Pithampur Poly Products Ltd Directors Report.

Your Director have pleasure in presenting their 23 Annual Report on the business and operation of the company and the accounts for the Financial year Ended 31 March,2020.

FINANCIAL PERFORMANCE OF THE COMPANY :

The financial results for the year ended 31st March, 2020 and the

corresponding figures for the last year are as under :-

(Rs. In Lacs)
Particulars 2019-20 2018-19
Total Income 100.07 791.43
Profit (Loss) before taxes and extraordinary items (177.51) (311.76)
Less: Extraordinary items 0.00 0.00
Profit (Loss)before tax (177.51) (311.76)
Deferred taxation (46.37) (53.77)
Net Profit/ (Loss) (131.14) (257.98)

STATE OF COMPANYS AFFAIRS :

The Company has achieved a total turnover of Rs. 10,007,851/- and Profit (Loss) after Tax of Rs. (13,114,496) which is transferred to General Reserve.

During the Year, Honble NCLT through their order dated 3rd January 2020 have discontinue the present Board of Directors of the Company and appointed Insolvency Resolution Professional (IRP) to start insolvency proceeding.

The above said order of the Honble NCLT have been set aside by NCLAT through their order dated 13th August 2020 and allowed the Board of Directors of the Company to function independently.

DIVIDEND :

Considering the financial performance, your directors regret to declare any dividend.

DIRECTORSS RESPONSIBILITY STATEMENT:

The Directors Responsibility Statement referred to in clause (c) of Sub- section (3) of Section 134 of the Companies Act, 2013 shall state that

1. in the preparation of the annual accounts, the applicable accounting standards had been followed along with proper explanation relating to material departures:

2. The director had selected such accounting policies and applied them 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 end of the financial year and of the profit and loss of the company for that period;

3. the director had taken proper and sufficient care for the maintenance of adequate accounting records in accordance with the provisions of this Act for safeguarding the assets of the company and for preventing and detecting fraud and other irregularities;

4. the directors had prepared the annual accounts on a going concern basis; and

5. the directors, in the case of a listed company, had laid down internal financial controls to be followed by the company and that such internal financial controls are adequate and were operating effectively.

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

CORPORATE GOVERNANCE

The Company has complied with the mandatory provisions on Corporate Governance as prescribed in the Regulation 27 of SEBI (Listing obligations and Disclosure Requirements) Regulations, 2015 with the Stock Exchanges. A separate report on Corporate Governance as per schedule V {C} of SEBI (Listing obligations and Disclosure Requirements) Regulations, 2015 is included as a part of the Annual Report along with the Auditors Certificate on its compliance.

RELATED PARTY TRANSACTIONS

All related party transactions that were entered into during the financial year were on an arms length basis and were in the ordinary course of business and that the provision of section 188 of the Companies Act,1956 is not attracted.

All Related Party Transactions are placed before the Audit Committee as also the Board for approval. Details of contracts/ arrangements/transactions with the related party are given in the notes to financial statements.

Form AOC-2 is attached herewith as Annexure B.

CORPORATE SOCIAL RESPONSIBILITY

The Company has incurred losses during the last three years, so the Company has not incurred any Corporate Social Responsibility expenditure during the year under review.

However, a Corporate Social Responsibility committee consisting Shri R.K. Tekriwal as the Chairman, Mrs. Meera Tekriwal and Mr. Vishwanath Kanungo, as member of the Committee. The board of directors have approved a policy on CSR.

RISK MANAGEMENT AND ADEQUACY OF INTERNAL FINANCIAL

CONTROLS

The Company does not have risk management policy as the elements of the risk threating the Companys existence are very minimal.

DIRECTORS

In terms of Section(s) 149, 152 and all other applicable provisions of the Companies Act, 2013, for the purpose of determining the directors liable to retire by rotation, the Independent Directors are not included in the total number of directors of the Company. Mrs. Meera Tekriwal (DIN 02014492), shall retire by rotation at the ensuing Annual General Meeting and being eligible, has offered herself for re-appointment as a Director of the Company.

The Board place on records its appreciation for valuable guidance and service rendered by Mrs. Meera Tekriwal (DIN 02014492) to the Company during her tenure.

