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EQUITY - MARKET SCREENER

M Lakhamsi Industries Ltd
Industry :  Finance & Investments
BSE Code
ISIN Demat
Book Value()
512153
INE808W01012
74.8584906
NSE Symbol
P/E(TTM)
Mar.Cap( Cr.)
N.A
1.29
0.57
EPS(TTM)
Face Value()
Div & Yield %
5.2
10
7.44
 

As on: Aug 14, 2022 09:22 PM

To

The Members of M Lakhamsi Industries Limited (Formerly Known as Specular Marketing and Financing Limited)

Your Directors have pleasure in presenting the 37th Directors' Report on the business and operations of the Company together with the Audited Financial Statements of Accounts of the Company for the Financial Year ended March 31, 2021.

1. FINANCIAL HIGHLIGHTS:

(Rupees in INR)

P A R T I C U L A R S FY 2020-21 FY 2019-20
Revenue from Operations 9,00,000 -
Other Income - -
Total Revenue 9,00,000 -
Employee Benefit Expenses 1,80,000 1,72,500
Finance Cost - -
Depreciation and Amortization Expenses 27 32
Other Expenses 6,69,654 42,22,729
Total Expenses 8,49,681 43,95,261
Profit/Loss Before Tax 50,319 (43,95,261)
Less: Tax Expense 10,000 -
Profit for the Year 40,319 (43,95,261)
Other Comprehensive Income -
Total Comprehensive Income/(loss) 40,319 (43,95,261)
for the year
Earning Per Shares (Basic) 0.16 (17.72)
Earning Per Shares (Diluted) 0.16 (17.72)

2. (a) STATE OF COMPANY AFFAIRS AND REVIEW OF OPERATIONS:

During the Financial Year ended 31st March, 2021, the Company has recorded total turnover of INR 9,00,000/- (Indian Rupees Nine Lakh Only). During the year under review the Company has earned Net Profit of INR 50,319/- (Rupees Fifty Thousand Three Hundred and Nineteen Only) as compared to previous year Loss of INR 43,96,261/- (Rupees Forty Three Lakh Ninety Six Thousands Two Hundred and Sixty One Only) in previous financial year. The management of the Company is putting their best efforts to improve the performance of the Company.

(b) CHANGE IN MANAGEMENT:

Pursuant to the Open Offer, management or control of the Company is changed. The acquirers and person acting in concert will become the Promoters and Promoter Group of the Company.

3. SHARE CAPITAL:

The Authorized Share Capital of the Company was increased from INR 25,00,000 (Indian Rupees Ten Lakh Only) in to 2,50,000 Equity Shares of INR 10/- each to INR 1,00,00,000 (Indian Rupees One Crore Only) divided into 10,00,000 Equity Shares of INR 10/- each in the EGM held on 07.06.2021.

On March 31, 2021, the paid-up capital stood at INR 24,80,000/- (Indian Rupees Twenty Four Lakh and Eighty Thousand Only) divided into 2,48,000 Equity Shares of INR 10/- (Indian Rupees Ten Only)each.

4. DEPOSITS:

During the year under review, your Company has not accepted any deposits, falling within the meaning of Section 73 of the Companies Act, 2013 and the Companies (Acceptance of Deposits) Rules, 2014.

5. DIVIDEND:

The Board of Directors did not recommend any dividend for the year.

6. 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.

7. AMOUNTS, IF ANY, WHICH IT PROPOSES TO CARRY TO ANY RESERVES:

We do not propose to transfer any amount to general reserve.

8. CHANGE IN THE NATURE OF BUSINESS, IF ANY:

During the financial year under review, there was no change in the nature of the business of the Company.

However pursuant to open offer and acquisition thereon, the Business of the Company changed to dealing in Edible products.

9. REVISION OF FINANCIAL STATEMENT, IF ANY:

There was no revision in the financial statements of the Company

10. DIRECTORS & KEY MANAGERIAL PERSONNEL:

Board of Directors

During the period under review, there is no change in the Board of Directors of the Company, as on March 31st, 2021 the composition of the Board and Key Managerial Personnel is as mentioned below.

