As on: Oct 01, 2023 08:04 AM
To,
The Members,
Yours Directors take pleasure in presenting the Twenty-Seventh (27th) Annual Report on the business and operations of your Company together with the audited accounts for the financial year ended March 31,2022.
1. Financial Summary/ Performance of the Company:
(Amount in Rs.)
2. Dividend
The Board of Directors of your Company, after considering the relevant circumstances holistically and in order to conserve the resources, has decided that it would be prudent not to recommend any divided for the year ended 31st March, 2022.
3. Transfer to Reserves
Your Company has transferred a sum of ' 23,00,038 to the General Reserves. The total Reserves and Surplus as at March 31, 2022 was ' 4,68,28,031.
4. Operations Review and the state of affairs of the Company
During the year under the review your Company focuses on achieving milestone in the same area. This would strengthen the generation and sustainability of revenue in the years to come. Your Company achieved total revenue of '150,513,958/- in 2021-22 as against ' 27,07,95,514/- in 2020-21 and earned a profit of ' 23,00,038 /- in 2021-22 as against ' 21,15,072/- in 2020-21, registering a growth of 8.74% as compared to the previous year profit.
5. Nature of Business
Your Company continues to operate only in one segment i.e. in the business of all kinds of varieties of steels, stainless steels, mild steels, carbon iron steel and acting as consignment agent and there is no change in the nature of business of the company.
6. Share Capital/ Capital Structure and Listing of Share
The Authorised Share capital of the Company as at 31st March, 2022 was ' 95,000,000/- divided into 9,500,000 equity shares of ' 10/- each.
The Paid up Share Capital of your Company as on 31st March, 2022 was ' 79,919,000 divided into 7,991,900 equity shares of ' 10/- each. During the year under review, your Company has not issued any shares.
The Company's equity shares are listed with BSE Limited. The annual listing fee for the financial year 2022-23 is required to be paid to the Stock Exchange
7. Material changes and commitments affecting the financial position of the Company
There has been no material Change and Commitment 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.
8. Subsidiaries, Associate Companies and Joint Venture
The Company is not required to consolidate its financial statement for the year ended 31st March, 2022 as the Company does not have any subsidiaries, joint venture, or associate Companies.
9. Indian Accounting Standards (Ind As):-
The Ministry of Corporate Affairs (MCA) vide its notification in the Official Gazette dated February 16, 2015, notified the Indian Accounting Standard (Ind As) and Ind AS has replaced the existing Indian GAAP prescribed under Section 133 of the Companies Act, 2013 read with Rule 7 of the Companies (Accounts) Rules, 2014. The Company has adopted Indian Accounting Standards ("Ind AS") from April 01, 2017 (transition date to Ind AS is April 01, 2016) and the financial Statements have been prepared in accordance with recognition and measurement principal of Indian Accounting Standards ("Ind AS") as prescribed under the Companies (Indian Accounting Standards) Rules, 2015, as specified in section 133 of the Companies Act, 2013.The Annual Accounts for the year ended 31st March, 2022 have also been prepared in accordance with Indian Accounting Standard (Ind AS).
10. Conservation of Energy, Technology Absorption and Foreign Exchange Earnings and Outgo
The Company being engaged in the business of Trading of Stainless
Steel and does not have any energy utilization or technology absorption. The Company during the year under review does not have any inflow or outflow in foreign exchange.
The Information relating to conservation of energy, technology absorption, foreign exchange earnings and outgo under Section 134(3) (m) of the Companies Act, 2013 read with Rule 8(3) of the Companies (Accounts) Rules, 2014 is enclosed as "Annexure-I" and forms part to this report.
11. Board and Committee Meetings
During the financial year 2021-22, 5 (Five) number of Board Meetings and 5 (Five) number of Audit Committee Meetings were held. For the details thereof kindly refer to the Corporate Governance Report.
The intervening gap between the Meetings was within the period prescribed under the Companies Act, 2013.
Board Meeting dates are finalized in consultation with all directors and agenda papers backed up by comprehensive notes and detailed background information are circulated well in advance before the date of the meeting thereby enabling the Board to take informed decisions.