In accordance with the provisions of Section 203 and Schedule V of the Companies Act, 2013 (the ‘Act), a person who has attained the age of 70 years can be appointed as managing director only by passing a special resolution, in which case, the explanatory statement annexed to the notice for such motion shall indicate the justification for appointing such person.

Accordingly, special resolutions are proposed to take shareholders approval for re-appointment of Shri R.K. Tekriwal as Chairman and Managing Director of the Company for the second term of five years w.e.f. 01.10.2020 to 30.09.2025.

As per Regulation 17(1A) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (‘LODR), as amended vide SEBI LODR (Amendment) Regulations, 2018 w.e.f. April 1, 2019, no listed entity shall appoint a person or continue the directorship of any person as a non-executive director who has attained the age of seventy five years unless a special resolution is passed to that effect and justification thereof is indicated in the explanatory statement annexed to the notice for such appointment.

Accordingly, special resolutions are proposed to take shareholders approval for re-appointment of Shri Anil Waman Jog as Independent Directors for the second term of five years w.e.f. 01.10.2020 to 30.09.2025.

Accordingly, special resolutions are proposed to take shareholders approval for re-appointment of Shri Vishwanath kanungo as Independent Directors for the second term of five years w.e.f. 06.06.2020 to 05.06.2025.

DECLARATION BY INDEPENDENT DIRECTORS

Necessary declarations have been obtained from all the Independent Directors under sub-section (7) of Section149 of the Companies Act, 2013.

MEETINGS

During the Financial year Six (6) Board Meetings and Three (3) Audit Committee Meetings were convened and held. The details of which are given in the Corporate Governance Report. The intervening gap between the Meetings was within the period prescribed under the Companies Act, 2013.

During the Year, Honble NCLT through their order dated 3rd January 2020 have discontinue the present Board of Directors of the Company and appointed Insolvency Resolution Professional (IRP) to start insolvency proceeding.

The above said order of the Honble NCLT have been set aside by NCLAT through their order dated 13th August 2020 and allowed the Board of Directors of the Company to function independently.

So, there is no board meeting held in the Fourth quarter of the financial year as the Board of Directors of the Company were discontinued.

PERFORMANCE EVALUATION OF BOARD, COMMITTEE AND

DIRECTORS

Pursuant to the Provisions of the Companies Act, 2013 and as stipulated under Chapter IV (17) (10) SEBI (Listing obligations and Disclosure Requirements) Regulations, 2015, the Board of Directors has carried out an annual evaluation of its own performance, performance of its directors individually as well as the evaluation of the working of its committees. The evaluation of all directors and the Board as whole was conducted based on the criteria and framework adopted by the Board.

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

AUDITORS AND AUDITOR REPORT

Pursuant to the provisions of section 139 and other applicable provisions, if any, of Companies Act, 2013 read with Rule 3 of Companies (Audit and Auditors) Rules, 2014, M/s. S.N. Gadia & Co., Chartered Accountants (FRN 002052C),Chartered Accountants, appointed as Auditor of the Company which was subject to rectification at every Annual General Meeting, be and is hereby ratified to hold office from the conclusion of this Annual General Meeting till the conclusion of next Annual General Meeting, on such remuneration as may be fixed by the Board.

A resolution proposing ratification of M/s. S.N. Gadia & Co., Chartered Accountants (FRN 002052C),Chartered Accountants, as the Statutory Auditors of the company pursuant to section 139 of the Companies Act, 2013 forms part of the Notice.

The notes on Financial Statements referred to in the Auditors Report are self-explanatory and do not call for any further comments.

SECRETRIAL AUDITOR AND SECRETRIAL AUDIT REPORT

Pursuant to the provisions of Section 204 of the Companies Act, 2013 and the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, the Company has appointed Ms. Harshita Modani, Company Secretary in Practice to undertake the Secretarial Audit of the Company. The Report of the Secretarial Audit Report is annexed herewith.

The Secretarial Audit report is self-explanatory.

SUBSIDIARY, JOINT VENTURE AND ASSOCIATE COMPANY

There were no subsidiary, JV and associate Company.

PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS

UNDER SECTION 186

Details of Loans:

There were NIL loans given, investment made or guarantee given or security provided as per the provisions of Section 186 of the Companies Act, 2013 . Deposit:

The Company has neither accepted nor renewed any deposits during the year under review.

