As on: Sep 22, 2023 12:51 PM
To,
The Members of
Ascom Leasing & Investment Limited
The Board of Directors of your company are pleased to present the Thirty-Fifth (35 th) Annual Report on the business and operations of the Company, italicizing the progress and growth achieved during the year along with Audited Financial Statements with Auditors' Report thereon, Secretarial Auditor's Report for the Financial Year ended 31st March, 2022.
The Financial highlights are as follows:
1. FINANCIAL RESULTS:
The financial performance of the Company for the financial year ended on 31st March, 2022 is as follows:
The Company has prepared the financial statements in accordance with the generally accepted accounting principles in India ('Indian GAAP') to comply in all material respects with the notified Accounting Standards ('AS') under section 133 of the Companies Act, 2013 ('the Act'), read with rule 7 of the Companies (Accounts) Rules, 2014 and the Companies (Accounting Standards) Amendment Rules, 2016. Further, the company follows the statutory requirements, circulars and guidelines issued by the Reserve Bank of India (RBI) for Non-Banking Financial Companies (NBFC), from time to time to the extent they have an impact on the financial statements and current practices prevailing in India.
2. RESULTS OF OPERATIONS & STATE OF COMPANY'S AFFAIRS
The management of the Company is putting their best efforts to improve the performance of the Company. During the year, the Company has generated the total Revenue of Rs. 1244.63 Lakhs in comparison to Rs. 1069.60 Lakhs in the previous year. The total expenses for the period under review was Rs.597.93 Lakhs and Company has earned the Net profit (after tax) of Rs. 487.30 Lakhs
The Company's Capital Adequacy Ratio calculated in line with the Reserve Bank of India ('RBI') directions for Non-Banking Financial Companies ('NBFCs') which is well above the minimum regulatory requirement.
3. CHANGE IN THE NATURE OF BUSINESS
There were no changes in the nature of Business of the Company during the financial year.
4. SHARE CAPITAL AND DEBT STRUCTURE
During the Financial Year 2021-22, there were no changes in the Capital Structure of the Company. The Authorized Share Capital of the Company is Rs. 15,00,00,000 divided into 1,50,00,000 Equity Shares of Rs. 10/- each. The Subscribed, Issued and Paid-up Capital of the Company is Rs. 7,80,94,530 divided into 78,09,453 Equity Shares of Rs.10/- each.
a) Bonus Issue
As per Section 63 of Companies Act, 2013 and rule 14 of Companies (Share Capital and Debenture) Rules, 2014, during the period under review, your Company has not issue bonus shares.
b) Issue of equity shares with differential rights
As per Section 43(2) of Companies Act, 2013 and rule 4 (4) of Companies (Share Capital and Debentures) Rules, 2014, during the period under review, your Company has not issued equity shares with differential rights.
c) Issue of sweat equity shares
As per Section 54 of Companies Act, 2013 and rule 8 (13) of Companies (Share Capital and Debentures) Rules, 2014, during the period under review, your Company has not issued Sweat equity shares.
d) Issue of employee stock options
As per Section 62(1)(b) of Companies Act, 2013 and rule 8 (13) of Companies (Share Capital and Debentures) Rules, 2014, during the period under review, your Company has not issued Sweat equity shares.
e) Provision of money by Company for purchase of its own shares by employees or by trustees for the benefit of employees
As per Section 68 of Companies Act, 2013 and rule 16 (4) of Companies (Share Capital and Debentures) Rules, 2014 there are no voting rights exercised directly or indirectly by the employees in respect of shares held by them.
5. DIVIDEND
The Board of Directors has not recommended any dividend for the financial year ended on 31st March, 2022. Since the Board have considered it financially prudent in the long-term interest of the Company to re-invest the profits into the business of the Company to build a strong reserve base and grow the business of the Company.
6. TRANSFER TO RESERVES
During the year, the Company has transferred Rs. 97.46 Lakhs (20% of the profits are required to be transferred to a Statutory/Special Reserve Account.) to the statutory Reserve as per Section 45IC of the Reserve Bank of India Act, 1934,
7. TRANSFER OF UNCLAIMED DIVIDEND TO INVESTOR EDUCATION AND PROTECTION FUND
The provisions of Section 125(2) of the Companies Act, 2013 do not apply as there was no dividend declared and paid last year.
