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Shreenath Investment Company Ltd Directors Report

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Feb 18, 2025|12:00:00 AM

Shreenath Investment Company Ltd Share Price directors Report

To,

The Members

Shreenath Investment Company Limited

Your Directors are pleased to present herewith 46 th Annual Report on the business and operation of the Company together with the Audited Financial Statement of your Company for the Financial Year ended 31 st March, 2026.

The State of the Company s Affairs:

During the financial year under review, the Company continued to carry on its principal business activities in accordance with its main objects. The Company continued to focus on its investment activities and management of its investment portfolio.

1. The financial performance of the Company during the year under review, as compared with the previous financial year, is set out below:

KEY FINANCIAL HIGHLIGHTS:

Particulars For the Year ended 31 st March, 2026 For the Year ended 31 st March, 2025
(Rs. In lacs) (Rs. In lacs)
Income 643.14 829.86
Expenditure 386.45 505.29
Profit/(Loss) before Depreciation and Tax 257.41 325.20
Depreciation 0.72 0.63
Profit/(Loss) before Tax 256.69 324.57
Deferred Tax/Current Tax 93.36 99.03
Profit/(Loss) after Tax 163.33 225.54

During the year under review your Company has reported a Net Profit of Rs. 163.33 Lakhs against Net profit of Rs. 225.54 Lakhs in the previous financial year.

2. DIVIDEND:

With a view to plough back the profits of the Company for future growth, your directors do not recommend dividend for the year ended 31 st March, 2026.

3. TRANSFER TO RESERVES:

Your Company has transferred during the financial year ended 31st March, 2026, amount of Rs.163.33/- Lakhs as against Rs. 225.54/- Lakhs in the financial year ended 31st March, 2025 to the Retained Earnings out of the profit available for appropriation.

4. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND OUTGO (SECTION 134 (3) (m) OF THE COMPANIES ACT,2013:

With the kind of activities carried out by the Company, it has not spent any substantial amount on conservation of energy and technology absorption stipulated under Section 134(m) of the Companies Act, 2013.

5. FOREIGN EXCHANGE EARNINGS AND OUTGO:

The Foreign Exchange earned in terms of actual inflows and the Foreign Exchange Outgo in terms of actual outflows is NIL.

6. MATERIAL CHANGES AND COMMITMENTS AFFECTING THE FINANCIAL POSITION OF THE COMPANY WHICH HAVE OCCURED BETWEEN THE END OF THE FINANCIAL YEAR OF THE COMPANY TO WHICH THE FINANCIAL STATEMENTS RELATE AND THE DATE OF THE REPORT:

There has been no material changes and commitments affecting the financial position of the company which have occurred between the end of the financial year of the Company to which the financial statements relate and the date of the report.

7. REVISION OF THE FINANCIAL STATEMENT OF THE COMPANY/THE REPORT OF THE BOARD:

The Financial Statement of the Company/Board Report has not been revised during the Financial Year 2025-26 as per section 131 of Companies Act, 2013.

8. ANNUAL - RETURN EXTRACTS:

Pursuant to Section 92(3) of the Companies Act, 2013, the Annual Return of the Company for the financial year ended March 31, 2026, is available / shall be available on the Companys web link at: https://shreenathinvestment.in/index.php/annual-return-under-section-92-of-companies-act-2013/

9. DETAILS OF NEW SUBSIDIARY/ JOINT VENTURES / ASSOCIATE COMPANIES:

Sr.No. Name of the Company Subsidiary / Joint Ventures / Associate Company Date of becoming of Subsidiary / Joint Ventures / Associate Company
N.A. N.A. N.A. N.A.

10. DETAILS OF THE COMPANY WHICH CEASED TO BE ITS SUBSIDIARY/ JOINT

VENTURES/ ASSOCIATE COMPANIES:

Sr. No. Name of the Company Subsidiary / Joint Ventures / Associate Company Date of cessation of Subsidiary / Joint Ventures / Associate Companies
N.A. N.A. N.A. N.A.

