Russia 2.5 1.3 -6.6 4.1
India* 6.8 4.2 -4.5 6.0
Brazil 1.3 1.1 -9.1 3.6

Strong multilateral cooperation is the need of the hour to overcome the effects of the pandemic in the economic arena as well. Countries need to urgently help those economies that are facing twin health and funding shocks to slow the spread of the virus.Additionally,broad-based fi across the globe can lift aggregate demand, build market confidence and avert an even deeper downturn.


Indias economic growth moderated in FY 2019-20 to 4.2% from 6.1% a year earlier due to weak domestic consumption and subdued investments. The IMF estimates Indian GDP to contract by 4.5% in FY 2020-21 given the severe impact of pandemic on the domestic economic activities but bounce back to 6% in the subsequent year.

India Economic Growth (%)

Particulars F.Y 2018-19 F.Y 2019-20
GDP 6.1 4.2
Agriculture 2.4 4.0
Industry 4.9 0.9
Services 7.7 5.5
Manufacturing 5.7 0.0
GFCF 9.8 -2.8
Construction 6.1 1.3

India faced an eventful FY 2020. Notwithstanding a large mandate for a stable government in the general elections, extended monsoons and a weakened investment and consumer sentiment subdued economic activity for a large part of the year. However, towards the end of third quarter, the demand picked up, especially with back-to-back policy rate cuts from the Reserve Bank of


The global steel industry witnessed moderate growth during CY 2019, with spurts of growth in specific geographies. The industry was further hit by shutdowns, disrupted supply chains, collapsing confidence and delayed investment and construction projects, aggravated by financial market volatility and collapsing oil prices during this period. The year witnessed slower macroeconomic growth and increased pricing pressure, led by protectionist tendencies.

in million tonnes
Crude Steel Production Finished Steel Apparent Consumption
2018 2019 Variance (%) 2018 2019 2020-P Variance (%)
2019 vs 2018 2020-P vs 2019
World 1,814 1,869 3.0 1,708 1,766 1,654 3.4 -6.4
China 920 996 8.3 836 907 917 8.5 1.0
World-China 894 873 -2.3 872 859 737 -1.5 -14.2
Japan 104 99 -4.8 65 63 51 -3.4 -19
US 87 88 1.1 100 98 75 -2.1 -22.9
Korea 73 71 -2.7 54 53 46 -0.9 -12.7
EU-28 168 159 -5.3 168 158 133 -5.6 -15.8
ASEAN 34 37 9.1 77 78 76 0.8 -2.4

India (RBI) and the announcement of a large-scale multi-year infrastructure pipeline worth 102 lakh crores by the government. In March 2020, as the pandemic spread its influence across the country, the Government of India proactively laid down containment measures, starting with a 21-day lockdown w.e.f.

25th March 2020, which was further extended in phases. The macroeconomic and financial activities, since then, have steeply waned, with a contraction in exports, declining production and sales of automobiles and a sharp fall in the demand for electricity.

The IMF projections of growth or de-growth are based upon the assumption that the lockdown and the pandemic recede during the second half of FY 2021, and there are synchronised efforts from both the government and the Reserve Bank of India (RBI) to support the economy and spur demand.

Despite the imminent risks to the economy, Indias growth is expected to gain pace gradually in the coming months, expectedly driven by targeted measures to protect jobs, income support to the vulnerable sections of households and businesses, and encourage investments. The Government of India has already announced a 20 trillion package (or ~10% of Indias GDP) to assist the nation and its people in mitigating the economic impacts of this pandemic.

Indias economy remains resilient with robust long-term fundamentals, providing large external buffers and reserves, which bolster the countrys potential to increase fiscal expenditure once the pandemic recedes. Moreover, India has the capacity and scale to expand its share in the global supply chain, which has been disrupted by the COVID-19 outbreak.

Recovering steel industry in China

China is the worlds largest manufacturer and consumer of steel.

After eight weeks of lockdown, China resumed normal economic activities, including steel production in March 2020. All steel-consuming sectors are reviving to near normalcy level driven by large fiscal and favorable monetary policies in the country.

While in the near term China is witnessing a strong domestic demand, but elevated levels of production could lead to higher exports out of China later in 2020, which may appear as a risk for global steel prices.


Despite the current market condition, steel demand is expected to remain buoyant in the long term, driven by construction and infrastructure development in the emerging economies. Besides, Advanced economies are expected to modernise and re-build their infrastructure, which bodes well for the global steel demand.

Indian steel industry

India is the worlds second largest producer of crude steel and is estimated to become the second-largest consumer of 2 over the medium term, with the sector contributing ~2% of the countrys GDP. The growth in Indias steel consumption is driven primarily by infrastructure, construction and automobile sectors that account for ~75% of the domestic demand. The growth in Indias production and consumption of steel is a direct result of its economic development and consistent industry.government However, construction and manufacturing activities were subdued for most part of the year driven by a credit squeeze and prolonged monsoon season. This also translated into softer pricing and weaker spreads for finished steel, notably in the first half of 2019-20. Well-placed players in the industry responded by shifting their market focus to exports, to liquidate accumulated inventory.

This led to India becoming a net exporter of steel during the year under review, with non-alloy Hot Rolled Coil being the most exported item.

India leads global DRI production in March 2020

Global production of Direct Reduced Iron (DRI), also called sponge iron, in January-March 2020 continued to be driven by India (9.72 MnT) at the number one spot with a growth of 10.7% over the same period of 2019.

Impact of COVID-19 on Indias steel sector

The nation-wide lockdown across India has impacted all economic activities. As a result, several steel user industry segments such as construction, infrastructure projects and automobiles had abruptly halted. However, with a subsequent lifting of lockdown measures, the economic activities across these segments are gradually moving back towards normalcy. With a substantial decline in demand, most steel production units across India are running at low capacity utilisation levels. The Indian steel industry . responded to the situation by shifting focus on to exports, which meant a decent utilisation levels across the sector in May and June, with inventory levels not being elevated. With strong government incentives and policies, and the economys inherent strengths, India is likely to gradually recover the lost ground in economic development in the coming year, leading to a significant momentum and strong recovery in the countrys steel demand during FY 2022.