6 Z B Name Of Director Designation Date of Appointment Date of Resignation
00211592 Shreyas Ramniklal Mehta Managing Director 21/03/1990 27/07/2021
00211712 Samir Mahendra Mehta Director 30/09/1999 27/07/2021
00211968 Nilima Shreyas Mehta Director 15/09/2015 27/07/2021
00343459 Dilip Navin Dalal Independent Director 30/09/1988 27/07/2021
05015909 Kerul Kiran Parikh Independent Director 11/10/2019 27/07/2021

Further, pursuant to the Open Offer, the Board has accepted the resignation letter from the existing directors on the Board and appointed the new directors on the Board. The Board places on record the sincere appreciation for the services rendered by the Directors resigned. As on date of this report, the composition of the Board and Key Managerial Personnel is as below:

DIN No. / PAN Name Of Director Designation Date of Appointment Date of Resignation
02045968 Sanjiv Mulchand Sawla Managing Director 27/07/2021 NA
00429203 Nilesh Damjibhai Vira Additional Director 08/04/2021 NA
01943285 Mallika Sanjiv Sawla Additional Director 27/07/2021 NA
02823232 Smita Mayur Parekh Independent Director 27/07/2021 NA
09267303 Kunaal Yoddha Independent Director 30/08/2021 NA

Key Managerial Personnel

• During the period under review, Mr. Tejas Shah Company Secretary and Compliance Officer of the Company has resigned w.e.f 31.03.2021 and the Board of Directors of the Company, based on the recommendations of the Nomination and Remuneration Committee, at its meeting held on 18th May 2021, has appointed Ms. Pooja as Whole Time

Company Secretary and Compliance Officer of the Company with effect from 18th May 2020.

• Mr. Ashay Shreyas CFO of the Company has resigned w.e.f 27.07.2021 and Ms. Mallika Sanjiv Sawla has been appointed as CFO of the Company w.e.f 27.07.2021.

11. NUMBER OF MEETINGS OF THE BOARD OF DIRECTORS

During the Financial Year under review 06 (Six) meetings of the Board of Directors were held. The dates on which the said meetings were held:

• 01st June 2020,

• 26th June 2020,

• 12th August 2020,

• 10th November 2020,

• 20th January 2021.

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

S. No. Name Of Director Designation No. of Board Meeting eligible to attend No. of Meetings attended No. Meeting in which absent
1. Shreyas Ramniklal Mehta Managing Director 5 5 0
2. Samir Mahendra Mehta Director 5 5 0
3. Nilima Shreyas Mehta Director 5 5 0
4. Dilip Navin Dalal Independent Director 5 5 0
5. Kerul Kiran Parikh Independent Director 5 5 0

12. MATERIAL CHANGES AND COMMITMENTS AFFECTING FINANCIAL POSITION OF THE COMPANY:

• COVID-19:

In the FY 2020-21, the Novel Coronavirus disease ('COVID-19') pandemic developed rapidly into a global crisis, forcing governments to enforce lock-downs of all economic activity. In enforcing social distancing to control the spread of the disease and ensuring the health and well-being of all employees, the Company's trading facilities and office operations were closed as and when declared by the concerned government authorities. Consequently, revenues and profitability have been affected, in line with the industry for few months of delay. The situation has come back to normal to this respect. The Company has readiness to adapt to the changing business environment and respond suitably to fulfil the needs of its customers while complying with the measure required by the Indian Government.

• Open Offer:

During the Financial Year, the Company has entered into the Business Succession Agreement with Mr. Sanjiv Mulchand Sawla and Mr. Mulchand Lakhamsi Sawla (Partners of M/s M. Lakhamsi and Co.) on 08th April, 2021. In continuation of the same Mr. Sanjiv Mulchand Sawla ("Acquirer 1") and Mr. Mulchand Lakhamsi Sawla ("Acquirer 2") has made a Public Announcement in respect of Open Offer for Acquisition of upto 2,20,480 (Two Lakh Twenty Thousand Four Hundred and Eighty) Equity Shares of the Company.

Pursuant to the Open Offer, management or control of the Company is changed. The aforesaid acquirers and person acting in concert will become the Promoters and Promoter Group of the Company.