11. THE DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE

REGULATIONS OR COURTS OR TRIBUNALS IMPACTING THE GOINGCONCERN

STATUS AND COMPANY S OPERATIONS IN FUTURE:

Sr.No. Name of the Authority who has issued an order. Date of Order. Particulars of order.
N.A. N.A. N.A. N.A.

12. DEPOSITS:

During the year, the Company has not accepted any deposits covered under section 73 to 76 under the Companies Act, 2013.

13. INTERNAL FINANCIAL CONTROL:

The Board of Directors is responsible for ensuring that internal financial controls have been laid down in the Company and that such controls are adequate and is functioning effectively. Shreenath Investment Company has policies, procedures, control frameworks and management systems in place that map into the definition of Internal Financial Controls. These have been established at the entity and process levels and are designed to ensure compliance internal control requirements, regulatory compliance and appropriate recording of financial and operational information. The company has adequate internal control system in place on the basis of which financial accounting is done and periodically financial statements are prepared. Such internal control systems are adequate operating effectively.

14. BOARD MEETINGS:

Seven meetings of the Board were held during the year under review. The necessary quorum was present for all the meetings. The maximum interval between any two Board meetings did not exceed 120 days. For details of meetings and composition of the Board and Committees of the Board, please refer to the Corporate Governance Report, which forms part of this Report. The details of which are given below:

Sr. No. Date of Meetings Directors Present Venue Leave of Absence
Mr. Jatin Jain Mr. Ashwin Jain 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021
01 27.05.2025 Mrs. Renu Jain NA
Mr. Ritesh Chopra
Mr. Bhavya Sundesha
Mr. Jatin Jain Mr. Ashwin Jain 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021
02 24.07.2025 Mrs. Renu Jain NA
Mr. Ritesh Chopra
Mr. Bhavya Sundesha
Mr. Jatin Jain Mr. Ashwin Jain 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021
03 21.08.2025 Mrs. Renu Jain NA
Mr. Ritesh Chopra
Mr. Bhavya Sundesha
Mr. Jatin Jain Mr. Ashwin Jain 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021
04 27.10.2025 Mrs. Renu Jain NA
Mr. Ritesh Chopra
Mr. Bhavya Sundesha
Mr. Jatin Jain Mr. Ashwin Jain 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021
05 12.11.2025 Mrs. Renu Jain NA
Mr. Ritesh Chopra
Mr. Bhavya Sundesha
Mr. Jatin Jain Mr. Ashwin Jain 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021
06 02.12.2025 Mrs. Renu Jain NA
Mr. Ritesh Chopra
Mr. Bhavya Sundesha
Mr. Jatin Jain Mr. Ashwin Jain 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021
Mrs. Renu Jain
07 12.02.2026 NA
Mr. Ritesh Chopra
Mr. Bhavya Sundesha

15. CHANGE IN DIRECTORS AND KEY MANAGERIAL PERSONNEL:

In accordance with Section 152(6) of the Companies Act, 2013 and Articles of Association of the Company, Mr. Ashwin Pukhraj Jain (DIN: 00173983), Director of the Company retires by rotation at the ensuing Annual General Meeting, being eligible offers himself for reappointment.

Apart from the above, there were no other changes in the Directors and Key Managerial Personnel of the Company during the financial year.

16. STATEMENT ON DECLARATION GIVEN BY THE INDEPENDENT DIRECTORS

UNDER SECTION 149 (6) OF THE COMPANIES ACT, 2013:

The Company has received the necessary declaration from each Independent Directors in accordance with Section 149(7) of the Companies Act, 2013, that he/she meets the criteria of independence as laid out in sub-section (6) of Section 149 of the Companies Act, 2013. In view of the above provisions, your Company has following Independent Directors:

Sr. No. Name of the Independent Director Date of appointment / Reappointment Date of passing of special resolution/Ordinary resolution (if any)
1. Renu Jain 31/08/2023 30/09/2023
2. Ritesh Chopra 31/08/2023 30/09/2023
3. Bhavya Dilip Sundesha 18/08/2022 22/09/2022

17.CHANGE IN THE NATURE OF BUSINESS

There is no change in the nature of Business by the Company during the period under review.