Government stimulus creating demand for steel in domestic market

The Government of Indias focus on delivering world-class infrastructure projects across the country has increased the overall steel demand in the country, with infrastructure, construction and real estate sectors together forming 60-65% of

Indias steel demand.

Besides, the new National Steel Policy (NSP) that was introduced in

CY2016, retains the objectives of the NSP 2005. It aims to increase per capita steel consumption to 160 kg by FY 2030-31 and has a mandate of increasing production capacity to 300 MT by FY 2030-31, which will translate into additional investments of 10 lakh crores (~$156.08 billion).

Industry opportunities and threats

With several backward and forward linkages in place, several factors catalyse the demand in the steel industry. Traditionally, FYconstruction, infrastructure, automobiles and consumer durable sectors generate steel demand, while the availability of raw materials and workforce have an impact on the production.

During FY 2020, Indian steel manufacturers continued to face the challenges of imported steel due to elevated level of imports from Japan and South Korea, besides reduced demand from the automobile and its ancillary sectors.

However, the government is working towards bolstering Indias steel industry by direct and indirect policy stimuli that are expected to increase demand (multimillion-dollar NIP and fresh investment in power, railways, and water, coupled with renewed interest in the automobile sector) and reduced imports.


Indias steel consumption growth is expected to rise over the medium to long term on account of government expenditure on infrastructure and fiscal stimulus to manufacturing industries. Further the country is looking to modernise, expand and accommodate the aspirations of a growing population where industrialisation, urbanisation and access to technology are the key pillars of the economic growth.


Performance review

( in crores)

Particulars FY 2019-20 FY 2018-19 Variation (%)
Turnover 2,638.16 1,879.41 39
(Loss)/Profit before depreciation, interest, tax and exceptional items (EBITDA) (17.85) 27.68 -164
Interest and finance charges 253.32 445.27 -43
Depreciation 216.99 275.60 -21
Exceptional items - 2,767.92 -100
Loss before tax (488.16) (3,461.11) -86
Other comprehensive loss (OCL) (3.65) (33.04) -89
Total comprehensive loss for the year (491.81) (3,494.15) -86

Financial Performance

During the year the Company recorded a net loss of 488.16 crores as against 3,461.11 crores in the previous year. It recorded an EBITDA loss of 17.85 crores, while FY2019 EBITDA stood at

27.68 crores. The overall steel industry was reeling through a rough phase and the prices of all products were lower in the current year vis-a-vis the previous year, while the prices of raw material did not fall as much. In Q4 FY2020, the prices of TMT, pellets and

DRI were on the rise but due to the COVID-19 pandemic the prices softened.

The Company ended with a net total comprehensive loss of

491.81 crores in FY 2019-20 as against a loss of 3,494.15 crores in FY2019.

The analysis of the major items of the financial statements is given here: a. Net sales and operating income

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Domestic turnover 2,361.29 1,796.06 565.23 31
Export turnover 246.47 76.29 170.18 223
Total turnover 2,607.76 1872.35 735.41 39
Other operating
Revenues 30.40 7.06 23.34 331
Revenue from
Operations 2,638.16 1,879.41 758.75 40
Other income 25.97 26.83 (0.86) -3
Total income 2664.13 1906.24 757.89 40

During the year, revenue from operations increased by 31% as compared to the previous year mainly due to higher sale of Pellets,

DRI and TMT. During FY 2020, the capacity of Pellets production grew from 1.50 MTPA to 2.20 MTPA.

b. Materials

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Cost of Goods Sold 1,943.36 1,478.00 465.36 31

89 During FY 2020, the Cost of Goods Sold (COGS) increased by 31% as compared to the previous year. This is in line with the increase 86 in sales. The increase in COGS is due to increase in sales of Pellets, DRI and TMT.

c. Employee benefits expense

16 ( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Employee benefits expense 116.46 89.34 27.12 30

The increase in employee benefits expenses as compared to the previous year is mainly on account of increase in the number of employees.

d. Depreciation and amortisation expense

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Depreciation and amortisation 216.99 275.60 (58.61) -21

During the year, depreciation expense reduced by 21% as in the current year the depreciation is calculated on the reduced value of assets post impairment accounted for in the previous year.

e. Other expense

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Other expenses 334.88 163.37 171.51 105

Other expenses include cost of stores & spares consumed, which have increased from 34.64 crores to 124.09 crores, mainly due to an increase in production and start of steel operations during FY 2020.

f. Finance cost

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Finance cost 253.32 445.27 (191.95) -43

Finance cost reduced by 43% y-o-y mainly on account of reduction in interest charge pursuant to the implementation of the resolution plan as approved by the NCLT.

g. Exceptional items

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Exceptional items - 2,767.92 (2,767.92) -100

There is no exceptional item to be reported for FY 2020.

h. Fixed assets

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Tangible assets 3,219.68 3,372.55 -152.87 -5
Capital work-in- progress 237.63 153.63 84.00 55
ROU assets 29.58 - 29.58 100
3,486.89 3,526.18 -39.29 -1

During the year, the Company undertook several projects for increasing the capacity of the Pellet plant, including improvements in the blast furnace and special steel projects. The increase in

Capital Work in Progress and Tangible Assets is on account of these projects.

i. Investments

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Investments in subsidiaries, associates and joint ventures - - - -
Other investment 0.75 0.99 -0.24 -24

j. Inventories

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Raw materials (includes goods in transit) 336.40 227.23 109.17 48
Work-in-progress 4.95 5.73 (0.78) -14
Finished goods 369.97 350.40 19.57 6
Stores and spares (includes goods in transit) 146.17 75.45 70.72 94
Total 857.49 658.81 198.68 30