8. MATERIAL CHANGES AND COMMITMENTS AFFECTING FINANCIAL POSITION BETWEEN THE END OF THE FINANCIAL YEAR AND DATE OF REPORT
There have been no material changes and commitments were recorded during the financial year which materially affects the financial position of the Company till the date of this report.
9. DEPOSIT
The Company being non-deposit taking NBFC, has not accepted any deposits from the public during the year under review.
10. PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS MADE U/S 186 OF THE COMPANIES ACT, 2013
The company has complied with the provisions of sections 186 of the Companies Act, 2013, in respect of grant of loans. However, the Company has not made any investments or granted any guarantees or securities during the year, the particulars of loans, guarantees and investments have been disclosed in the financial statements which also form part of this report.
11. SUBSIDIARIES. IOINT VENTURES AND ASSOCIATE COMPANIES
The Company does not have any Subsidiary, Joint Venture or Associate Company; hence provisions of Section 129(3) of the Companies Act, 2013 relating to preparation of consolidated financial statements are not applicable.
12. CORPORATE SOCIAL RESPONSIBILITY
The Company's vision on CSR is that the Company being a responsible Corporate Citizen would continue to make a serious endeavor for a quality value addition and constructive contribution in building a healthy and better society through its CSR related initiatives and focus on education, environment, health care and other social causes.
As per the provisions of Section 135 of the Companies Act, 2013 read with rules framed thereunder, certain class of companies is required to spend 2% of its average net profit during 3 preceding years on CSR activities. It also provides for formation of CSR committee of the Board. The rules prescribe the activities qualify under CSR and the manner of spending the amount.
The disclosures related to CSR activities pursuant to Section 134(3) of the Companies Act, 2013 read with Rule 9 of Companies (Accounts) Rules, 2014 and Companies (Corporate Social Responsibility) Rules, 2014 is annexed hereto and form part of this report as "Annexure I"
13. CONSERVATION OF ENERGY, RESEARCH AND DEVELOPMENT, TECHNOLOGY ABSORPTION- FOREIGN EXCHANGE EARNINGS AND OUTGO
The particulars as prescribed under Section 134(3) of the Companies Act, 2013 read with Rule 8(3) of Companies (Accounts) Rules, 2014 are annexed herewith at "Annexure No. II"
14. INTERNAL FINANCIAL CONTROL SYSTEM
The Company has a well-placed, proper and adequate Internal Financial Control System which ensures that all the assets are safeguarded and protected and the transactions are authorized, recorded and reported correctly. During the year, such controls were tested and no reportable material weakness in the design or operation was observed. A report on the Internal Financial Controls under clause (i) of sub-section 3 of section 143 of the Companies Act, 2013 as given by the Statutory Auditors of the Company forms part of Independent Auditor's Report on Financial Statements.
To further strengthen the internal control process, the Company has developed the very comprehensive compliance management tool to drill down the responsibility of the compliance from top management to executive.
15. PARTICULARS OF EMPLOYEES U/S 197(12) OF THE COMPANIES ACT. 2013
The information required under Section 197 & Rule 5 of the Companies (Appointment and Remuneration of Managerial Personnel) Rules 2014 is given below-
a) The ratio of the remuneration of each director to the median remuneration of the employees of the company for the financial year- NA
b) Percentage increase in the median remuneration of employees in the financial year2021-22: NIL
c) Number of permanent employees on the rolls of the Company as on March 31, 2022: 25 (Twenty Five).
d) Average percentile increase made in the salaries of employees other than key managerial personnel in the last financial year and its comparison with the percentile increase in the managerial remuneration and justification thereof and point out if there are any exceptional circumstances for increase in the managerial remuneration: NIL
e) There is no employee covered under the provisions of section 197(14) of the Companies Act 2013.
There was no employee in the Company who drew remuneration of Rs. 1,02,00,000/- per annum during the period under review. Hence the Company is not required to disclose any information as per Rule 5(2) of the Companies (Appointment and Remuneration) Rules 2014.
16. MANAGEMENT DETAILS/ INFORMATION
> Directors &Key Managerial Personnel of the Company
There were no changes in the Composition of Board of Directors of the Company. Following are the Details of Directors and Key Managerial Personnel of the Company.