18.NOMINATION AND REMUNERATION COMMITTEE:

The Company has formulated a Nomination and Remuneration Policy in accordance with Section 178 of the Companies Act, 2013 and applicable provisions of the SEBI LODR Regulations, 2015, covering, inter alia, the criteria for appointment of Directors, qualifications, positive attributes, independence of Directors, Board diversity and remuneration of Directors, Key Managerial Personnel and other employees. The Policy is available on the Companys website at www.shreenathinvestment.in.

In accordance with the provisions of Section 178 of the Companies Act, 2013 read with Regulation 19 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Board of Directors of your Company has duly constituted the Nomination and Remuneration Committee ( NRC ).

The Committee comprises of three Directors, consisting of a majority of Independent Directors. The Chairman of the Committee is an Independent Director. The composition of the Committee is in compliance with the applicable provisions of the Companies Act, 2013 and SEBI (LODR) Regulations, 2015.

Further; the Company has devised a policy for performance evaluation of Independent Directors, Board, Committees and other individual Directors. The Company s Nomination and Remuneration Policy is directed towards rewarding performance based on review of achievements periodically. The Nomination and Remuneration Policy is in consonance with the existing industry practice.

COMPOSITION:

The Nomination and Remuneration Committee consists of three Directors with the Chairman being the Independent Director. The committee acts in accordance with the terms of reference as approved and adopted by the Board in its Nomination and Remuneration Policy.

The Composition of the Committee is as under:

Chairperson: Mr. Bhavya Sundesha- Independent Director Members: Ms. Renu Jain Independent Director Mr. Ritesh Chopra- Independent Director

MEETING AND ATTENDANCE

The Nomination and Remuneration Committee met once in a year ended on 27 th October 2025. The necessary Quorum was present for the meeting.

Sr. No. Date and time of Meetings Venue Committee Members Attendance/ Present Leave of Absence
1. 27-10-2025 801-802, Dalamal Tower, Nariman Point, Mumbai- 400021 Mr. Bhavya Sundesha Ms. Renu Jain Mr. Ritesh Chopra NA

19.AUDIT COMMITTEE:

The Audit Committee performs the roles and functions as mandated under the Act, the SEBI Listing Regulations and such other matters as prescribed by the Board from time to time. The Audit Committee comprises a majority of Independent Directors. All members of the Committee possess accounting or related financial management expertise.

The extract of terms of reference of the Audit Committee, attendance at its meetings and other details are provided in the Corporate Governance Report, which forms part of this Report. During the year under review, all the recommendations made by the Audit Committee were accepted by the Board. In accordance with the provisions of section 177 of the Companies Act, 2013 read with Regulation 18 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the Board of Directors of your Company has duly constituted the Audit Committee.

The Audit Committee comprises of three Directors, including a majority of Independent Directors. The Chairman of the Committee is an Independent Director. The composition of the Committee is in compliance with the requirements of the Companies Act, 2013 and SEBI (LODR) Regulations, 2015.

The Audit Committee acts in accordance with the terms of reference specified by the Board, which inter alia includes oversight of financial reporting process, recommendation of appointment and remuneration of auditors, review of financial statements and internal control systems, and such other matters as prescribed under the applicable laws.

The Composition of the Committee is as under:

Chairman: Mr. Bhavya Sundesha- Non- Executive Independent Directors Members: Mr. Ritesh Chopra-Non- Executive Independent Directors Mr. Jatin Jain - Executive Director

MEETING AND ATTENDANCE:

The Audit Committee met 4 times in a year for the year ended 31 st March 2026. The necessary quorum was present at the meeting.