PARTICULARS OF EMPLOYEES AND RELATED DISCLOSURE

Disclosures pertaining to remuneration and other details as required under Section 197(12) of the Act read with Rule 5(1) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 is not applicable.

EXTRACT OF ANNUAL RETURN

The extract of Annual Return in Form No.MGT-9 as required under Section 92 of the Companies Act, 2013 for the financial year ending March 31 , 2020 is annexed hereto as Annexure A and forms part of this report.

VIGIL MECHANISM / WHISTLE BLOWER POLICY

The Company has a Vigil Mechanism/Whistle Blower Policy to deal with instance of fraud and mismanagement, if any.

CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND

FOREGIN EXCHANGE EARNING AND OUTGO

The provisions of Section 134(m) of the Companies Act, 2013 do not apply to our Company. There was no foreign exchange inflow or Outflow during the year under review.

TRANSFER OF AMOUNTS TO INVESTOR EDUCATION AND

PROTECTION FUND

Your Company did not have any funds lying unpaid or unclaimed for a period of seven years. Therefore there were no funds which were required to be transferred to Investor Education and Protection Fund (IEPF).

MATERIAL CHANGES AND COMMITMENTS, IF ANY, AFFECTING THE FINANCIAL POSITION OF THE COMPANY WHICH OCCURRED BETWEEN THE END OF THE FINANCIAL YEAR OR THE COMPANY TO WHICH THE FINANCIAL STATEMENTS RELATE AND THE DATE OF THE REPORT

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

LISTING OF SHARES

The Companys shares are listed with BSE Limited. The Company has paid its annual listing fees for financial year 2019-20.

INDUSTRIAL RELATIONS

The Companys industrial relations continued to be healthy, cordial and harmonious during the period under review.

ENVIORMENT AND SAFETY

The Company is conscious of the importance of environment clean and safe operations. The Companys policy required conducts of operations in such a manner, so as to ensure safety of all concerned, compliances environmental regulations and preservation of natural resources.

GENERAL

Your Directors state that no disclosure or reporting is required in respect of the following items as there were no transactions on these items during the year under review:

a) Issue of equity shares with differential rights as to dividend, voting or otherwise.

b) Issue of shares (including sweat equity shares) to employees of the Company under any scheme.

c) Neither the Managing Director nor the Whole-time Directors of the Company receive any remuneration or commission from its subsidiary.

d) No significant or material orders were passed by the Regulators or Courts or Tribunals which impact the going concern status and Companys operations in future.

e) During the year under review, there were no cases filed or reported pursuant to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

ACKNOWLEDGEMENT

The Board desires to place on record its grateful appreciation for the excellent assistance and co-operation received and continued support extended to the Company by the bankers, investors, suppliers and esteemed customers and other business associates. Your Directors also wish to place on record their deep sense of appreciation to all the employees of the Company for their commitment and continued contribution in the performance of the company.

By order of the Board
Place: Pithampur R.K.Tekriwal
Date: 14/08/2020 (Chairman & Managing Director)
DIN:00011492

ANNEXURE-A

FORM MGT-9

EXTRACT OF ANNUAL RETRUN AS ON THE FINANCIAL YEAR ENDED 31 MARCH 2020

Pursuant to Section 92 (3) of the Companies Act, 2013 and rule 12(1) of the Company (Management & Administration) Rules,

2014.

I. REGISTRATION & OTHER DETAILS:

1 CIN L25202MP1994PLC008513
2 Registration Date 28/07/1994
3 Name of the Company PITHAMPUR POLY PRODUCTS LIMITED
4 Category/Sub-category of the Company COMPANY LIMITED BY SHARES NON GOVT. PUBLIC COMPANY
5 Address of the Registered office & contact details 115, SECTOR I, INDUSTRIAL AREA, PITHAMPUR DIST. DHAR (MP)
6 Whether listed company LISTED
7 Name, Address & contact details of the Registrar & Transfer Agent, if any. Purva Share Registry (I) Pvt. Ltd.
9,Shiv Shakti Industries, J.R. Boricha Marg, Opp/ Kasturba Hospital, Lower Parel (E)
Mumbai 400 011. Phone : [022] 23018261.

