National Steel & Agro Industries Ltd Directors Report.

Dear Members,

Your Directors hereby present the Thirty Fifth Annual Report on the business and operations of the Company along with the Audited Statement of Accounts for the Financial Year ended 31st March, 2021.

FINANCIAL RESULTS (Rs. in Lakhs)
PARTICULARS Year ended Year ended
31.03.2021 31.03.2020
Revenue from Operations 1,57,848 1,30,933
Earning Before Interest, Tax, Depreciation and Amortisation (EBITDA) (644) (621)
Finance Cost 19,758 18,242
Depreciation 4,870 4,864
Profit/(Loss) Before Tax (PBT) Provision for :- (25,272) (23,727)
Income Tax/Adjusted for earlier years (Net) - 13
Deferred Tax (Assets)/Liabilities (2,532) 5,343
Profit/(Loss) After Tax (PAT) (22,740) (29,083)
Networth (1,25,558) (1,01,873)

FINANCIAL PERFORMANCE OF THE COMPANY

During the year under review, the revenue from operations is 1,57,848 Lakhs [Previous Year 1,30,933]. The Earning Before Interest, Tax, Depreciation and Amortisation (EBITDA) is (644) Lakhs [Previous year (621) Lakhs]. The Loss Before Tax has been (25,272) Lakhs [Previous Year (23,727) Lakhs] and Loss After tax is (22,740) Lakhs [Previous Year (29,083) Lakhs].

OPERATIONAL PERFORMANCE OF THE COMPANY

The disastrous outbreak of Covid-19 pandemic resulted in lockdown/travel restrictions on the movement of people to contain the spread of the virus. However, the plant facilities (Steel Sector) were exempt from the lockdown measures, subject to adherence of hygiene standards and social distancing norms.

During the year under review, the Company has utilized 86% (approx) of its production capacity of its Colled Rolling Mill, Galvanized Plant and Color Coating Line.

The details of the product wise performance of the Company have been covered under the Management Discussion and Analysis section of the Annual Report.

RE-CLASSIFICATION OF PROMOTERS

During the year under review, requests received from four (4) members of promoters/promoter group of the Company have been approved by the Board of the Directors for re-classification of their shareholding from Promoter & Promoter Group Category to Public Category and Removal of names from Promoter and Promoter Group Category.

The resolution seeking shareholders approval to the above forms part of the Notice convening the Thirty Fifth (35th) Annual General Meeting.

MANAGEMENT DISCUSSION AND ANALYSIS

Management Discussion and Analysis, forming part of this report as required under Regulation 34 of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015{here in after referred as SEBI (LODR) Regulations, 2015},is attached separately to this Report.

TRANSFER TO RESERVE, IF ANY

In absence of the profits, the Company does not propose to transfer any amount to Reserves.

DIVIDEND

In absence of divisible profits, the Board has not recommended any dividend during the year under review.

SHARE CAPITAL

During the year under review, there was no change in the issued and paid-up share capital of the Company.

DIRECTORS AND KEY MANAGERIAL PERSONNEL

During the year under review, members of the Company at Thirty Fourth Annual General Meeting (34th AGM) have approved the re-appointment of Mr. Santosh Shahra as a Whole-Time Director of the Company, designated as Executive Chairman w.e.f 17th December, 2019 and appointment of Mr. Manoj Khetan as a Whole-Time Director of the Company designated as Whole-Time Director & CFO w.e.f. 30th December, 2019.

Pursuant to the recommendation of Nomination and Remuneration Committee, the Board of Directors has appointed Mr. Sumit Mittal as an Independent Director of the Company w.e.f 12th February, 2021.

The Independent Directors have submitted the Declaration of Independence in accordance with Section 149(7) of the Companies Act, 2013 (the Act) and Regulations 16(1)(b) and 25(8) of the SEBI (LODR) Regulations, 2015 that he/she meets the criteria of independence as laid out in the Act and SEBI (LODR) Regulations, 2015.