The Company carries optimum inventory to avoid any shortages. The increase in inventory is in line with the increase in production plan for Pellets, DRI, TMT and Steel operations.

k. Trade receivables

( in crores)

Particulars FY 2019-20 FY 2018-19 Change () Change (%)
Total debtors 54.00 35.06 18.94 54
Less: Provision for doubtful debts (2.23) (2.08) (0.15) 7
Total 51.77 32.98 18.79 57

Trade receivables in absolute numbers have increased but as number of days to sales has reduced due to improvement in collections.

l. Details of significant changes (i.e. change of 25% or more as compared to the immediately previous financial year) in key financial ratios, along with detailed explanations

( in crores)

Particulars FY 2020 FY 2019 Change (%)
Debtors Turnover (days) Note 1 5.86 10.29 -43
Inventory Turnover (days) 120.27 129.00 -7
Interest Coverage Ratio Note 2 (0.12) 0.03 -486
Current Ratio 1.97 2.38 -17
Debt Equity Ratio Note 3 1.76 1.11 59
Operating Profit Margin (%) Note 4 (1.66) 0.05 3,772

Net Profit Margin(%) Note 5 (18.50) (184.16) -90

Note 1: The debtors Turnover ratio has improved with improvement in collections. The Company has been trying to collect advances wherever possible and gives credit against security instruments like letter of credit.

Note 2: During the year, the prices for commodities that the

Company sells has come down and has in turn reduced its margins.

Note 3: The Company is in stabilisation and improvement phase and hence the Company has had to borrow funds for capital expenditure. Moreover, with declining margins the Company had to borrow funds for its working capital needs too. Note 4: The operating profits of the Company have declined compared to the previous year as the prices of commodities have come down while the cost of inputs has not come down to the same extent.

Note 5: During the previous year when the Company was taken over by the new management, the Company had written off many assets which were not recoverable as exceptional items. Hence the net profit margin is not comparable.


The DRI units at both Raigarh and Raipur works were in continuous operation at time of acquisition by the Consortium in August 2018.

The facilities at Raigarh works (other than those relating to Pellets and DRI) were under planned shut down from 21 June 2019 for repairs, maintenance and upgradation. During the period of this shut down, the Company undertook a modification of the plant and machinery for manufacturing special steel products, apart from general maintenance. The Company started some of its manufacturing facilities, namely iron making, steelmaking and rolling mills forming part of the integrated steel making operations on 2 March 2020 and is expected to commence manufacturing special steel in Q1 FY 2021.

The manufacturing facilities of the Company at both Raigarh and

Raipur works were shut down on 25 March 2020 following the country wide lockdown due to COVID-19. With a gradual easing of restrictions, the Company restarted the integrated steelmaking operations at Raigarh works on 2 May 2020 and at Raipur works on 15 May 2020.

Special steels production

MIEL undertook a major planned shutdown during the year to convert its Steel Melting Shop and Rolling Mills to enable production of special steels. This was done by strengthening the equipment and providing higher levels of automation. This will result in: Addition to product basket with a variety of cast product sizes

- 280x370 mm for heavy forgings and rail applications

- 220 mm sq for various grades like low, medium carbon and micro alloy forgings

- 220 mm and 310 mm diameter for seamless pipe industry

- 140 mm sq with extra lengths up to 14 meter for cast products of cold heading, free cutting and high carbon steels

Meeting of wide range of requirements at JSW Steel Italy

Piombino S.P.A. which can consume the cast products

Production of spring steel flats up to 90 series, bars in the range of 20 mm to 60 mm for variety of applications including auto industry, railways and general engineering, by the upgraded bar mill as While the special steel production will be ramping up concurrent with a range of approvals in the current financial year, TMT bar supply will continue meeting the requirements of construction industry.


The quality assurance department has been provided with a wide range of testing equipment and inspection facilities. Quality systems are being set in place to meet and exceed the customer expectations on quality and quantity with delivery at the right time.

The focus is on zero defect and continued after sales support up to the end/OEM customer.

During the year under review, the Raigarh works received ISO 9001:2015, ISO 14001:2015, ISO 45000:2018 certification and was also declared the winner of the 19th Annual Greentech

Environment Award 2019.

Synergies with JSW Steel

JSW Steel, one of the countrys leading steel manufacturers infused capital into MIELs business and is a member of the

Consortium which assumed control over MIEL pursuant to IBC. The Company can leverage on JSW Steels technical knowhow, training and marketing skills and vast experience. Besides, MIEL benefits from the larger organisations economies of scale and utilises its centralised raw materials procurement and marketing. The Company is planning to export special steel cast products to global potential customers, including JSW Steel Italy

Piombino S.P.A.

Demand Scenario

There is a vibrant steel demand in the countrys eastern and northern region. MIEL is ideally located in Chhattisgarh—central

India to cater to these geographies driven by a favourable cost of logistics.

Organisational opportunities and threats


Potential for switching over to special steel to serve north and east market Availability of special steel export market including exports through JSW Steel Italy Piombino S.P.A. JSW Group know-how and in-house resources available for special steel product development

Potential to procure iron ore from JSW Steels captive mines, ensuring raw material security

Steel being increasingly viewed as a more sustainable alternative to other construction materials, driving demand over the long term Steel as a direct beneficiary of the large-scale infrastructure pipeline laid out by the Government of India National Steel Policy 2017 and other announcements by the Government of India supporting the overall growth of domestic steel industry


Proximity of large players who have advantage of lower cost of production and vertical integration COVID-19 disruptions in national and international markets Continuous environmental pressures leading to process/ equipment related changes Divergent global market environment


The identification and evaluation of risks play a crucial part in the sustainability of any organisation. At MIEL, the re-constituted management of the Company adopted a robust risk management framework for identifying and evaluating risks and opportunities.