II. PRINCIPAL BUSINESS ACTIVITIES OF THE COMPANY

(All the business activities contributing 10 % or more of the total turnover of the company shall be stated)

S. No. Name and Description of main products / services NIC Code of the Product/service % to total turnover of the company
1 Manufacturing of FIBC and PP woven bags and fabric 63053200 100%

III. PARTICULARS OF HOLDING, SUBSIDIARY AND ASSOCIATE COMPANIES

S.No. Name and address of the Company CIN/GLN Holding/ Subsidiary/ Associate % of shares held Applicable Section
1 NIIL

IV. SHARE HOLDING PATTERN

(Equity share capital breakup as percentage of total equity)

(i) Category-wise Share Holding

Category of Shareholders

No. of Shares held at the beginning of the year

No. of Shares held at the end of the year

% Change
Demat Physical Total % of Total Shares Demat Physical Total % of Total Shares during the year
A. Promoters
(1) Indian
a) Individual/ HUF - 1805200 1805200 37.04% - 1805200 1805200 37.04% 0.00%
b) Central Govt - - - 0.00% - - - 0.00% 0.00%
c) State Govt(s) - - - 0.00% - - - 0.00% 0.00%
d) Bodies Corp. - 688300 688300 14.12% - 688300 688300 14.12% 0.00%
e) Banks / FI - - - 0.00% - - - 0.00% 0.00%
f) Any other - - - 0.00% - - - 0.00% 0.00%
Sub Total (A) (1) - 2493500 2493500 51.16% - 2493500 2493500 51.16% 0.00%
(2) Foreign
a) NRI Individuals - - - 0.00% - - - 0.00% 0.00%
b) Other Individuals - - - 0.00% - - - 0.00% 0.00%
c) Bodies Corp. - - - 0.00% - - - 0.00% 0.00%
d) Any other - - - 0.00% - - - 0.00% 0.00%
Sub Total (A) (2) - - - 0.00% - - - 0.00% 0.00%
TOTAL (A) - 2493500 2493500 51.16% - 2493500 2493500 51.16% 0.00%
B. Public Shareholding
1. Institutions
a) Mutual Funds - - - 0.00% - - - 0.00% 0.00%
b) Banks / FI - - - 0.00% - - - 0.00% 0.00%
c) Central Govt - - - 0.00% - - - 0.00% 0.00%
d) State Govt(s) - - - 0.00% - - - 0.00% 0.00%
e) Venture Capital Funds - - - 0.00% - - - 0.00% 0.00%
f) Insurance Companies - - - 0.00% - - - 0.00% 0.00%
g) FIIs - - - 0.00% - - - 0.00% 0.00%
h) Foreign Venture Capital Funds - - - 0.00% - - - 0.00% 0.00%
i) Others (specify) - - - 0.00% - - - 0.00% 0.00%
Sub-total (B)(1):- - - - 0.00% - - - 0.00% 0.00%
2. Non-Institutions
a) Bodies Corp.
i) Indian - 323200 323200 6.63% 10800 315400 326200 6.69% 0.06%
ii) Overseas - - - 0.00% - - - 0.00% 0.00%
b) Individuals
i) Individual shareholders holding nominal share capital upto Rs. 1 lakh 181500 1469500 1651000 33.87% 190200 1461800 1652000 33.89% 0.02%
ii) Individual shareholders holding nominal share capital in excess of - 236300 236300 4.85% - 236300 236300 4.85% -
Rs 1 lakh
c) Others (specify)
Non Resident Indians 10000 121500 131500 2.70% 12000 121500 133500 2.74% 0.04%
Overseas Corporate Bodies - 30000 30000 0.62% - 30000 30000 0.62% -
Employee - - - 0.00% - - - 0.00% -
Clearing Members 6000 - 6000 0.12% - - - 0.00% -0.12%
Trusts - - - 0.00% - - - 0.00% -
HUF 2500 - 2500 0.06% 2500 - 2500 0.06% -
Sub-total (B)(2):- 200000 2180500 2380500 48.85% 215500 2165000 2380500 48.85% 0
Total Public (B) 200000 2180500 2380500 48.85% 215500 2165000 2380500 48.85% 0
C. Shares held by Custodian for - - - 0.00% - - - 0.00% -
GDRs & ADRs
Grand Total (A+B+C) 200000 4674000 4874000 100% 215500 4658500 4874000 100% 0