In the opinion of the Board, there has been no change in the circumstances which may affect their status as Independent Directors of the Company and the Board is satisfied of the integrity, expertise, and experience (including proficiency in terms of Section 150 (1) of the Act and applicable rules there under) of all Independent Directors on the Board. In terms of Section 150 read with Rule 6 of the Companies (Appointment and Qualification of Directors) Rules, 2014, Independent Directors of the Company have under taken requisite steps towards the inclusion of their names in the data bank of Independent Directors maintained with the Indian Institute of Corporate Affairs.

RETIRE BY ROTATION

Pursuant to the provisions of Section 152 of the Companies Act, 2013, Mr. Manoj Khetan, Whole-Time Director & CFO of the Company, retires by rotation and being eligible, offers himself for re-appointment.

BOARD EVALUATION

Pursuant to the applicable provisions of the Companies Act, 2013 and SEBI (LODR) Regulations, 2015, the Board has carried out an annual performance evaluation of its own performance, its Committees and the Directors. The manner in which the evaluation has been carried out, explained in the Corporate Governance Report.

AUDIT COMMITTEE

The Audit Committee comprises of below mentioned directors:

Name Category Designation
Mr. Rajesh Nema Independent Director Chairman
Mr. Ashutosh Upadhyay Independent Director Member
Mr. Santosh Shahra Executive Director Member

There are no recommendations of the audit committee which have not been accepted by the board during the year under review.

Details of terms of reference of Audit Committee and meetings of Audit Committee held during they ear under review have been given in Corporate Governance Report.

NOMINATION AND REMUNERATION POLICY

The Board has, on there commendation of the Nomination & Remuneration Committee, framed a policy for selection and appointment of Director(s), Senior Management Personnel and their remuneration. The salient features of the Policy are:

^ It acts as a guideline for matters relating to appointment, remuneration, removal and evaluation of directors, Key Managerial Personnel and Senior Management Personnel.

^ It contains guidelines for determining qualifications,positive attributes of directors, and independence of a Director.

^ It lays down the criteria for Board Membership and the approach of the Company on board diversity.

^ It lays down the criteria for determining independence of a director, in case of appointment of an

Independent Director.

^ It lays down the parameters based on which payment of remuneration (including sitting fees and remuneration) should be made to Independent Directors (IDs) and Non-Executive Directors (NEDs).

^ It lays down the parameters based on which remuneration (including fixed salary, benefits and perquisites, bonus/performance linked incentive, commission, retirement benefits) should be given to whole-time directors, KMPs and Senior Management.

During the year under review there were no changes in the Policy and the same is available on the website of the Company at http://nsail.com/downloads/Nomination % 20&%20 Remuneration %20 Policy. pdf. The composition of the Nomination & Remuneration Committee has complied with the requirements of the provisions of Section 178 of the Companies Act, 2013 and of Regulation 19 the SEBI (LODR) Regulations, 2015.

Details of terms of reference of Nomination & Remuneration Committee and meetings of Nomination & Remuneration Committee held during the year under review have been given in Corporate Governance Report.

BOARD MEETINGS

During the year under review 5 (five) Board Meetings were held on 31st July, 2020, 2nd September, 2020, 15th September, 2020, 10th November, 2020 and 12th February, 2021. The details of the Board Meetings are given in the Corporate Governance Report.

The intervening gap between the meetings was within the period prescribed under the Companies Act, 2013 and the SEBI (LODR) Regulations, 2015.

DIRECTORS RESPONSIBILITY STATEMENT

Pursuant to the provisions of Section 134 of the Companies Act, 2013, your Directors confirm that:

a) in the preparation of the annual accounts for the financial year ended 31st March, 2021, the applicable Accounting Standards had been followed along with proper explanation relating to material departures, if any;

b) the Accounting Policies had been selected and applied consistently and made judgments and estimates that are reasonable and prudent so as to give a true and fair view of the state of affairs of the Company at the financial year ended 31st March, 2021 and of the loss of the Company for that period;

c) proper and sufficient care had been taken for the maintenance of adequate accounting records in accordance with the provisions of the Companies Act, 2013 for safeguarding the assets of the Company and for preventing and detecting fraud and other irregularities;

d) the Annual Accounts had been prepared on a going concern basis;

e) Internal Financial Controls were laid down to be followed and that these controls were adequate and operating effectively; and

f) proper systems to ensure compliance with the provisions of all applicable laws were in place and were adequate and operating effectively.