Key Risk Adverse global and domestic demand-supply dynamics:

Global demand and supply dynamics impact the Companys ability to reach beyond the domestic markets and cater to a diverse customer base. MIEL is growing its presence in various markets and catering to a number of sectors to manage this risk. Besides, during the year, it began production of value-added products that will help it create a niche for itself in the industry.

Cyclical nature of the steel industry:

To overcome the cyclical nature of the steel industry, it is essential to have a foothold in various markets that have different cyclical patterns, as this helps the Company to leverage market opportunities. MIEL is serving the domestic markets of northern and eastern India and will also be cater to international markets including JSW Steel Italy Piombino S.P.A.

Unfair trade practices resulting into surge in imports:

Several markets face unfair trade practices. MIEL works with various industry associations and other such bodies to engage with the government in ensuring a level playing field.

Trade barriers imposed by other countries like the US, Europe:

Some markets are highly regulated and have trade barriers. MIEL supports different trade bodies that focus on encouraging these markets to lower these restrictions

Disruption of business activities:

A proactive risk management approach enables the Company to eliminate disruption of business activities.

The Company takes steps to address the business risks which can be controlled and mitigated. With synergies and support from the JSW Steel and considering the upgradation of the Raigarh works facilities, the management expects to further improve the processes, quality of products and market reach. The Company will focus on producing special steel products and exports. It is well placed to mitigate the known key risks leading to its growth and profitability.


People are the backbone of any organisation and MIEL appreciates the determination, drive and dedication of its people, recognising them as a key differentiator for the business. As on 31 March 2020, the Company had 2,255 direct employees, apart from a strong base of contract workforce. The Company promotes a culture of meritocracy and strives to provide a conducive workplace for all. It has all the contemporary safety practices in place and works continuously to ensure occupational health and safety of its people. The Company has laid down Anti Sexual Harassment policy on Gender Equality, Gender Protection, Prevention of Sexual Harassment and Redressal System as per the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. All employees (permanent, contractual, temporary, apprenticeship) are covered under this policy.


The internal control systems include documented policies, checks and balances, guidelines and procedures, that are supplemented by robust internal audit processes and monitored continuously by periodical reviews by the management to provide reasonable assurance that all assets are safeguarded; transactions are authorised, recorded and reported properly. Post-acquisition, the reconstituted Board/Management is in the process of further . strengthening the internal controls framework with an objective to have a best-in-class internal control framework commensurate with the size, scale and nature of business.


Statements in the Management Discussion and Analysis describing the Companys estimates and expectations may be

‘forward-looking statements within the meaning of applicable securities laws and regulations. Actual results/performance could differ materially from those expressed or implied.

Business responsibility report

Pursuant to Regulation 34(2)(f) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015.


Corporate Identity Number (CIN) of the Company L02710CT1990PLC009826

Corporate Identity Number (CIN) of the Company L02710CT1990PLC009826
Name of the Company Monnet Ispat and Energy Limited (MIEL)
Registered address Monnet Marg, Mandir Hasaud, Raipur, Chhattisgarh-492101
Website www.aionjsw.in
E-mail id isc_miel@aionjsw.in
Financial Year reported 2019-2020
Sector(s) that the Company is engaged in (industrial activity code-wise) S. Name and Description of NIC Code of the Product/service
No. main products / services
1 Steel 241
2 Metal 243
List three key products/services that the Company manufactures/provides a) DRI/Sponge Iron
(as in balance sheet) b) Pellets
c) Structural Steel/TMT
Total number of locations where business activity is undertaken by the Company Detailed hereunder:
(a) Number of International Locations (Provide details of major 5) -
(b) Number of National Locations 2 manufacturing locations
Markets served by the Company Local/State/National/International All


Total Turnover () 2664.13 crores
Total profit/(loss) after taxes( ) (488.16) crores
Total spending on Corporate Social Responsibility (CSR) as percentage of profit after tax (%) As the average net profitof the Company during the previous three financial years was negative, it was not mandated to spend any amount on CSR during 2019-2020. The Company has however voluntarily incurred expenses of 1.48 crores on certain social initiatives.
List of activities in which expenditure in above has been incurred:- The Companys efforts have focused on following areas:
a) Education
b) Health and medical facilities
c) Women empowerment/ Skill Enhancement
d) Rural development


1. Does the Company have any Subsidiary Company/ Companies?

Yes, has two direct subsidiaries i.e., one Indian and one foreign subsidiary.

2. Do the Subsidiary Company/Companies participate in the BR Initiatives of the parent company? If yes, then indicate the number of such subsidiary company(s)

No. Both the subsidiaries are non-operational.

3. Do any other entity/entities (e.g. suppliers, distributors etc.) that the Company does business with, participate in the BR initiatives of the Company? If yes, then indicate the percentage of such entity/entities? [Less than 30%, 30-60%, More than 60%]

MIEL was under the Corporate Insolvency Resolution Process (CIRP) since the financial year 2017-2018. The CIRP process was successfully resolved during the financial year 2018-2019. During the financial year 2019-2020, the new management has undertaken repairs, maintenance, upgradation and modernization of the integrated steel operations at its Raigarh plant and operations are still stabilizing. Hence, suppliers, distributors and the like who are associated with the Company have not yet participated in the BR initiatives of the Company.