2. 24-07-2025 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021 Mr. Bhavya Sundesha Mr. Ritesh Chopra Mr. Jatin Jain NA
3. 12-11-2025 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021 Mr. Bhavya Sundesha Mr. Ritesh Chopra Mr. Jatin Jain NA
4. 12-02-2026 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021 Mr. Bhavya Sundesha Mr. Ritesh Chopra Mr. Jatin Jain NA

The Terms of Reference of the Audit Committee are broadly stated as under:

(a) Recommendation for appointment, remuneration and terms of appointment of auditors of Company; (b) Overview of the company s financial reporting process and the disclosure of its financial information to ensure that the financial statement is correct, sufficient and credible; (c) Review and control of internal financial controls and risk management systems; (d) Review of financial statements before submission to Board; (e) Supervision of other financial and accounting matters as may referred to by the Board; (f) Discussion with statutory auditors before audit commences, about the nature and scope of audit as well as post-audit discussion to assert any area of concern; (g) Scrutiny of inter-corporate loans and investments; (h) Monitoring the end use of funds raised through public offers and related matters; (i) Valuation of undertakings or assets of the company, wherever it is necessary; (j) Approval of appointment of chief financial officer after assessing the qualifications, experience and background etc., of the candidate;

20.STAKEHOLDER RELATIONSHIP COMMITTEE:

In accordance with the provisions of Section 178 of the Companies Act, 2013 read with Regulation 20 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations,

2015, the Board of Directors of your Company has duly constituted the Stakeholders

Relationship Committee.

The Committee comprises of three Directors and is chaired by a Non-Executive Director. The composition of the Committee is in compliance with the applicable provisions of the Companies Act, 2013 and SEBI (LODR) Regulations, 2015.

The Stakeholders Relationship Committee acts in accordance with the terms of reference specified by the Board, which inter alia includes consideration and resolution of grievances of security holders of the Company relating to transfer/transmission of shares, non-receipt of annual reports, dividends and other investor-related matters, and ensuring effective exercise of shareholders rights and redressal of investor complaints. The Committee has the mandate to review, redress shareholders grievances and to approve all the share transfers.

The Composition of the Committee is as under:

Chairman: Mr. Bhavya Sundesha- Non- Executive Independent Directors

Members: Mr. Ashwin Jain-Executive Directors Mr. Jatin Jain- Executive Director

The Meeting of Stakeholders Relationship Committee met once in a year for the year ended 31 st March 2026.

Sr. No. Date and time of Meetings Venue Committee Members Attendance/ Present Leave of Absence
1. 16-12-2025 801-802, Dalamal Tower, Nariman Point, Mumbai 400 021 Mr. Bhavya Sundesha Mr. Ashwin Jain Mr. Jatin Jain NA

21.CORPORATE SOCIAL RESPONSIBILITY COMMITTEE:

The Company s CSR initiatives and activities are aligned to the requirements of Section 135 of the Act. The Annual Report on CSR activities for the year under review is set out in Annexure I of this Report in the format prescribed in the Companies (Corporate Social Responsibility

Policy) Rules, 2014. The CSR Policy is available on the Company s website at www.shreenathinvestment.in For other details regarding the CSR Committee, please refer to the Corporate Governance Report, which forms part of this Report.

In accordance with the provisions of Section 135 of the Companies Act, 2013, the Board of Directors of your Company has duly constituted the Corporate Social Responsibility (CSR) Committee.

The Committee comprises of three Directors and is responsible for formulating and recommending the CSR Policy of the Company, recommending the amount of expenditure to be incurred on CSR activities, and monitoring the implementation of CSR projects/programmes in accordance with the applicable provisions of the Companies Act, 2013 and rules made thereunder.

The Meeting of CSR Committee was held on dated 27th May, 2025 and 07th November, 2025.