RELATED PARTY TRANSACTIONS

Proper systems to ensure compliance with the provisions of all applicable laws were in place and were adequate and operating effectively.

All Related Party Transactions were placed before the Audit Committee and the Board of Directors, pursuant to applicable provisions of SEBI (LODR) Regulations, 2015 & Companies Act, 2013. Omnibus approval of the Audit Committee has been obtained for entering into related party transactions. The transaction entered into pursuant to the omnibus approval so granted are audited and a statement giving details of all related party transactions is placed before the Audit Committee and the Board of Directors.The policy on Related Party Transactions as approved by the Board, is available at the Companys website at www.nsail.com.

Details of Related Party Transactions are given in "Annexure-A."

RISK MANAGEMENT

The Board has constituted a Risk Management Committee to assess risks in the operations of business of the Company, to mitigate and minimise risks assessed, periodic monitoring of risks and other matters to be delegated to the Committee by the Board from time to time.

Following are the members of the Committee :

1. Mr. Santosh Shahra : Chairman
2. Mr. Rajesh Nema : Member
3. Mr. Ashutosh Upadhyay : Member

CORPORATE SOCIAL RESPONSIBILITY

During the period under review, the Company is not required to spend towards Corporate Social Responsibility (CSR).

The annual report on Corporate Social Responsibility (CSR) containing, details of CSR Policy, composition of CSR Committee, CSR projects undertaken and web-link thereto on the website of the Company, as required under Companies (Corporate Social Responsibility Policy) Rules, 2014, is set out in "Annexure - B" forming part of this Report.

AUDITORS

(a) Statutory Auditors :

The Equity Shareholders of the Company in their Thirty Third Annual General Meeting held on 6thAugust, 2019 had accorded their approval pursuant to the provisions of Sections 139 and other applicable provisions of Companies Act, 2013 and Rules made there under to appoint M/s. Fadnis & Gupte, Chartered Accountants (FRN No. 006600C), as the Statutory Auditor of the Company for the period of five years commencing from the conclusion of Thirty Third Annual General Meeting until the conclusion of Thirty Eighth Annual General Meeting.

Any qualification, reservation, adverse remark or disclaimer in the Auditors Report to the Members read alongwith notes to the accounts are self explanatory, needs no further clarification or explanation. Further, no fraud has been reported by the Auditors under section 143(12) of the Companies Act, 2013 requiring disclosure in the Boards Report.

(b) Cost Auditors :

Pursuant to Section 148(1) of the Companies Act, 2013 your Company is required to maintain cost records as specified by the Central Government and accordingly such accounts and records are made and maintained.

Pursuant to the provisions of Section 148(2) read with the Companies (Cost Records and Audit) Amendment Rules, 2014, your Company is also required to get its cost accounting records audited by a Cost Auditor. Accordingly, the Board of your Company had appointed M. Goyal & Co., Cost Accountants (FRN No. 000051) as the Cost Auditor of the Company for the financial year 2020-21. The Cost Audit Report with Annexure shall be submitted alongwith full information and explanation on every reservation or qualification contained therein, if any, to the Central Government within stipulated time period.

The Cost Audit Report for the financial year ended 31st March, 2020 was filed with the Central Government (Ministry of Corporate Affairs) vide SRN R67438861 dated 16th October, 2020.

(c) Secretarial Auditor :

Pursuant to the provisions of Section 204 of the Companies Act, 2013 and the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, the Company had appointed Mr. Ashish Garg, Company Secretary in Practice (FCS5181/CP4423) to undertake the Secretarial Audit of the Company.