Mr. Hemant Kumar, Company Secretary and Compliance Officer of the Company was resigned from the said post with effect from 4th March, 2022 due to his personal reasons and in place of him, Company has appointed Mrs. Shweta Aggarwal as Company Secretary and Compliance Officer of the Company w.e.f. 4th March, 2022.
> Directors seeking appointment and re-appointment
In accordance with the provisions of Sections 152 and other applicable provisions of the Companies Act, 2013 one-third of such of the Directors as are liable to retire by rotation shall retire every year and if eligible offer himself for re-appointment at every Annual General Meeting. Consecutively, Mr. Rohitkumar Balvantrai Pandya, Whole Time Director will retire by rotation at the conclusion of Annual General Meeting.
The Board recommended his reappointment for the consideration of the members of the Company at the ensuing Annual General Meeting.
> Independent Directors and Declaration by Independent Director(s)
In accordance with the provisions of Section 149 of the Companies Act, 2013 ("the Act"), the independent directors have submitted declarations that each of them meet the criteria of independence as provided in Section 149(6) of the Act along with Rules framed thereunder and Regulation 16(1)(b) of the SEBI Listing Regulations. The Independent Directors of the Company fulfill the conditions specified in the Act and the Rules made there under for the appointment as Independent Directors.
> Board Evaluation
The Board, the Committees of the Board and independent directors continuously strive for efficient functioning of Board and its committees and better corporate governance practices. The performance of the Board of Directors and its Committees were evaluated on various parameters such as structure, composition, experience, performance of specific duties and obligations, quality of decision making and overall effectiveness. The performance of individual Directors was evaluated on parameters, such as meeting attendance, participation and contribution and independent judgment.
A separate meeting of Independent Directors was called up for the evaluation of the performance of non-independent Directors, the Board as a whole and performance of the Chairman was evaluated. The Board takes note of all the observations and feedbacks during the evaluation process.
17. MEETINGS OF THE BOARD
The Company prepares the schedule of the Board Meeting in advance to assist the Directors in scheduling their program. The agenda of the meeting is circulated to the members of the Board well in advance along with necessary papers, reports, recommendations and supporting documents so that each Board member can actively participate on agenda items during the meeting.
The Board met Six (06) times during the Financial Year 2021-2022. The Board Meetings were held of the Company as follow: •
• 19.04.2021
• 15-05-2021
• 29.06.2021
• 01.09.2021
• 11.11.2021
• 04.03.2022
The maximum interval between any two meetings did not exceed 120 days. Following are details of meetings attended by each Directors of Company:
The 34rd Annual General Meeting of the Company was held on 25th September, 2021.
18. POLICY ON DIRECTORS' APPOINTMENT AND REMUNERATION INCLUDING CRITERIA FOR DETERMINING QUALIFICATIONS. POSITIVE ATTRIBUTES. INDEPENDENCE AND OTHER MATTERS PROVIDED UNDER SECTION 178 (3)
The Company has in place a Nomination & Remuneration Committee in accordance with the requirements of the Companies Act, 2013.
The Committee has formulated a policy on Director's appointment and remuneration including recommendation of remuneration of the key managerial personnel and other employees, composition and the criteria for determining qualifications, positive attributes and independence of a Director and the policy is available on the website of the Company i.e., www.ascomfinance.com
19. CONSTITUTION OF VARIOUS COMMITTEES& ITS MEETING
The Board committees play a crucial role in the governance structure of the Company and have been constituted to deal with specific areas/ activities which concern the Company and need a closer review. The Board committees are set up under the formal approval of the Board, to carry out clearly defined roles which are considered to be performed by the members of the Board, as a part of good governance practice. All decisions and recommendations of the committees are placed before the Board for information or for approval. The minutes of the meetings of all the committees are placed before the Board for their review.