• Issue of Equity Shares on Preferential Basis:

The Board of Directors at their meeting held on Thursday, 08th April, 2021 have inter alia approved Issue of shares, the details of which is as under:-

Issue in one or more tranches, up to 6,00,000 (Six Lakhs) Equity Shares of Rs.10/- (Rupees Ten Only) each at a premium of Rs. 90/-fully paid-up on Preferential Allotment basis to the Promoters and Non Promoters by virtue of Business Succession Agreement.

• Change of Object Clause of the Memorandum of Association:

Pursuant to the Business Succession Agreement with M/s M. Lakhamsi and Co., Board has considered that the main object clause of the Company needs to be changed to reflect the true nature of business. Accordingly the main objects were amended to carry the business of Exports of sesame seeds, castor oil and seeds, peanuts, safflower seeds, niger seeds, spices, wheat flour, rice, oil cakes, meals, Whole / Ground Spices, Seeds, Kernels, Oil Seeds, Pulses etc..

• Change In Name Of Company:

Pursuant to the Business Succession Agreement and change in object clause of the company, the Board of Directors of the company decided to change the name of the company as the old name is not in line with the revised objectives of the company. Hence in order to ensure that the name of the company adequately reflects the business being carried on by the Company, Accordingly the name of the company is changed from Specular Marketing and Financing Limited to M Lakhamsi Industries Limited w.e.f 25.08.2021

13. PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS MADE U/S 186 OF THE COMPANIES ACT, 2013:

The Company has not given any loan, guarantees or made any investments exceeding sixty per cent of its paid-up share capital, free reserves and securities premium account or one hundred per cent of its free reserves and securities premium account, whichever is more, as prescribed in Section 186 of the Companies Act, 2013.

14. INTERNAL FINANCIAL CONTROL SYSTEMS AND THEIR ADEQUACY:

According to Section 134(5)(e) of the Companies Act, 2013, the term "Internal Financial Control (IFC)" means the policies and procedures adopted by the Company for ensuring the orderly and efficient conduct of its business, including adherence to the company's policies, safeguarding of its assets, prevention and detection of frauds and errors, accuracy and completeness of the accounting records and timely preparation of reliable financial information. The company has a well-placed, proper and adequate Internal Financial Control System which ensures that all the assets are safeguarded and protected and that the transactions are authorized recorded and reported correctly. 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 the top management to executive level.

The compliance relating to Internal Financial controls have been duly certified by the statutory auditors.

15. CORPORATE SOCIAL RESPONSIBILITY:

Provisions of Corporate Social Responsibility are not applicable on the Company. Therefore, Company has not developed and implemented any Corporate Social Responsibility Initiatives as provisions of Section 135(1) of the Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014.

16. CORPORATE GOVERNANCE:

Provisions of Para C, D and E of Schedule V of the SEBI (Listing Obligations and Disclosures Requirements) Regulations, 2015 are not applicable to your Company. Hence, report on Corporate Governance is not annexed.

17. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND OUTGO:

The particulars as prescribed under sub-section (3)(m) of Section 134 of the Companies Act, 2014 read with Rule 8(3) of Companies (Accounts) Rules, 2014 are annexed herewith at "Annexure-I".

18. DECLARATION BY AN INDEPENDENT DIRECTOR(S) AND RE- APPOINTMENT, IF ANY:

The Independent Directors have submitted their disclosures to the Board that they fulfill all the requirements as stipulated in Section 149(7) of the Companies Act, 2013 so as to qualify themselves to be appointed as Independent Directors under the provisions of the Companies Act, 2013 and the relevant rules.

19. BOARD EVALUATION:

The Board of Directors has carried out an annual evaluation of its own performance, board committees and individual directors pursuant to the provisions of the Act and the corporate governance requirements as prescribed by Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations 2015 ("SEBI Listing Regulations").

The performance of the board was evaluated by the Board after seeking inputs from all the directors on the basis of the criteria such as the board composition and structure, effectiveness of board processes, information and functioning, etc.

The performance of the committees was evaluated by the Board after seeking inputs from the committee members on the basis of the criteria such as the composition of committees, effectiveness of committee meetings, etc.

The Board and the Nomination and Remuneration Committee reviewed the performance of the individual directors on the basis of the criteria such as the contribution of the individual director to the Board and Committee meetings like preparedness on the issues to be discussed, meaningful and constructive contribution and inputs in meetings, etc. In addition, the chairman was also evaluated on the key aspects of his role.