The composition of the CSR committee:

1. Mr. Bhavya Sundesha- Chairperson- Non-Executive Independent Director

2. Mr. Jatin Jain- Member-Executive Director

3. Ms. Renu Jain- Member-Non-Executive Independent Director

According to Rule 3(2) of The Companies (Corporate Social Responsibility Policy) Rules, 2014:

Every company which ceases to be a company covered under subsection (1) of section 135 of the Act for three consecutive financial years shall not be required to-

(a) Constitute a CSR Committee; and

(b) comply with the provisions contained in sub-section (2) to (5) of the said section, till such time it meets the criteria specified in sub-section (1) of section 135.

(c) Thus, keeping in view, the above provisions and non-fulfilment of criteria under section 135 of the Act for three consecutive financial years, the Company was not required to spend any amount for CSR in the financial year 2025-26.

The Annual Report on CSR Activity is annexed as Annexure- I.

22. VIGIL MECHANISM:

The Company has a Whistle Blower Policy and has established the necessary vigil mechanism for Employees, Directors and Stakeholders in conformation with the provisions of Section 177(9) of the Act and Regulation 22 of SEBI Listing Regulations, to report genuine concerns about unethical behaviour and to ensure strict compliance with ethical and legal standards across the Company. This Policy is available on the Company s website and can be accessed by clicking here

23. QUALIFICATION GIVEN BY THE AUDITORS:

There are no qualifications, reservation or adverse remarks or disclaimers made by the Statutory Auditors of the Company in their Report.

24. SECRETARIAL AUDITOR:

During the year under review, the Members of the Company approved the appointment of M/s. Pramod S. Shah & Associates, Practising Company Secretaries, as the Secretarial Auditors of the Company for a term of five consecutive financial years commencing from FY 2025-26 to FY 2029-30, pursuant to Section 204 and other applicable provisions of the Companies Act, 2013.

Accordingly, M/s. Pramod S. Shah & Associates (C.P.No.3804) continue to act as the Secretarial Auditors of the Company for the financial year under review.

During the year under review, the reports of Statutory Auditors and Secretarial Auditors of the Company does not contained any qualification, Observations, disclaimer, reservation or adverse remark. Secretarial Audit report, i.e., Form No. MR-3 is attached to this Report as

Annexure II.

25. COST AUDIT:

The maintenance of cost records as specified by the Central Government under sub-section (1) of section 148 of the Companies Act, 2013, is not applicable to the Company.

26. LOANS, GUARANTEES OR INVESTMENTS BY THE COMPANY:

Particulars of loans given, investments made or guarantees or securities provided pursuant to Section 186 of the Act are given under Notes to Accounts annexed to the Standalone Financial Statements for the financial year ended March 31, 2026 and the same forms part of the Annual Report.

27. CONTRACT OR ARRANGEMENT WITH RELATED PARTIES:

The company has entered into transactions with the related party and the particulars of contracts and arrangements with related parties referred to in Section 188(1), as prescribed in Form AOC 2 of the rules prescribed under Chapter IX relating to Accounts of Companies under the Companies act, 2013, is appended as Annexure III.

28. PERFORMANCE EVALUATION:

The company has in its place a policy on performance evaluation of independent directors, board, committees and individual directors. The Board of Directors evaluates its own performance in terms of operations of the company, financial results etc. The performance of committee(s) is evaluated by the board based on the effectiveness of individual director(s) based on the contribution of individual director to be the board/ committee meetings, participation in discussions, inputs given in the meeting.

As required under the section 178(2) of the Companies Act, 2013 and under Schedule IV to the Companies Act, 2013 on Code of Conduct for Independent Directors, a comprehensive exercise for the evaluation of the performances of every individual director, of the Board as a whole and its Committees and the Chairperson of the Company has been carried by your company during the year under the review as per the evaluation criteria approved by the Board and based on the Guidelines given in Schedule IV to the Companies Act, 2013.