The Board of Ascom Leasing & Investment Limited currently has 4 (Four) Committees:
1. Audit Committee(AC)
2. Nomination and Remuneration Committee(NRC)
3. Stakeholder's Relationship Committee(SRC)
4. Corporate Social Responsibility Committee(CSR).
The major terms of reference of the Committees, its composition and number of meetings held during the year ended March 31, 2022 are as follows:
> AUDIT COMMITTEE
The Board of Directors of the Company has constituted Audit Committee under Section 177 of the Companies Act, 2013. The Composition of the Audit Committee as on the date of the Report is as follows:
Meetings of the Audit Committee
During the year the Audit Committee met 3 (Three) times. The date of the meetings held during the year ended March 31, 2022 are:
Following are details of meetings attended by each Directors/ Member of Audit Committee:
In case any person requires more information/ details regarding the Audit Committee the person may access the Company's website at the link: www.ascomfinance.com
> NOMINATION AND REMUNERATION COMMITTEE
Pursuant to Section 178(3)of the Companies Act, 2013, The major terms of reference of the Nomination and Remuneration Committee are as follows:.
• Identification of persons qualified to become directors and be appointed in senior management in accordance with the criteria laid down, recommend to the Board their appointment and removal;
• Formulation of the criteria for determining qualifications, positive attributes and independence of a director;
• Specifying the manner for effective evaluation of performance of Board, its committees and individual directors; Recommending to the Board a policy, relating to the remuneration for the directors, key managerial personnel and other employees.
Nomination & Remuneration Policy is uploaded on the website of the Company i.e. at www.ascomfinance.com.
Composition of Nomination & Remuneration Committee as on the date of the report:
Meetings of the Nomination & Remuneration Committee
During the year the Nomination and Remuneration Committee met 2 (Two) times. The date of the meetings held during the year ended March 31, 2022 are:
Following are details of meetings attended by each Directors/ Member of Nomination & Remuneration:
Nomination & Remuneration Policy is placed at the website of the Company i.ewww.ascomfinance.com.
> STAKEHOLDERS RELATIONSHIP COMMITTEE MEETING
The Board of Directors of the Company has constituted Stakeholders Relationship Committee under Section 178 of the Companies Act, 2013.
The major terms of reference of the Stakeholders Relationship Committee include:
• Consideration & Resolution of the grievances of security holders of the Company;
• Reviewing of Transfer / Transmission requests / Demat / Remat requests of the security shareholders and issuance of duplicate share certificate, if any
Composition of the Stakeholders Relationship Committee as on the date of the report:
Meetings of the Stakeholders Relationship Committee
During the year the Stakeholders Relationship Committee met 4 (Four) times. The date of the meetings held during the year ended March 31, 2022 are:
• 07.04.2021
• 09.07.2021
• 16.10.2021 • 10.01.2022
Following are details of meetings attended by each Directors/ Member of Stakeholders Relationship Committee:
> CORPORATE SOCIAL RESPONSIBILITY COMMITTEE
The Board of Directors of the Company has constituted Corporate Social Responsibility Committee under Section 135 of the Companies Act, 2013.
Meetings of the Corporate Social Responsibility Committee: Please refer Annexure I attached with the Board Report"
> INDEPENDENT DIRECTORS MEETING
The Independent Directors played active role in Board as well as committee meetings in which they are members. Keeping in view the provisions the meeting of Independent Directors held on 31st March, 2022, without the presence of Non-Independent Directors and members of the Management. They reviewed the performance of Non-Independent Directors and the Board as a whole, the performance of the Chairman of the Company, taking into account the views of Executive Director and Non- Executive Directors and assessed the quality, quantity and timeliness of flow of information between the Company Management and the Board that is necessary for the Board to effectively and reasonably perform its duties.
The Independent Directors expressed satisfaction over theperformance and effectiveness of the Board, individual Non- Independent Directors and the Chairman.
As per the provisions of the Companies Act, 2013 read with Schedule IV, following are the Independent Directors of the Company.
20. COMPLIANCE OF SECRETARIAL STANDARDS
The Company has complied with the applicable clauses of Secretarial Standards i.e. SS-1 and SS-2 on Meetings of the Board of Directors and General Meetings, respectively issued by the Institute of Company Secretaries of India.
21. LISTING
Currently the Equity Shares of the Company are listed on SME platform of National stock exchange (NSE) and there are no arrears on account of payment of Listing Fees to the Stock Exchange.