2. Principle-wise (as per National Voluntary Guidelines) BR Policy/policies a) Details of compliance (Reply in Y/N)

No Questions P1 P2 P3 P4 P5 P6 P7 P8 P9
1 Do you have a policy/ policies for: Y Y Y Y Y Y Y Y Y
2 $ Has the policy being formulated in consultation with the relevant stakeholders? Y Y Y Y Y Y Y Y Y
3 # Does the policy conform to any national / international standards? If yes, specify? (50 words) Y Y Y Y Y Y Y Y Y
4 Has the policy being approved by the Board? Y Y Y Y Y Y Y Y Y
Is yes, has it been signed by MD/ owner/ CEO/ appropriate Board
5 Does the company have a specified committee of the Board/ o oversee theDirector/Official implementation of the policy? Y Y Y Y Y Y Y Y Y
6 @ Indicate the link for the policy to be viewed online? https://www.aionjsw.in/investors/policies.
7 Has the policy been formally communicated to all relevant internal and external stakeholders? Y Y Y Y Y Y Y Y Y
8 * Does the company have in-house structure to implement the policy/ policies. Y Y Y Y Y Y Y Y Y


1. Details of Director/Directors responsible for BR

Details of the Director/Director responsible for implementation of the BR policy/policies

Name Ravichandar Moorthy Dhakshana
Designation Whole-Time Director
Details of the BR head
DIN Number (if applicable) 08059827
Name Vimal Singh
Designation Vice President
Telephone number +91 7762 251000
e-mail id vimal.singh@jsw.in

The Composition of the Business Responsibility Reporting (BRR) and International Trade Practice Committee is as under;

Sr. No. Name DIN Designation
1 Mrs. Anuradha Bajpai 07128141 Non-Executive Independent Director- Chairperson
2 Mr. Ravichandar Moorthy Dhakshana 03298700 Executive- Whole-Time Director – Member
3 Mr. Nikhil Gahrotra 01277756 Non-Executive Director- Member
Sr. No.Questions P1 P2 P3 P4 P5 P6 P7 P8 P9
9 ^ Does the Company have a grievance redressal mechanism related to the policy/ policies to address stakeholders grievances related to the policy/ policies? Y Y Y Y Y Y Y Y Y
10 Has the company carried out independent audit/ evaluation of the working of this policy by an internal or external agency? N N N N N N N N N


$ Currently, the policy has been uploaded on the Companys website and is being communicated through the Business Responsibility Report under Annual

Report 2020. However, it is proposed to formally communicate the policy to all relevant internal and external stakeholders.

# The BRR policy is based on National Voluntary Guidelines on Social, Environmental and Economic Responsibilities of Business.

@ The BRR policy is available on the website of the Company viz. https://www.aionjsw.in/investors/policies..

* The Business Responsibility Head with the support other functional head and internal / external experts ensures the implementation of the BR policies. The Corporate Governance & BRR Committee to oversee implementation of Business Responsibility policies.

^ Pursuant to the BR policy, the Company has established grievance redressal mechanism whereby stakeholders can approach the Company by writing email at isc_miel@aionjsw.in for the redressal of their grievances. b) If answer to the question at serial number 1 against any principle, is ‘No, please explain why: (Tick up to 2 options)

Sr. No.Questions P1 P2 P3 P4 P5 P5 P6 P7 P8 P9
1 The company has not understood the Principles
2 The company is not at a stage where it finds itself in a position to formulate and implement the policies on specified principles NOT APPLICABLE
3 The company does not have financial or manpower resources available for the task
4 It is planned to be done within next 6 months
5 # It is planned to be done within the next 1 year
6 Any other reason (please specify)

# The Company has formulated and approved the BR policies based on National Voluntary Guidelines and has implemented most of the principles and is in process of implementing the other principles, since the process of implementation has been slowed downed due to the outbreak of the COVID pandemic and exercise of implementation thereof will be completed in the current financial year 2020-2021.

3. Governance related to BR

a. Indicate the frequency with which the Board of Directors, Committee of the Board or CEO to assess the BR performance of the Company.

Within 3 months, 3-6 months, annually, more than 1 year.

SEBI vide its notification dated 26 December 2019 extended the applicability of Business Responsibility Reporting ("BRR") in the Annual Report from the present top 500 listed companies to the top 1000 listed entities based on market capitalization. The Company is covered under such top 1000 listed Companies.

The Company proposes to assess the BR performance of the Company at half-yearly rests aided by regular updates during the year on its implementation.

b. Does the Company publish

a BR or a Sustainability Report?

What is the hyperlink for viewing this report?

How frequently it is published?

This is the first year where the Company is required to publish a Business Responsibility Report as parts of the Annual Report vide SEBI notification dated 26 December, 2019. This report is available at the website of the Company athttps://www.aionjsw.in/ investors and same will be published annually.


Principle 1 - Businesses should conduct and govern themselves with ethics, transparency and accountability

1. Does the policy relating to ethics, bribery and corruption cover only the company? Yes/ No. Does it extend to the Group/Joint Ventures/ Suppliers/ Contractors/NGOs /Others?

The Company (together with its subsidiaries and controlled joint ventures of the Company) conducts and is committed to conducting all aspects of its business in keeping with the highest legal and ethical standards and expects all employees and other persons acting on its behalf to uphold this commitment. The Anti-Corruption Compliance and

Trade Control Compliance Policy is applicable to all directors, officers, employees, agents and other associated persons of the Company. The Vigil Mechanism and the Whistle Blower Policy of the

Company provides a mechanism for directors and employees of the Company to approach the Chairman of the Audit Committee of the Board to report genuine concerns about unethical behaviour, actual or suspected fraud or violation of the Companys Code of Conduct or any other unethical or improper activity.

2. How many stakeholder complaints have been received financial in the past year and what percentage was satisfactorily resolved by the management? If so, provide details thereof, in about 50 words or so.

During the financial year 2019-2020, the Company has received 12 complaints/queries from shareholders of the Company and all of them were satisfactorily resolved. The Stakeholders Relationship Committee of the Company specifically looks into various aspects of interest of shareholders, and other security holders of the Company.

During financial year 2019-2020 no complaints pertaining to sexual harassment were received or pending to be resolved by the Company. Similarly, the Company has not received any ‘Protected Disclosure or pending to be resolved under Whistle Blower Policy/Vigil Mechanism of the Company about unethical behavior, actual or suspected fraud or violation of the Code of Conduct or any other unethical or improper activity.

The Company has not received any other complaint from other stakeholders.