12. Annual Return
Pursuant to Section 92(3) read with Section 134(3)(a) of the Act, the draft copy of Annual Return as on March 31, 2022 is available on the Company's website at http://www.srusteels.in/annual return.html
13. Directors & Key Managerial Personnel
a) Retirement by Rotation
Pursuant to the provisions of Section 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 themselves for re-appointment at every AGM. Consequently , Mrs. Richa Singla (DIN:00082722), Director, is liable to retire by rotation at the ensuing Annual General Meeting of the Company and being eligible, she has offered herself for reappointment. Necessary resolution for her reappointment are included in the Notice of AGM for seeking approval of members. The Board of Directors has recommended her re-appointment.
The details as required under Regulation 36(3) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 regarding re-appointment of Mrs. Richa Singla, her brief resume, the nature of expertise in specific functional areas, names of Companies in which she hold Directorships, committee Memberships/ Chairmanships, her shareholding in the Company etc., are furnished in the annexure to the notice of the ensuing AGM.
b) Appointment Mr. Deepak
Mr. Deepak has been appointed by the Board of Directors of the Company as Company Secretary and Compliance Officer of the Company with effect from February 14, 2022 on the recommendation of the Nomination and Remuneration Committee of the Company, pursuant to the provisions of SEBI (Listing Obligations & Disclosure Requirements) Regulations, 2015 and pursuant to the provision of Section 2 (18) read with Section 203 of the Companies Act, 2013 read with Companies (Appointment and Remuneration) Rules, 2014
c) Cessation
During the year under review, Ms. Shallu Garg, has resigned from the post of Company Secretary and Compliance Officer of the Company w.e.f January 20, 2022 and the Board places on record its appreciation for Ms. Shallu Garg for her invaluable contribution and guidance during her tenure as Company Secretary and Compliance Officer of the Company.
d) Woman Director
In terms of Section 149 of the Companies Act, 2013 read with Companies (Appointment and Qualification of Directors) Rules, 2014 and Regulation 17 of the SEBI (Listing Obligations and Disclosure Requirements) Regulation, 2015, the Company has appointed Ms Richa Singla (DIN: 00082722) who is serving on the Board of the Company, since the year 2014.
14. Declaration from Independent Directors on Annual Basis
The company has received necessary declarations from all the Independent Directors of the company under Section 149(7) of the Act confirming that they meet the criteria of independence as laid down under Section 149(6) of the Companies Act, 2013 and Regulation 16(1) (b) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
The Company has also received from them declaration of Compliance of Rule 6 (1) & (2) of the Companies (Appointment and Qualifications of Directors) Rules, 2014, regarding online registration with the 'Indian Institute of Corporate Affairs' and for renewal of name in the data bank of Independent Directors. During the financial year 2021-22, the Board of Directors have taken on record the declarations and confirmations submitted by the independent director.
The Board of Director are of the opinion that the independent director is a person of integrity and possesses relevant expertise and experience and his continued association as Director will be of immense benefit and in the best interest of the Company and there has been no change in the circumstances which may affect their status as Independent Directors of the Company and the Board is satisfied of the integrity, expertise, and experience (including proficiency in terms of Section 150(1) of the Act and applicable rules thereunder) of all Independent Directors on the Board.
15. Policy on Directors' appointment and Policy on Remuneration
Pursuant to the provisions of Section 134 (3) (e) and Section 178 of the Companies Act, 2013 and in terms of Regulation 19(4) of the SEBI (Listing Obligation and Disclosure Requirement) Regulations, 2015, the Board has formulated a policy on Nomination and Remuneration for its Directors, Key Managerial Personnel and senior management.
The salient features of the Policy are:
• It provides the diversity on the Board of the Company and
• It provides the mechanism for performance evaluation of the Directors
• It lays down the parameters based on which payment of remuneration (including sitting fees and remuneration) should be made to Independent Directors and Non-Executive Directors.
• It lays down the parameters based on which remuneration (including fixed salary, benefits and perquisites, bonus/ performance linked incentive, commission, retirement benefits) should be given to Whole-time Directors, KMPs and rest of the employees.