22. PARTICULARS OF CONTRACTS OR ARRANGEMENTS MADE WITH RELATED PARTIES
During the year, there were no contracts or arrangements with related parties covered under Section 188 of Companies Act, 2013. Moreover, the Company had not entered into any contract/arrangement/transaction with related parties which could be considered material in accordance with the provisions of Regulation 23 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. Accordingly, the disclosure of Related Party Transactions as required under Section 134(3)(h) of the Companies Act, 2013 in Form AOC-2 is attached as Annexure-III applicable.
The Policy on dealing with related party transactions ,as approved by the Board may be accessed on the Company's website at the link www.ascomfinance.com.
23. VIGIL MECHANISM / WHISTLE BLOWER POLICY
As per the provisions of Section 177(9) of the Companies Act, 2013, the Company has established a "Vigil Mechanism" incorporating whistle blower policy in terms of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 for employees and Directors of the Company, for expressing the genuine concerns of unethical behavior, actual or suspected fraud or violation of the codes of conduct by way of direct access to the Chairman/ Chairman of the Audit Committee.
As per the provisions of Companies Act, 2013, every Listed Company shall establish a vigil mechanism (similar to Whistle Blower mechanism). In pursuance of the provisions of Section 177(9) & (10) of the Companies Act, 2013, a vigil mechanism/ whistle blower policy for Directors and employees to report genuine concerns has been established and approved by Board.
The Company believes in the conduct of the affairs of its constituents in a fair and transparent manner by adopting highest standards of professionalism, integrity and ethical behaviour.
The Vigil Mechanism - cum - Whistle Blower Policy may be accessed on the Company's website at the link: www.ascomfinance.com.
The following is a summary of Protected Disclosures received and disposed off during the year 202122:
No. of Protected Disclosures received : NIL
No of Protected Disclosures disposed off : NIL
The Audit Committee oversee the Vigil Mechanism of the Company. The employees of the Company have the right to report their concern/grievance to the Audit Committee constituted by the Board of Directors to oversee the Vigil mechanism.
The Company is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations.
24. DETAILS OF SIGNIFICANT AND MATERIAL ORDERS BY THE REGULATORS OR COURTS ORTRIBUNALS IMPACTING THE GOING CONCERN STATUS AND COMPANY'S OPERATIONS IN FUTURE.
There was no significant order was passed by any regulatory authority or court or tribunal.
25. DIRECTORS' RESPONSIBILITY STATEMENT AS REQUIRED U/S 134f3)fc):
Pursuant to section 134(5) of the Companies Act, 2013, the board of Directors, to the best of their knowledge and ability, confirm that: -
a. in the preparation of the annual accounts, the applicable accounting standards have been followed;
b. the Directors have 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;
c. the Directors have taken proper and sufficient care 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 Directors have prepared the annual accounts on a going concern basis.
e. the Directors have laid down internal financial controls to be followed by the Company and that such internal financial controls are adequate and were operating effectively
f. the Directors have devised proper system to ensure compliance with the provisions of all applicable laws and that such systems were adequate and operating effectively.
26. AUDITORS & AUDITORS REPORT:
> STATUTORY AUDITOR
Pursuant to the provisions of Section 139 (2) of the Act and the rules made thereunder, the Members at their Thirty-Two AGM held on September 20, 2019, had appointed M/s Karma& Co. LLP Chartered Accountants (Erstwhile Known as DilipParesh& Co. LLP) (ICAI Firm's Registration Number 127544W) Statutory Auditors of the Company for a term of five years i.e. from the conclusion Thirty T wo of AGM till the conclusion of the Thirty Seven AGM.
The notes on accounts referred to in the auditors' report are self-explanatory and therefore don't call for any further comments by the Board of Directors.
EXPLANATIONS OR COMMENTS OF THE BOARD ON QUALIFICATIONS). RESERVATIONS) OR ADVERSE REMARKfS) OR DISCLAIMER MADE BY STATUTORY AUDITOR
The Statutory Auditor in its Report: The notes on accounts referred to in the auditors' report are self-explanatory and therefore don't call for any further comments by the Board of Directors. During the year under review, the Company has not reported any fraud mentioned under Section 143(12) of the Act.
> SECRETARIAL AUDITOR
In terms of Section 204 of the Act and Rules made there under, M/s KMPM & Co., Practicing Company Secretaries was appointed as Secretarial Auditors for the financial year 2021-22 and have submitted their Secretarial Audit Report in Form No. MR-3 as required under Section 204 of the Companies Act, 2013 for the financial year ended 31st March, 2021. The Report forms part of this report as Annexure IV.