In a separate meeting of independent directors, performance of non-independent directors, performance of the board as a whole and performance of the chairman was evaluated, taking into account the views of executive directors and non-executive directors. The same was discussed in the board meeting that followed the meeting of the independent directors, at which the performance of the board, its committees and individual directors was also discussed. Performance evaluation of independent directors was done by the entire board, excluding the independent director being evaluated.

20. STATEMENT SHOWING THE NAMES OF THE TOP TEN EMPLOYEES IN TERMS OF REMUNERATION DRAWN AND THE NAME OF EVERY EMPLOYEE AS PER RULE 5(2) & (3) OF THE COMPANIES (APPOINTMENT & REMUNERATION) RULES, 2014:

Disclosure pertaining to remuneration and other details as required under Section 197 of the Companies Act, 2013 read with rule 5(1) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 is given in "Annexure-II" to this Report.

The Statement containing the particulars of employees as required under section 197(12) of the Companies Act, 2013 read with rule 5(2) and other applicable rules (if any) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, is provided in a separate annexure forming part of this report.

21. RATIO OF REMUNERATION TO EACH DIRECTOR

During the year Company has not given any remuneration to any Director of the Company.

22. COMMITTEES OF THE BOARD AND OTHER COMMITTEES:

Currently, the Board has following committees: Audit Committee and Nomination & Remuneration Committee.

Audit Committees:

The Audit Committee of the Company is constituted/re-constituted in line with the provisions of Regulation 18 of SEBI (Listing Obligations and Disclosure requirements)

Regulations, 2015 read with Section 177 of the Companies Act, 2013.The Audit Committee is constituted in line to monitor and provide effective supervision of the management's financial reporting process, to ensure accurate and timely disclosures, with the highest level of transparency, integrity, and quality of Financial Reporting.

During the Financial Year under review 04 (Four) meetings of the Audit Committee were convened and held. The dates on which the said meetings were held:

• 26th June 2020,

• 12th August 2020,

• 10th November 2020,

• 20th January 2021

S. Name of the Members No Designation No. of Audit Committee Meetings attended during the year
1. *Mr. Dilip N Dalal Chairman and Independent Director 4
2. *Mr. Samir Mahendra Mehta Member and Director 4
3. *Mr. Kerul Parikh Member and Independent Director 4
4. ** Mr. Mallika Sanjiv Sawla Chairman and NonExecutive Director -
5. ** Ms. Smita Mayur Parekh Member and Independent Director -
6. *** Mr. Kunaal Y oddha Member and Independent Director -

*Resigned w.e.f., 27.07.2021 **Appointed w.e.f., 27.07.2021 *** Appointed w.e.f., 30.08.2021

During the year, all recommendations of the audit committee were approved by the Board of Directors.

Nomination and Remuneration Committee:

The Nomination and Remuneration Committee of the Company is constituted/re- constituted in line with the provisions of Regulation 19 of SEBI (Listing Obligations and Disclosure requirements) Regulations, 2015 read with Section 178 of the Companies Act, 2013. The Nomination and Remuneration Committee recommends the appointment of Directors and remuneration of such Directors. The level and structure of appointment and remuneration of all Key Managerial personnel and Senior Management Personnel of the Company, as per the Remuneration Policy, is also overseen by this Committee.

During the Financial Year under review 02 (Two) meetings of the Nomination and Remuneration Committee were convened and held. The dates on which the said meetings were held:

• 12th August, 2020

• 20th January, 2021

S. No Name of the Members Designation No. of Nomination and remuneration Committee Meetings attended during the year
1. * Mr. Samir Mahendra Mehta Chairman and NonExecutive Director 2
2. * Mr. Dilip N Dalal Member and Independent Director 2
3. * Mr. Kerul Parikh Member and Independent Director 2
4. ** Ms. Smita Mayur Parekh Chairman and Independent Director
5. ** Mr. Mallika Sanjiv Sawla Member and NonExecutive Director
6. *** Mr. Kunaal Yoddha Member and Independent Director

*Resigned w.e.f., 27.07.2021 **Appointed w.e.f., 27.07.2021 *** Appointed w.e.f., 30.08.2021

23. POLICY ON DIRECTORS' APPOINTMENT AND REMUNERATION AND OTHER DETAILS:

The Nomination & Remuneration Committee of Directors have approved a Policy for Selection, Appointment, Remuneration and determine Directors' Independence of Directors which inter-alia requires that composition of remuneration is reasonable and sufficient to attract, retain and motivate Directors, KMP and senior management employees and the Directors appointed shall be of high integrity with relevant expertise and experience so as to have diverse Board and the Policy also lays down the positive attributes/criteria while recommending the candidature for the appointment as Director.