(ii) Shareholding of Promoter

SN Shareholders Name

Shareholding at the beginning of the year

Shareholding at the end of the year

% change in share- holding during the year
No. of Shares % of total Shares of the company %of Shares Pledged / encumbered to total shares No. of Shares % of total Shares of the company %of Shares Pledged / encumbered to total shares
1 Diya Tekriwal 471500 9.67% 0 471500 9.67% 0 0.00%
2 Suchita Tekriwal 374293 7.68% 0 374293 7.68% 0 0.00%
3 Vistar Finvest & leasing Ltd. 279300 5.73% 0 279300 5.73% 0 0.00%
4 Pithampur Investment & Finance Ltd. 200000 4.10% 0 200000 4.10% 0 0.00%
5. Mohd Iqbal 116100 2.38% 0 116100 2.38% 0 0.00%
6. Pithampur Investment &Finance Ltd. 110700 2.27% 0 110700 2.27% 0 0.00%
7. R.K. Tekriwal 68100 1.40% 0 68100 1.40% 0 0.00%
8. Meera Tekriwal 58200 1.19% 0 58200 1.19% 0 0.00%
9. Gaurav Tekriwal 58400 1.20% 0 58400 1.20% 0 0.00%
10 Suchita Tekriwal 57600 1.18% 0 57600 1.18% 0 0.00%
11 Ashish Shekhar 238007 4.88% 0 238007 4.88% 0 0.00%
12 Vistar Finvest & Leasing Ltd. 49200 1.01% 0 49200 1.01% 0 0.00%
13 Vista Finvest & Leasing P. Ltd. 49100 1.01% 0 49100 1.01% 0 0.00%
14 Ashish Shekhar 20000 0.41% 0 20000 0.41% 0 0.00%
15 K S Lakhotiya 323500 6.64% 0 323500 6.64% 0 0.00%
16 Gaurav Tekriwal 17500 0.36% 0 17500 0.36% 0 0.00%
17 Ashish Shekhar 2000 0.04% 0 2000 0.04% 0 0.00%
Total 2493500 51.15% 0 2493500 51.15% 0 0

(iii) Change in Promoters Shareholding (please specify, if there is no change)

SN Particulars Date Reason

Shareholding at the beginning of the year

Cumulative Shareholding during the year

s No. of shares % of total shares No. of shares % of total shares
1. At the beginning of the year - - 2493500 51.15% 2493500 51.15%
2. Changes during the year NO CHANGE
3. At the end of the year - - 2493500 51.15% 2493500 51.15%

(iv) Shareholding Pattern of top ten Shareholders:

(Other than Directors, Promoters and Holders of GDRs and ADRs):

SN For each of the Top 10 shareholders Date Reason

Shareholding at the beginning of the year

Cumulative Shareholding during the year

No. of shares % of total shares No. of shares % of total shares
1. North American Investments ltd. - - 200000 4.10% 200000 4.10%
2. Shivratan Luharuka - - 143200 2.94% 143200 2.94%
3. Jamno Perumal Kalwanz - - 50000 1.03% 50000 1.03%
4. Peekay holdings Ltd. - - 50000 1.03% 50000 1.03%
Total 443200 9.09% 443200 9.09%

(v) Shareholding of Directors and Key Managerial Personnel:

SN Shareholding of each Directors and each Key Date Reason

Shareholding at the beginning of the year

Cumulative Shareholding during the year

Managerial Personnel No. of shares % of total shares No. of shares % of total shares
1. R.K. Tekriwal - - 68100 1.39% 68100 1.39%
2. Meera Tekriwal - - 58200 1.19% 58200 1.19%

V) INDEBTEDNESS

Indebtedness of the Company including interest outstanding/accrued but not due for payment.