For the purpose of carrying out performance evaluation exercise, four types of Evaluation forms were devised in which the evaluating authority has allotted to the individual directors, the Board as a whole, its Committees and the Chairperson appropriate grading from1 to 5 and in which rating 1 would be considered a highest rating depending upon the performance.

Such evaluation exercise has been carried out:

(i) of Independent Directors by the Board;

(ii) of Non-Independent Directors by all Independent Directors in separate meeting held for the purpose on 06th March, 2026.

(iii)of the Board as a whole and its committees by all the Independent Directors in separate meeting held for the purpose on 06th March, 2026.

(iv) of the Chairperson of the Company by the independent Directors in separate meeting held on 06th March, 2026 after taking into account the views of the Executive/ Non-Executive Directors;

(v) of individual directors by Nomination and Remuneration Committee;

(vi) of the Board itself;

Having regard to the industry, size and nature of business your company is engaged in, the evaluation methodology adopted is, in the opinion of the Board, sufficient, appropriate and is found to be serving the purpose.

29. AUDITORS:

Pursuant to Section 139(8) of the Companies Act, 2013, a casual vacancy arose in the office of the Statutory Auditors of the Company due to the resignation of M/s. Kamdar Dalal & Associates, Chartered Accountants, having Firm Registration No. 129596W.

Accordingly, based on the recommendation of the Audit Committee, the Board of Directors appointed M/s. Mahesh Patira & Associates, Chartered Accountants, having Firm Registration No. 136900W, as the Statutory Auditors of the Company to fill the said casual vacancy, subject to the approval of the Members of the Company.

The Members of the Company, at the Extraordinary General Meeting held on 29 th December, 2025, approved the appointment of M/s. Mahesh Patira & Associates, Chartered Accountants, having Firm Registration No. 136900W, as the Statutory Auditors of the Company to fill the casual vacancy caused by the resignation of M/s. Kamdar Dalal & Associates, Chartered Accountants, and to hold office until the conclusion of the ensuing Annual General Meeting.

The Board recommends the appointment of M/s. Mahesh Patira & Associates, Chartered Accountants, having Firm Registration No. 136900W, as the Statutory Auditors of the Company for the ensuing term, subject to the approval of the Members at the ensuing Annual General Meeting, as applicable.

30. INTERNAL AUDITOR:

The Board, based on the recommendation of Audit Committee, had appointed M/s. ZADN & Associates, Chartered Accountants, as the Internal Auditors of the Company for the financial year 2025-26 in accordance with the provisions of the Act.

31. DISCLOSURE AS PER RULE 5 OF THE COMPANIES (APPOINTMENT AND

REMUNERATION OF MANAGERIAL PERSONNEL) RULES, 2014:

Disclosures with respect to the remuneration of Directors, KMP and employees as required under Section 197(12) of the Companies Act,2013, read with rule (5)(1) of Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 are given in

Annexure-IV.

32. LISTING ON STOCK EXCHANGES:

Your company s equity shares are listed on Bombay Stock Exchange Limited, Mumbai (BSE LTD). The company has paid the listing fees to the stock exchanges for the financial year 2025-26.

33. MANAGEMENT DISCUSSION ANALYSIS REPORT:

The Management Discussion and Analysis report are provided under Annexure -V.

34. CORPORATE GOVERNANCE REPORT:

Your Company aims and constantly strives in maintaining the highest standards of Corporate Governance practices. Your Company complies with all the mandatory requirements as stipulated under the Regulation 34 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. Report on Corporate Governance along with the Certificate from Auditor on compliance of conditions of Corporate Governance and the Certificate from Practicing Company Secretary on Non-disqualification of Directors, forms part of this report and is attached as Annexure VI. A declaration signed by the Chairman and Managing Director in regard to compliance with the Code of Conduct by the Board members and Senior Management Personnel also forms part of this Report.