Nomination & Remuneration Policy is uploaded on the website of the Company i.e. at http://www.specularmarketing.com/.

24. RISK MANAGEMENT:

The Company is taking every care for minimizing the risk involved in the manufacturing process of the unit, business of dealers and agents and Investment Business. Our Company believes that managing helps in maximizing returns. Responsible staff is employed to take every care to minimize the risk factor in the factory. Our company does not have any separate Risk Management Policy as the unit run by it is small in size and the elements of risk threatening the company's existence is almost negligible.

25. PARTICULARS OF CONTRACTS OR ARRANGEMENTS MADE WITH RELATED PARTIES:

During the year, there is no transaction entered with related parties referred to in Section 188(1) of the Companies Act, 2013 read with Rule 8(2) of Companies (Accounts) Rules, 2014. Therefor there is no requirement to attached Form AOC-2 Related party transactions if any, are disclosed in the notes to financial statements.

26. NO FRAUDS REPORTED BY STATUTORY AUDITORS

During the Financial Year 2020-21, the Auditors have not reported any matter under section 143(12) of the Companies Act, 2013, therefore no detail is required to be disclosed under section 134(3) (ca) of the Companies Act, 2013.

27. SUBSIDIARIES, TOINT VENTURES AND ASSOCIATE COMPANIES:

During the year under review, 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.

28. VIGIL MECHANISM / WHISTLE BLOWER POLICY:

Pursuant to Section 177(9) and (10) of the Companies Act, 2013, and Regulation 22 of the SEBI (Listing Obligation and Disclosure Requirement) Regulation, 2015, the Company has formulated Whistle Blower Policy for vigil mechanism of Directors and employees to report to the management about the unethical behavior, fraud or violation of Company's code of conduct. The mechanism provides for adequate safeguards against victimization of employees and Directors who use such mechanism and makes provision for direct access to the chairman of the Audit Committee in exceptional cases.

29. DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS OR TRIBUNALS IMPACTING THE GOING CONCERN STATUS AND COMPANY'S OPERATIONS IN FUTURE:

During the period under review no material orders have been passed by the regulators or courts or tribunals impacting the going concern status and company's operations in future.

30. DIRECTORS' RESPONSIBILITY STATEMENT:

Pursuant to the requirement under Section 134 (5) of the Companies Act, 2013, with respect to Directors Responsibilities Statement, it is hereby confirmed:

(a) That 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;

(b) That the directors had selected such accounting policies and applied them consistently and made judgments and estimates that were 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 or loss of the company for the year review;

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

(d) That the directors had prepared the annual accounts for the financial year ended 31st March,2021 on a going concern basis;

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

(f) That 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.

31. AUDITORS& AUDITOR'S REPORT:

Statutory Auditor:

Pursuant to the provisions of Section 139 of the Act and the rules framed thereafter, M/s K.B. Gosalia & Co., Chartered Accountants, were appointed as statutory auditors of the Company from the conclusion of the Thirty Third (33rd) Annual General Meeting (AGM) of the Company held on 10th August, 2017 till the conclusion of the Thirty Eighth (38th) AGM to be held in the year 2022.

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.

There are no qualifications or adverse remarks in the Auditors' Report which require any clarification or explanation.

However, w.e.f 27.07.2021 M/s. K.B. Gosalia & Co. have resigned as statutory auditors of the Company and M/s Rajen T. Gala & Co. as statutory auditors were appointed w.e.f 27.07.2021 as a result of casual vacancy who holds office upto this Annual General Meeting. Their appointment as statutory auditors for the period of 5 years from the conclusion of this Annual General Meeting is sought from the shareholders in the ensuing Annual General Meeting.