The Secretarial Audit Report is annexed herewith as "Annexure-C". The Secretarial Audit Report does not contain any qualification, reservation or adverse remark or disclaimer except as under:

i. In respect of improper composition of Board of the Company; owing to falling under top 2000 listed entities determined on the basis of market capitalization as at the end of the immediate previous financial year, the Company was required to have atleast six directors on the Board. However, the Board of the Company comprises of five directors. The Company has appointed Mr. Sumit Mittal as Independent Director of the Company w.e.f. 12th February, 2021.

ii. In respect of SEBI ex-parte ad-interim order; SEBI has passed final Order No. WTM/AB/IVD/ ID11/8666/2020-2021 dated 12th August, 2020 revoking the directions of restraining the Company from buying, selling or dealing in the securities market either directly or indirectly with immediate effect.

iii. In respect of case filed before Debt Recovery Tribunal (DRT) by the lender banks; The Company has adopted legal course of action to defend the same.

iv. In respect of Applications/Petitions filed under the Insolvency and Bankruptcy Code, 2016;The Company is taking necessary legal recourse to defend the same.

ENERGY CONSERVATION, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND OUTGO

The information on conservation of energy, technology absorption and foreign exchange earnings and outgo stipulated under Section 134(3)(m) of the Companies Act, 2013 read with Rule 8 of the Companies (Accounts) Rules, 2014 is annexed herewith as "Annexure-D".

EXTRACT OF ANNUAL RETURN

The Annual Return as required under Section 92 and Section 134 of the Companies Act, 2013 read with Rule 12 of the Companies (Management and Administration) Rules, 2014 is available on the Companys website at https://www.nsail.com/downloads/Draft_Annual_Return_%202020-21.pdf.

PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS

Details of Loans, Guarantees and Investments covered under the provisions of Section 186 of the Companies Act, 2013 are given in the Notes to the Financial Statements and are within the limits.

PARTICULARS OF JOINT VENTURE, SUBSIDIARY & ASSOCIATE COMPANY

The Company does not have any joint venture, subsidiary or associate company during the year. INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY

The Company has adopted policies and procedures for ensuring the orderly and efficient conduct of its business, including adherence to the Companys Policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of accounting records and the timely preparation of financial disclosures.

The Company has an Internal Control System commensurate with the size, scale and complexity of its operations. These are routinely tested and certified by Statutory as well as Internal Auditor. Significant audit observations and corrective action are reported to the Audit Committee.

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

VIGIL MECHANISM/WHISTLE BLOWER POLICY

Your Company has formulated a mechanism called "Vigil Mechanism/ Whistle Blower Policy" for directors and employees to report to the management instances of unethical behavior, actual or suspected fraud or violation ofthe Companys Code of Conduct and provided a framework to protect employees wishing to raise a concern about serious irregularities within the Company.

The policy permits all the directors and employees to report their concerns to the Competent Authority, Executive Chairman/Executive Director of the Company and if the Whistle Blower believes that there is a conflict of interest between the Competent Authority and the Whistle Blower, he/she may send his/her protected disclosure directly to the Chairman of the Audit Committee.

The policy with the name and address of the Competent Authority, Executive Chairman/Executive Directorof the Company and Chairman of the Audit Committee has been communicated to the employees by uploading the same on the website of the Company.

DEPOSITS

Your Company did not accept any deposit from the Public during the year under review.

INSURANCE

Your Companys Fixed Assets have been adequately insured.

CORPORATE GOVERNANCE

Your Company has been particular in implementing and complying with the norms of Corporate Governance and complying all the mandatory requirements as specified in Regulations 17 to 27, clause (b) to (i) and (t) of sub-regulation (2) of Regulation 46 and paragraph C, D and E of Schedule V of the SEBI (LODR) Regulations,2015. A detailed report on Corporate Governance along with Certificate from Practicing Company Secretary confirming the compliance of the conditions of Corporate Governance is attached separately to this Report.

PARTICULARS OF EMPLOYEES

In terms of the provisions of Section 197(12) of the Companies Act, 2013 read with Rule 5 of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, a statement showing the names and other particulars of the employees drawing remuneration in excess of the limits setout in the said rules are provided in "Annexure-E", forming part of this report.

DISCLOSURE AS PER SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (PREVENTION, PROHIBITION AND REDRESSAL) ACT, 2013

The Company has zero tolerance towards sexual harassment at the workplace and to this end, has adopted a policy in line with the provisions of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. The Company has complied with the Constitution of Internal Compliant Committee under Sexual Harassment of Women at Workplace (Prevention,Prohibition and Redressal) Act, 2013.