EXPLANATIONS OR COMMENTS OF THE BOARD ON QUALIFICATIONS). RESERVATIONS) OR ADVERSE REMARK(S) OR DISCLAIMER MADE BY SECRETARIAL AUDITOR.
The Company Secretary in practice in his Report; There are no qualifications or adverse remarks in the Secretarial Auditors' Report except existing Independent - Non Executive Directors of the Company have not yet appeared for the Online Proficiency Self-Assessment Test pursuant to the Section 150(1) of the Companies Act, 2013 read with Rule 6(1) of the Companies (Appointment and Qualification of Directors) Rules, 2014.
Board of Directors is assuring that the aforesaid compliance will be complied with on or before 30th September, 2022.
> INTERNAL AUDITOR
In terms of Section 138 of the Companies Act, 2013 read with Companies (Accounts) Rules, 2014, M/s Dharan Shah &Associates, Chartered Accountants were appointed as Internal Auditors for the financial year 2021-22.
> COST AUDITORS
Pursuant to section 148 (3) of the Companies Act, 2013 and rule 6(2) of the Companies (Cost records and Audit Rules) 2014 is not applicable on the Company.
27. INSTANCES OF FRAUD. IF ANY REPORTED BY THE AUDITORS:
Pursuant to provisions of Section 143(12) and sub section (14) of the Companies Act, 2013, as amended from time to time, the Auditors have not reported any incident of fraud to the Company during the year under review.
28. MANAGEMENT DISCUSSION AND ANALYSIS REPORT
As per SEBI Listing Regulations, Management Discussion and Analysis are attached, which form part of this report annexed herewith at Annexure No. V.
29. CORPORATE GOVERNANCE
Pursuant to Regulation 15(2)(a) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the compliance with the corporate governance provisions shall not apply to the listed entity which has listed its specified securities on the SME Exchange.
As the Equity Shares of the Company are listed on SME Platform of NSE Limited, provisions regarding Corporate Governance not applicable to your Company.
Your company have complied with applicable Secretarial Standards issued by the Institute of Company Secretaries of India (ICSI) and approved by Central Government from time to time.
30. RISK MANAGEMENT AND RISK MANAGEMENT POLICY
The Board has adopted a risk management policy where various risks faced by the Company have been identified and a framework for risk mitigation has been laid down. Even though not mandated, the Company has constituted a Risk Management Committee to monitor, review and control risks. The risks and its mitigating factors are discussed in the Board for identifying the element of risk which, in the opinion of the Board may threaten the existence of the Company and safeguarding the Company against those risks.
31. CODE OF CONDUCT AND ETHICS
The Board of Directors of the Company has adopted a Code of Conduct and Ethics for the Directors and Senior Executives of the Company. The object of the Code is to conduct the Company's business ethically and with responsibility, integrity, fairness, transparency and honesty. The Code sets out a broad policy for one's conduct in dealing with the Company, fellow Directors and with the environment in which the Company operates.
32. INFORMATION REQUIRED UNDER SEXUAL HARASSMENT OF WOMEN AT WORK PLACE (PREVENTION. PROHIBITION & REDRESSAL) ACT. 2013
Your Company has a policy and framework for employees to report sexual harassment cases at workplace and the process ensures complete anonymity and confidentiality of information. No complaints of sexual harassment were raised in the financial year 2021-22.
33. ANNUAL RETURN
As per the requirements of Section 92(3) of the Companies Act and Rules framed thereunder, the extract of the Annual Return is available on website of the Company i.e. www.ascomfinance.com.
34. RBI REGULATIONS
The Company continues to comply with all the requirements prescribed by the Reserve Bank of India (RBI) from time to time. The Board of Directors have framed various policies as applicable to the Company including Risk based internal audit policy. The Board periodically reviews the policies and approves amendments as and when necessary.
35. ACKNOWLEDGEMENT
Your Directors pay their sincere gratitude to the Company's employees, customers, vendors, investors, Business Constituents, Shareholders and academic institutions for their Co-operation and continuous support. The Directors also thank the Government of India and concerned government departments / agencies for their co-operation.