Secretarial Auditor:

Pursuant to the provisions of Section 204 of the Companies Act, 2013 and Rule 9 the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, the Company has appointed Mr. Prashant Diwan, Practicing Company Secretary, to carry out Secretarial Audit for the financial year 2020-21. The Secretarial Audit report is annexed as "Annexure - III" to this Report. The report does not contain any qualifications.

The Auditors' Report does not contain any qualifications, reservations or adverse remarks.

Cost auditors:

Pursuant to Section 148 of the Companies Act, 2013 maintenance of cost accounts and requirement of cost audit is not applicable.

Internal auditors

The Company has complied with the requirement of the section 138 of the Companies Act, 2013 read with rule 13 of the Companies (Accounts) Rules, 2014, and other applicable provisions of the Act.

32. SECRETARIAL STANDARDS

Pursuant to the provisions of Section 118 of the Companies Act, 2013, the Company has complied with the applicable provisions of the Secretarial Standards issued by the Institute of Company Secretaries of India and notified by Ministry of Corporate Affairs.

33. ANNUAL RETURN

As required pursuant to section 92(3) of the Companies Act, 2013 and rule 12(1) of the Companies (Management and Administration) Rules, 2014, an annual return is uploaded on website of the Company www.specularmarketing.com.

34. FAMILIARISATION PROGRAMMES

The Company familiarises its Independent Directors on their appointment as such on the Board with the Company, their roles, rights, responsibilities in the Company, nature of the industry in which the Company operates, etc. through familiarisation programme. The Company also conducts orientation programme upon induction of new Directors, as well as other initiatives to update the Directors on a continuing basis. The familiarisation programme for Independent Directors is disclosed on the Company's website www.specularmarketing.com.

35. MANAGEMENT DISCUSSION AND ANALYSIS REPORT:

The Management's Discussion and Analysis Report for the year under review, as stipulated under regulation 34 (3) and Part B of schedule V of the SEBI (Listing Obligation and Disclosure Requirement) Regulation, 2015 is annexed to this Annual Report as "Annexure - IV".

36. CODE OF CONDUCT:

Commitment to ethical professional conduct is a must for every employee, including Board Members and Senior Management Personnel of the Company. The Code is intended to serve as a basis for ethical decision-making in conduct of professional work. The Code of Conduct enjoins that each individual in the organization must know and respect existing laws, accept and provide appropriate professional views, and be upright in his conduct and observe corporate discipline. The duties of Directors including duties as an Independent Director as laid down in the Companies Act, 2013 also forms part of the Code of Conduct. All Board Members and Senior Management Personnel affirm compliance with the Code of Conduct annually.

37. INFORMATION REQUIRED UNDER SEXUAL HARASSMENT OF WOMEN AT WORK PLACE (PREVENTION, PROHIBITION & REDRESSAL) ACT, 2013:

The Company has zero tolerance towards sexual harassment at the workplace and towards this end, has adopted a policy in line with the provisions of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules there under. The Company has complied with provisions relating to the constitution of Internal Complaints Committee under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 which redresses complaints received on sexual harassment. During the financial year under review, the Company has not received any complaints of sexual harassment from any of the women employees of the Company.

38. STATEMENT ON OTHER COMPLIANCES

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. Details relating to deposits covered under Chapter V of the Act.

b. Issue of equity shares with differential voting rights as to dividend, voting or otherwise;

c. Issue of shares (including sweat equity shares) to employees of the Company.

d. Neither the Managing Director nor any of the Whole-time Directors of the Company receive any remuneration or commission.;

39. ACKNOWLEDGEMENT:

The Directors regret the loss of life due to COVID-19 pandemic and are deeply grateful and have immense respect for every person who risked their life and safety to fight this pandemic. The Directors wish to convey their appreciation to all of the Company's employees for their contribution towards the Company's performance. The Directors would also like to thank the shareholders, employee unions, customers, dealers, suppliers, bankers, governments and all other business associates for their continuous support to the Company and their confidence in its management.

Date:30.08.2021 For & on behalf of the Board
Place: Mumbai M Lakhamsi Industries Limited (Formerly known as Specular Marketing & Financing Limited)
Sd/- Sd/-
Sanjiv Mulchand Sawla Mallika Sanjiv Sawla
Managing Director Director
DIN: 02045968 DIN: 01943285