Your Directors state that during the year under review, there was no complaint filed/pending pursuant to the provisions of "Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013".

MATERIAL CHANGES AND COMMITMENTS

There is no material change and commitment has occurred, affecting the financial position of the Company, between the end of the financial year of the Company i.e. 31st March, 2021 and the date of this report except:

1. A review petition was filed by Madhya Pradesh Paschim Kshetra Vidyut Vitaran Company Limited (MPPKVVCL) for reviewing the order passed by the Honble High Court, Madhya Pradesh (MP) in Writ Petition (WP) No. 22734 of 2017 wherein court had directed MPPKVVCL to issue fresh demand in connection with the demand raised by MPPKVVCL for the period from May 2009 to May 2016, without penalty but with interest calculated as per agreement rate. The review petition was allowed by the Honble High Court of MP by its order dated 13th May, 2020 ("May 2020 Court Order"). There after, MPPKVVCL had issued a demand notice for 79.18 Crores, including interest calculated at the rate of 16% per annum compounded in every six months, for the period from 12th June, 2015 to 31st May, 2020 along with an amount of 31.46 Crores which was due to be paid. There after, Company has filed Special Leave Petition (SLP) before Honble Supreme Court. The SLP was allowed and order passed in Writ Petition 22734 of 2017 and order passed in Review Petition 1765 of 2018 have been dismissed and MPPKVVCL has been instructed to consider the representations made by the Company to MPPKVVCL but MPPKVVCL has dismissed request made by the Company, therefore, a Writ Petition No. 7851 of 2021 has been filed which is pending for hearing with the Honble High Court of MP, Indore Bench.

SIGNIFICANT AND MATERIAL ORDERS PASSED

Following are the significant and material orders passed during the year under review:

1. An application, under Section 9 of Insolvency and Bankruptcy Code, 2016, had been admitted against the Company on June 09, 2020. Thereafter, dues were settled by the company through a settlement deed with the applicant "Argrocorp International Pte. Ltd.". Upon settlement, an application for withdrawal of the insolvency proceeding was filed. NCLT has dismissed the insolvency proceeding by allowing the said application by its order dated June 23, 2020.

2. An award had been passed against the company in the matter of Arbitration at Hongkong initiated by Smart Timing Steel Ltd (STSL). STSL got the award confirmed from High Court of Mumbai and it has initiated execution against the company by attaching one of its properties and in process to put the said property on auction. Simultaneously, STSL filed a petition under Insolvency and Bankruptcy Code, 2016 (IBC) before National Company Law Tribunal (NCLT), Mumbai, which was dismissed by NCLT. STSL has preferred an appeal before National Company Law Appellant Tribunal, Delhi (NCLAT) against the order of NCLT and the same is dismissed. Further, STSL has filed a civil appeal to Supreme Court which is pending for hearing.

3. In August 2010, the Company has started obtaining electricity through open access (from outside the state). Government of Madhya Pradesh (MP) enacted Vidyut Shulk Adhiniyam, 2012 whereby electricity duty was imposed on the consumption of electricity through open access in the state.

The Company had challenged the collection of electricity duty by filing writ petition in High Court of MP which was dismissed thereafter, the order was challenged in Supreme Court but same had been dismissed on December 19, 2019. Now, the Company has started making payment of amount of electricity duty and interest thereon in installments. The Company has paid an amount of 1.25 Crores against the total demand of 10.50 Crs. (including interest 24% p.a. on principal amount) till date.

ASSIGNMENT OF DEBT OF THE COMPANY

On 31st March, 2021, five (5) lender banks of the Company namely, IDBI Bank Limited, State Bank of India, Union Bank of India (earlier Andhra Bank), Central Bank of India and Bank of Maharashtra [collectively hereinafter referred as "Banks"] through a Joint Assignment Agreement, has assigned their debt extended to the Company to JM Financial Asset Reconstruction Company Limited ("JMFARC") along with all underlying securities, rights, title, and interest thereof.