Principle 2 – Businesses should provide goods and services that are safe and contribute to sustainability throughout their life cycle

1. List up to 3 of your products or services whose design has incorporated social or environmental concerns, risks and/or opportunities.

The Company understands its obligations relating to social and environmental concerns, risks and opportunities. The Company ensures fulfillment of compliance obligations that relate to its products, environmental aspects and occupational health and safety. During the financial year under review, the Company was engaged in manufacturing of following main products; a) DRI/Sponge Iron b) Pellets c) Structural Steel/TMT

The products of the Company are manufactured in compliance with applicable laws, regulations and the products are supplied in Business to Business segment. The Companys manufacturing processes have adequate systems and processes which ensure protection of environmental factors like reduction of emissions, discharge of pollutants and hazardous waste and treatment thereof in systematic manner to minimize adverse environmental impact. The Company prioritizes domestic sourcing wherever possible. Efforts are also made to transport maximum cargo via ship/rail. The manufacturing process also takes care of other aspects like minimizing and treatment of occupational disease, safety measures to avoid accidents, fire / leakages by adopting certain measures including a) selecting right equipment, processes, inputs and tracking emissions b) organizing Safety awareness programs, safety training, structural audit. The

Company also provides employment opportunities to local people around its manufacturing plants.

2. For each such product, provide the following details in respect of resource use (energy, water, raw material etc.) per unit of product(optional):

a) Reduction during sourcing/production/ distribution achieved since the previous year throughout the value chain?

The Company is committed to environmental sustainability and constantly endeavors for reduction and optimal utilization of energy, water, raw material by incorporating new techniques and innovative ideas. The Company has two manufacturing facilities at Raipur and Raigarh, in the state of Chhattisgarh. Raigarh Plant of the Company is the major contributor to the overall revenue and production of the Company. In accordance with the applicable provisions of the Insolvency and Bankruptcy Code 2016 ("IBC/Code"), the Corporate Insolvency Resolution Process ("CIRP") of the Company was initiated by the Financial Creditor(s) of the Company in the financial year 2017-2018 and the petition of the creditors was admitted by the National Company Law Tribunal, Mumbai ("NCLT") on 18 July 2017.

The Honble NCLT vide its order dated 24 July 2018 approved the Resolution Plan submitted by consortium of JSW Steel Limited ("JSW Steel") and AION Investments Private II Limited ("AION") (AION together with JSW Steel, the "Consortium").

Thereafter a new Board was constituted w.e.f. 31 August 2018 ("Reconstituted Board" or "Board") and new management was put in place.

During the previous financial year 2018-2019, the Company was manufacturing only Sponge Iron for full financial and the integrated steel production including Blast Furnace,

Electrical Arc Furnace (Steelmaking), Ladle Refinery, Continuous Casting of Steel and Pellet plant was re-started at the Raigarh plant of the Company, with effect from 8 February 2019.

During financial year 2019-2020, the Company has taken shut down of the steel manufacturing operations/plants, other than Pellet Plant and DRI Plant, at its Raigarh plant, with effect from 21 June 2019, for necessary modifications and general maintenance. The Pellet Plant and DRI Plant of the Company at Raigarh locations were operating throughout the year while integrated steel operations were running for about four months. The integrated steel operations at the Raigarh Plant of the Company were re-started with effect from 02 March 2020 up to 25 March 2020. In view of 21 days nationwide lockdown advisory announced by the Government of India and other authorities to contain the spread of Corona Virus disease (COVID-19), the Company temporarily suspended all the manufacturing operations of its plants situated at Raipur and Raigarh both located in the State of Chhattisgarh with effect from 25 March 2020 till further notice.

Considering that the majority of manufacturing activities of the Company for the past two financial years were not fully operational, the details on the achievement in reduction of use of resource like energy, water, raw material are not strictly comparable to the previous financial year.

b) Reduction during usage by consumers (energy, water) has been achieved since the previous year?

The Company operates in Business to Business segment therefore the Companys products do not have any broad based impact in the reduction of consumption of energy and water by its consumers. The Company is generally committed to reduce waste, conservation of raw material, resources and energy through various initiatives, technological upgradation.

3. Does the company have procedures in place for sustainable sourcing (including transportation)? If yes, what percentage of your inputs was sourced sustainably? Also, provide details thereof, in about 50 words or so.

The Company has a structured procedure for sourcing to ensure raw materials are sourced in an optimal sustainable manner. The Company procures key raw material like Iron-Ore from Odisha, furnace oil from Raipur, fluxes from Rajasthan, Kutch, Chhattisgarh, Madhya Pradesh and LPG gases from local vicinity where the plant of the Company is located. The sourcing of raw materials like iron ore and coal were made through rail wagons and road transport.

In financial year 2019-2020 majority of inputs of the Company were sourced sustainably.

4. Has the company taken any steps to procure goods and services from local & small producers, including communities surrounding their place of work? If yes, what steps have been taken to improve their capacity and capability of local and small vendors?

The Company believes in inclusive growth and encourages local sourcing wherever possible. The Company is promoting and encouraging surrounding areas local small suppliers, civil, housekeeping, horticulture contractors and transporters which help them in securing work contracts. Most of such local suppliers categorized under MSME (Micro, Small & Medium Enterprises) sector. To ensure improvement of capacity and capability of such local suppliers the Company ensures the timely payments against the respective services rendered by them. The Company do avail/employ people residing in vicinity of plants of the Company, whenever required, for the purpose of its manufacturing activities. The Company is providing technical and safety training, as required in plant, which makes them more reliable and employable in safe ways.

5. Does the company have a mechanism to recycle products and waste? If yes what is the percentage of recycling of products and waste (separately as <5%, 5-10%, >10%). Also, provide details thereof, in about 50 words or so.

The waste management at the Company comprises of a collective activity involving collection, segregation, transportation, processing, recycling and disposal of various types of wastes. Effective utilization of resources and its management is the prime focus in all processes. The major solid waste is slag which is generated from Blast Furnace (BF) and Steel Melting Shop (SMS). Slag is sold to cement companies. Other solid waste products like metallurgical dust, Mill scale were used in the sinter plant.