Particulars Secured Loans excluding deposits Unsecured Loans Deposits Total Indebtedness
Indebtedness at the beginning of the financial year
i) Principal Amount 127075005 3999249 - 131074254
ii) Interest due but not paid - - - -
iii) Interest accrued but not due - - - -
Total (i+ii+iii) 127075005 3999249 - 131074254
Change in Indebtedness during the financial year
* Addition - - - -
* Reduction - - - -
Net Change - - - -
Indebtedness at the end of the financial year
i) Principal Amount 106322644 3999249 - 110321893
ii) Interest due but not paid - - - -
iii) Interest accrued but not due - - - -
Total (i+ii+iii) 106322644 3999249 - 110321893

VI. REMUNERATION OF DIRECTORS AND KEY MANAGERIAL PERSONNEL

A. Remuneration to Managing Director, Whole-time Directors and/or Manager:

SN. Particulars of Remuneration Name of MD/WTD/ Manager Total Amount
Name RAJENDRA TEKRIWAL (Rs/LAC)
Designation MD
1 Gross salary 360000 360000
(a) Salary as per provisions contained in section 17(1) of the Income-tax Act, 1961 -
(b) Value of perquisites u/s 17(2) Income-tax Act, 1961 -
(c) Profits in lieu of salary under section 17(3) Income- tax Act, 1961 -
2 Stock Option -
3 Sweat Equity -
4 Commission -
- as % of profit -
- others, specify -
5 Others, please specify -
Total (A) - 360000
Ceiling as per the Act As per Act

B. Remuneration to other Directors

SN. Particulars of Remuneration Name of Directors Total Amount
Vishwanath Kanungo Anil Waman Jog (Rs/Lac)
1 Independent Directors
Fee for attending board committee meetings 15000 15000 30000
Commission -
Others, please specify -
Total (1) - - - -
2 Other Non-Executive Directors Meera Tekriwal -
Fee for attending board committee meetings -
Commission -
Others, please specify 360000 360000
Total (2) - - - 390000
Total (B)=(1+2) - - - 750000
Total Managerial Remuneration
Overall Ceiling as per the Act As per Act

C. Remuneration to Key Managerial Personnel other than MD/Manager/WTD

SN. Particulars of Remuneration

Name of Key Managerial Personnel

Total Amount
Name (Rs/Lac)
Designation CEO CFO CS
1 Gross salary
(a) Salary as per provisions contained in section 17(1) of the Income-tax Act, 1961 -
(b) Value of perquisites u/s 17(2) Income-tax Act, 1961 -
(c) Profits in lieu of salary under section 17(3) Income- tax Act, 1961 -
2 Stock Option -
3 Sweat Equity -
4 Commission
- as % of profit -
- others, specify -
5 Others, please specify -
Total - - - -

VII. PENALTIES / PUNISHMENT/ COMPOUNDING OF OFFENCES:

Type Section of the Companies Act Brief Description Details of Penalty / Punishment/ Compounding fees imposed Authority [RD / NCLT/ COURT] Appeal made, if any (give Details)
A. COMPANY
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL
B. DIRECTORS
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL
C. OTHER OFFICERS IN DEFAULT
Penalty NIL NIL NIL NIL NIL
Punishment NIL NIL NIL NIL NIL
Compounding NIL NIL NIL NIL NIL
By order of the Board
R.K.Tekriwal
(Chairman & Managing Director)
DIN:00011492

Place: Pithampur

Date: 14/08/2020

Form No. AOC-2

(Pursuant to clause (h) of sub-section (3) of section 134 of the Act and Rule 8(2) of the Companies (Accounts) Rules, 2014)

Form for disclosure of particulars of contracts/arrangements entered into by the company with related parties referred to in sub-section

(1) of section 188 of the Companies Act, 2013 including certain arms length transactions under third proviso thereto.

1. Details of contracts or arrangements or transactions not at arms length basis: NOT APPLICABLE

2. Details of material contracts or arrangement or transactions at arms length basis:

PARTICULARS (1) (2) (3) (4)
Name(s) of the related party and nature of relationship Bulkpack Exports Limited ---
Nature of contracts/arrangements/transactions Sales service & other income ---
Duration of the contracts / arrangements/transactions 1 Year
Salient terms of the contracts or arrangements or 7,597,783
transactions including the value, if any date(s) of approval by the Board N.A N.A N.A N.A
By order of the Board
Place: Pithampur R.K.Tekriwal
Date: 14/08/2020 (Chairman & Managing Director)
DIN:00011492