DETAILS OF APPLICATION MADE OR ANY PROCEEDING PENDING UNDER THE INSOLVENCY AND BANKRUPTCY CODE, 2016 (31 OF 2016) ALONGWITH THEIR STATUS AS AT THE END OF THE FINANCIAL YEAR 2020-21

The details of applications/petitions filed under the Insolvency and Bankruptcy Code, 2016 (IBC) by/ against the Company are as under:

A. Insolvency Proceedings to which Company is/was Respondent:

S. No. Particulars Type of Creditor Case No. and Forum before which the matter is/was pending. Amount involved Status as at the end of the Financial Year
1. Agrocorp International Pte. Ltd. Operational Creditor National Company Law Tribunal, Mumbai Bench. [C.P. (IB)-798(MB)/ 2019] USD 978,508 equivalent to 7,16,75,711. Withdrawn by NCLT Order CP(IB) No. 798/MB)C-IV /2019 dated June 9, 2020 pursuant to settlement agreement entered between the parties.
2. Korea Trade Insurance Corporation Operational Creditor National Company Law Tribunal, Mumbai Bench. [C.P. (IB)- 4169(MB)/ 2019] USD 3,500,960 equivalent to 24,58,37,439/- Pending before the NCLT.
3. Ripley & Co. Stevedoring & Handling Private Limited Operational Creditor National Company Law Tribunal, Mumbai Bench. [C.P. (IB)- 1869(MB)/ 2019] 77,85,271/- Pending before the NCLT.
4. Smart Timing Steel Limited Operational Creditor Supreme Court of India. (Civil Appeal No. 9435 of 2019) USD 426,494 and HKD 769,654 equivalent to 3,76,69,550/- Pending before Supreme Court
5. Bank of India Financial Creditor National Company Law Tribunal, Mumbai Bench. [C.P. (IB)- 2067(MB)/ 2019] 127,80,95,977/- Pending before the NCLT.

B. Insolvency Proceedings to which Company is/was Plaintiff:

S. No. Particulars Type of Debtor Case No. and Forum before which the matter is/was pending. Amount involved (in Rs.) Status as at the end of the Financial Year
1. Rite Bite Trading Private Limited Operational Debtor National Company Law Tribunal, Mumbai Bench. [C.P. (IB)-1459 (MB)/ 2020] 78,61,05,760/- Pending before the NCLT
2. Mitesh Trading Private Limited Operational Debtor National Company Law Tribunal, Mumbai Bench. [C.P. (IB)- 3231(MB)/ 2019] 40,39,41,054/- Pending before the NCLT.
3. Shimita Trading Private Limited Operational Debtor National Company Law Tribunal, Mumbai Bench. [C.P. (IB)- 2510(MB)/ 2019] 13,14,80,928/- Pending before the NCLT.

DETAILS OF DIFFERENCE BETWEEN AMOUNT OF THE VALUATION DONE AT THE TIME OF ONE TIME SETTLEMENT AND THE VALUATION DONE WHILE TAKING LOAN FROM THE BANKS OR FINANCIAL INSTITUTIONS ALONG WITH THE REASONS THEREOF:

The Company proposed One time Settlement (OTS) to its Lender Banks which was approved by 70% (approx) of its lenders. However, in the absence of arrangement of requisite funds, the proposal was withdrawn. Accordingly, the clause is not applicable to the Company during the year under review.

SECRETARIAL STANDARDS

The Company has in place proper systems to ensure compliance with the provisions of the applicable Secretarial Standards issued by The Institute of Company Secretaries of India (ICSI) and such systems are adequate and operating effectively.

ACKNOWLEDGEMENT

The Board of Directors take this opportunity to express their gratitude to the Central Government, State Government and Local Authorities, Lenders, Customers, Dealers, Vendors and all the stakeholders for their continued cooperation and support to your Company.

The Board of Directors wishes to express its appreciation to all the employees of the Company for their continuous contribution in the COVID-19 era towards successful operations of the Company. The Board also wishes for better health of its Stakeholders and hope for faster recovery from the current pandemic and look for prosperity, growth and constructive development of our country and world at large.

The Board specially thank to the shareholders for their continued confidence and faith in the Company.

For and on behalf of the Board of Directors
Place : Indore Santosh Shahra
Date : 30th June 2021 Executive Chairman