Waste water generated is reused/ recycled for processes internally through STP plant. Consequently, entire solid and water waste is usually recycled fully.

During the year, apart from recycling/reusing waste, the Company has also internally reused/recycled all products extracted from Bars like end-cuts, skulls, which were used in SMS.

Principle 3 – Businesses should promote the wellbeing of all employees

2. Please indicate the total number of employees hired on temporary/contractual/casual basis: 2,114
3. Please indicate the number of permanent women employees: 42
4. Please indicate the number of permanent employees with disabilities: 2
5. Do you have an employee association that is recognized by management: Yes/NO No
6. What percentage of your permanent employees Not applicable
is members of this recognized employee association?

7. Please indicate the number of complaints relating to child labour, forced labour, involuntary labour, sexual financial harassment in the last year and pending, as financial on the end of the year.

Category No. of complaints pending at the beginning of the financial year No. of complaints filed during the financial year No. of complaints Resolved during the financial year No. of complaints pending as on end of the financial year
Child labor/ forced labor/ involuntary labor Nil Nil Nil Nil
Sexual harassment Nil Nil Nil Nil
Discriminatory employment Nil Nil Nil Nil

8. What percentage of your under mentioned employees were given safety & skill up-gradation training in the last year?

Sr. Category of employees No. % of training given at Raigarh location % of training given at Raipur location
a) Permanent Employees 80 80
b) Permanent Women Employees 77 0*
c) Casual/Temporary/ 100 90
Contractual Employees
d) Employees with Disabilities 100 -

* % derived in fraction, during the year total 3 women employees were given safety & skill up-gradation training.

Principle 4 - Businesses should respect the interests of, and be responsive towards all stakeholders, especially those who are disadvantaged, vulnerable and marginalized.

1. Has the company mapped its internal and external stakeholders? Yes/No

Yes. The stakeholders have been mapped and the key stakeholders are as follows: a) Government and regulatory authorities b) Investors and Shareholders c) Employees d) Customers e) Local Communities f) Suppliers/contractors. g) Lenders

The Stakeholders Relationship Committee of the Company specifically looks into various aspects of interest of shareholders, and other security holders of the Company. Also at plant locations the management engages with other stakeholders to understand and resolve any concern of the stakeholders.

2. Out of the above, has the company identified the disadvantaged, vulnerable & marginalized stakeholders.

Yes, as a part of its social activities, the Company has identified certain disadvantaged, and marginalized villages in proximity to its plants. The Company organizes medical health check up plans, free ambulance facilities catering to 10 villages, maintenance of street lights, vocational classes for women (stitching classes) and improvements in school infrastructures/arrangement of transportation.

3. Arethereanyspecialinitiativestakenbythecompany to engage with the disadvantaged, vulnerable and marginalized stakeholders. If so, provide details thereof, in about 50 words or so.

See 2 above.

The Company also encourages its employees to participate in various social activities.

Principle 5 - Businesses should respect and promote human rights

1. Does the policy of the company on human rights cover only the company or extend to the Group/Joint Ventures/Suppliers/Contractors/NGOs/Others?

The Company strictly follows highest ethics including protection of human rights while conducting its business activities. The Companys stand on human rights, including non-discrimination, prohibition of child and enforced labour, freedom of association and the right to engage in collective bargaining. The Companys Human Rights Policy aims to cover all its businesses processes and is part of its commitment to ethical and socially responsible behavior across its value chain. Currently the Human Rights Policy is applicable to the Company.

The Companys Policy for Prevention of Sexual Harassment of Women at workplace is applicable to all the employees including contractual and also covers contractual, temporary, visitors.

The Whistle Blower Policy/Vigil Mechanism of the Company also provides a mechanism for directors and employees of the

Company to approach the Chairman of the Audit Committee of the Board to report genuine concerns about unethical behaviour, actual or suspected fraud or violation of the Code of Conduct or any other unethical or improper activity.

The Company has also extended strong support to manpower by covering them in Group Personal Accident &

Group Mediclaim policy. The Company abides by all the rules and regulations related to human rights which are applicable in the area of operations.

2. How many stakeholder complaints have been received in the past financial year and what percent was satisfactorily resolved by the management?

The Company has not received any complaints pertaining to sexual harassment or principles related to human rights and there is no complaint pending to be resolved in this respect, during financial year 2019-2020.

Principle 6 - Business should respect, protect, and make efforts to restore the environment

1. Does the policy related to Principle 6 cover only the company or extends to the Group/Joint Ventures/ Suppliers/Contractors/NGOs/others.

The Company has a Policy on Conservation and Preservation of the Environment. All the plants of the Company maintain the generation of emissions and waste within the permissible limits given by Central Pollution Control Board of India (CPCB)/ State Pollution Control Boards (SPCB) to minimize adverse impact on environment.

The Company has adopted an integrated approach towards addressing biological diversity at various sites. Wastelands around the sites and open spaces within the premises are being converted into green belts, leading to reduced dust, improved micro-climate conditions, enhanced ambience for natural flora and fauna, reduction in evaporation losses of water, and so on. There are 4120 trees/plants at the Raigarh premises of the manufacturing plants of the Company during the year 2019-2020.

The Company while dealing with its suppliers/contractors and other concerned parties, always ensures to conducts its dealings in accordance with policy on Conservation and Preservation of the Environment.

2. Does the company have strategies/ initiatives to address global environmental issues such as climate change, global warming, etc? Y/N. If yes, please give hyperlink for webpage etc.

The Company understands the global issue of climate change and aims to possible actions to address it. The Company is committed to; i) Addressing environmental issues through efficient use of natural resources, promote use of renewable energy, minimization of wastes, water management, protecting the biodiversity and reducing carbon footprint. ii) Effective implementation of environmental management system to prevent, mitigate and control environmental damages.