35. RISK MANAGEMENT:

Your directors have enlarged mandate of Audit Committee to include responsibility to assist the Board in a) Overseeing and approving the Company s enterprise-wide risk management framework; and b) Periodic appraisal to access any change needed in the context of changing business environment.

36. DIRECTOR S RESPONSIBILITY STATEMENT:

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

(a) In the preparation of the annual accounts, the applicable accounting standards had been followed along with proper explanation relating to material departures;

(b) The directors had selected such accounting policies and applied them consistently and made judgements 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 profit of the company for the period;

(c) The directors 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;

(d) The directors had prepared the annual accounts on a going concern basis;

(e) The directors had laid down internal financial controls to be followed by the company and such internal financial controls are adequate and operating effectively;

(f) The directors had devised proper systems to ensure compliance with the provisions of all applicable laws and with laid down internal financial controls to be followed by the company and those systems were adequate and operating effectively.

37. DETAILS IN RESPECT OF FRAUDS REPORTED BY THE AUDITORS UNDER

SECTION 143 (12) OF COMPANIES ACT, 2013:

There are no frauds reported by the Auditor which are required to be disclosed under Section 143 (12) of Companies Act, 2013.

38. POLICY FOR PREVENTION, PROHIBITION AND REDRESSAL OF SEXUAL

HARASSMENT OF WOMEN AT WORKPLACE.

Your Company has always believed in providing a safe and harassment free workplace for every individual through various interventions and practices. The Company always endeavors to create and provide an environment that is free from discrimination and harassment including sexual harassment. During the year ended March 31, 2026, no complaints have been received pertaining to sexual harassment.

The following is a summary of complaints received and resolved during the reporting period:

Sr. No Nature of Complaints Received Disposed-Off Pending
1 Sexual Harassment 0 0
2 Workplace Discrimination 0 0
3 Child Labour 0 0
4 Forced Labour 0 0
5 Wages and Salary 0 0
6 Other HR Issues 0 0

39. MATERNITY BENEFIT PROVIDED BY THE COMPANY UNDER MATERNITY BENEFIT ACT 1961:

The Company confirms that it is fully aware of and remains committed to complying with the provisions of the Maternity Benefit Act, 1961. the Company has appropriate systems and policies in place to ensure that all statutory benefits under the Act, including paid maternity leave, continuity of salary and service during the leave period, nursing breaks, and flexible return-to-work arrangements will be extended to eligible women employees as and when applicable. The Company remains committed to fostering an inclusive and legally compliant work environment.

40. STATEMENT REGARDING OPINION OF THE BOARD WITH REGARD TO INTEGRITY, EXPERTISE AND EXPERIENCE (INCLUDING THE PROFICIENCY) OF THE INDEPENDENT DIRECTORS APPOINTED DURING THE YEAR:

The Board on the opinion that all the independent directors possess integrity, expertise and experience as required in the Companies Act, 2013 and also has required skill set for efficient functioning of the company.

41. DETAILS OF INSOLVENCY AND BANKRUPTCY CODE:

No proceedings are initiated/pending against the Company under the Insolvency and Bankruptcy Code, 2016

42. DETAILS REGARDING VALUATION REPORT:

During the year under review, your Company has not entered into any One-Time Settlement with Bank s or Financial Institutions and therefore, no details of Valuation in this regard is available.

43. SECRETARIAL STANDARDS:

The Company has devised proper systems to ensure compliance with the provisions of all applicable Secretarial Standards issued by the Institute of Company Secretaries of India and that such systems are adequate and operating effectively.

44. ACKNOWLEDGEMENT:

Your directors place on record their sincere gratitude for the assistance, guidance and cooperation of the Company has received from all stakeholders. The Board placed further on record its appreciation for the dedicated services rendered by the employees of the Company.

For and on Behalf of the Board
Shreenath Investment Company Limited
Sd/-
Jatin Jain- Ashwin Jain-
Managing Director Director
DIN: 08521872 DIN: 00173983
Date: 26-08-2026
Place: Mumbai

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