In the financial year under review, various initiatives on energy saving, water saving, waste reduction etc. were implemented. Major activities in this regard taken were as under; a) LED lighting system Marginal investment has been made to adopt more efficient LED lighting system in place of conventional lighting system. At Raipur plant about 50 to 55 % of lighting has already been replaced by efficient

LED lighting system. Similarly at Raigarh location use of LED lighting system increased from 45% to 60%. b) Power generation from Sponge Iron unit –The waste heat generated during Sponge Iron production is utilized to generate steam and the same get converted into Power with the help of Waste heat recovery Boiler. During the financial year 2019-2020 Raipur plant has generated about 10 MW power, similarly Raigarh plant has generated about 23 MW power during said period.

3. Does the company identify and assess potential environmental risks? Y/N

Yes, the Company assesses the potential impacts of its operations on the environment through the implementation of the policy on Conservation and Preservation of the Environment. Potential environmental risks are identified by Risk Management Department. Once risk is identified, steps are taken to measure and mitigate risk through the

Management System approach.

4. Does the company have any project related to Clean Development Mechanism? If so, provide details thereof, in about 50 words or so. Also, if Yes, whether any environmental compliance report is filed?

The Company has not done any work so far in Clean Development Mechanism (CDM). However, it is increasing its efforts in sourcing energy from renewable sources like Solar. The Company has submitted Form-V (Environmental statement) to SPCB by respective plants under Environment Protection Act & rules.

5. Has the company undertaken any other initiatives on clean technology, energy efficiency, renewable energy, etc. Y/N. If yes, please give hyperlink for web page etc.


6. Are the Emissions/Waste generated by the company within the permissible limits given by CPCB/SPCB for the year being reported?

Yes, the emissions/waste generated by the Company are within the permissible limits given by CPCB/SPCB for air emissions, effluent quality and discharge, solid and hazardous waste generation and disposal.

7. Number of show cause/ legal notices received from CPCB/SPCB which are pending (i.e. not resolved to satisfaction) as on end of financial year.

As on 31 March, 2020, there was no pending show cause or legal notices received from CPCB or SPCB.

Principle 7 - Businesses, when engaged influencing public and regulatory policy, should do so in a responsible manner

1. Is your company a member of any trade and chamber or association? If Yes, Name only those major ones that your business deals with:

The Company is a member of Associated Chambers of

Commerce and Industry of India (ASSOCHAM), PHD Chamber of Commerce & Industry, Pellet Manufacturers Association of

India (PMAI) and Indian Steel Association.

2. Have you advocated/lobbied through above associations for the advancement or improvement of public good? Yes/No; if yes specify the broad areas (drop box: Governance and Administration, Economic Reforms, Inclusive Development Policies, Energy security, Water, Food Security, Sustainable Business Principles, Others)


Principle 8 - Businesses should support inclusive growth and equitable development

1. Does the company have specified programmes/ initiatives/projects in pursuit of the policy related to Principle 8? If yes details thereof.

The Company has voluntarily adopted a Corporate Social Responsibility (CSR) policy which governs the CSR activities of the Company are governed as per the said policy. As the average net profit of the Company during the previous three financial years was negative, it was not mandated to spend any amount on CSR during 2019-2020. The Company has however voluntarily incurred 1.48 crores on certain social initiatives (see response to question 4 below for additional details). As a responsible Corporate Citizen, after the closure of the financial year 2019-2020, the Company has also contributed to the Prime Ministers Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund) during the COVID-19 pandemic.

2. Are the programmes/projects undertaken through in-house team/own foundation/external NGO/ government structures/any other organization?

Voluntary social initiatives as mentioned hereinabove have been undertaken through support of Companys employees and nearby communities.

3. Have you done any impact assessment of your initiative?


4. What is your companys direct contribution to community development projects- Amount in and the details of the projects undertaken.

As the average net profit of the Company during the previous three financial years was negative, it was not mandated to spend any amount on CSR during 2019-2020.

Details of voluntary social initiatives for community development programs undertaken by the Company during the financial year 2019-2020 are as under;

Sr. No. Description voluntary social initiatives Nature of activity

Amount spent in crores

1 Running a school for all children in and around the plants Education 1.02
2 Occupational health care services, Dental camps. Health 0.36
3 Play school arrangement for families in and around the plants Community Development 0.08
4 Training in sewing for women and conducting examination Women empowerment 0.02
Total 1.48

5. Have you taken steps to ensure that this community development initiative is successfully adopted by the community? Please explain in 50 words, or so.

Identification and prioritization of community initiatives is done through participatory exercise at village level which is further endorsed by Gram Panchayats. The Company regularly engages with nearby villagers to ensure community development programs adopted by the respective beneficiaries are achieved with maximum possible benefits to the community.

Principle 9 - Businesses should engage with and provide value to their customers and consumers in a responsible manner

1. What percentage of customer complaints/consumer cases are pending as on the end of financial year-

None. The Company has received 39 quality-related complaints in respect of DRI and Pellets from customers, all of which were satisfactorily resolved.

2. Does the company display product information on the product label, over and above what is mandated as per local laws? Yes/No/N.A. /Remarks(additional information)

The Company displays product information on labels as mandated by law supplemented by additional information per requirements of the customer.

3. Is there any case filed by any stakeholder against the company regarding unfair trade practices, irresponsible advertising and/or anti-competitive is behaviour during the last five years and pending as on end of financial year. If so, provide details thereof, in about 50 words or so.


4. Did your company carry out any consumer survey/ consumer satisfaction trends?

As mentioned in Section C (3) above, during the financial year 2019-2020, the new management has undertaken repairs, maintenance, upgradation and modernization of the integrated steel operations at its Raigarh plant and operations are still stabilizing. The Company proposes to examine the need to carry out consumer surveys basis the market segment and the products dealt in by the Company and act accordingly.