• It lays down the parameters for remuneration payable to Director for services rendered in other capacity.
It is hereby affirmed that the Remuneration paid is as per the Remuneration Policy of the Company. During the year under review, there were no substantive changes in the Policy except to align the Policy with amendments made to applicable laws. The Policy is available on the website of the Company at http://www.srusteels.in/ pdfs/investor-policies/NRP.pdf
16. Particulars of remuneration of Directors/ KMP/ Employees
Disclosure pertaining to the remuneration and other details as required under Section 197(12) of the Companies Act, 2013 read with Rules 5(1) of the Companies(Appointment and Remuneration of Managerial Personnel) Rules, 2014, is attached as "Annexure-M", forming part of this report.
Further in pursuant to Section 197(12) of the Companies Act, 2013 read with Rule 5(2) and 5(3) of Companies (Appointment and Remuneration of Managerial Personnel), Amendment Rules, 2016, a statement showing the names and other particulars of the top ten employees and the employees drawing remuneration in excess of the limits set out in the said rules is enclosed as "Annexure-III" and forms part of this Report.
17. Evaluation of the Board's Performance
Pursuant to applicable provisions of the Act and the Listing Regulations, the Board, in consultation with its Nomination and Remuneration Committee, has formulated a framework containing, inter-alia, the criteria for performance evaluation of the entire Board of the Company, its Committees and individual directors, including Independent Directors. The framework is monitored, reviewed and updated by the Board, in consultation with the Nomination and Remuneration Committee, based on need and new compliance requirements.
The Board of Directors have carried out the annual evaluation of its own performance, the Individual Directors including the Chairman as well as the evaluation of the working of its Committees. The evaluation of Board as a whole and Non-Independent Directors including Chairman was done by the Independent Directors in their meeting held on 08th March, 2022. The details of evaluation process of the Board, its Committees and individual directors, including independent directors have been provided under the Corporate Governance Report which forms part of this Report.
18. Director's Responsibility Statement
Pursuant to Section 134(3) (c) and Section 134(5) of the Companies act, 2013, the Board of Directors of the Company hereby confirms and accepts the responsibility for the following in respect of the Audited
Annual Accounts for the financial year ended March 31, 2022:
a) That in the preparation of the annual accounts for the financial year ending 31st March, 2022, the applicable accounting standards had been followed along with proper explanation relating to material departures;
b) That the directors had selected the 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 the profit and loss of the Company for that period;
c) That 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) That the annual accounts/financial statements have been prepared on a going concern basis;
e) That proper internal financial controls were in place and that the financial controls were adequate and were operating effectively;
f) That the directors had devised proper systems to ensure compliance with the provisions of all applicable laws and that such systems were adequate and operating effectively.
19. Auditors
i. Statutory Auditor and their Report
Pursuant to the provisions of Section 139 of the Act, and rules made thereunder, M/s. Agarwal Mahesh Kumar & Co, Chartered Accountants, Delhi (Firm Registration No. 014618N) were appointed as the Statutory Auditors of the Company for a period of five consecutive years, to hold the office from the conclusion of 24th Annual General Meeting up to the Conclusion of 29th Annual General Meeting held in the year 2024 at a remuneration as may be fixed by the Board of Directors or Audit Committee in consultation with the Auditors thereof.
Pursuant to Section 139 and 141 of the Act and relevant Rules prescribed there under, the Statutory Auditors have confirmed that they are not disqualified from continuing as Auditors of the Company.
The Audit report on the financial statement of the Company for the FY 2021-22 forms part of the Annual Report. There are no qualifications, reservations or adverse remarks or disclaimer made by M/s. Agarwal Mahesh Kumar & Co, Chartered Accountants, in their report for the financial year ended 31st March, 2022.
Pursuant to Section 134 (3) (ca) during the year under review, the Statutory Auditor have not reported any instances of frauds committed in the Company by its Officers or Employees to the Audit Committee or the Board or Central Government under Section 143(12) of the Companies Act, 2013, details of which needs to be mentioned in this report.
ii. Cost Auditors
In pursuant to Section 148(1) of the Companies Act, 2013 and rules and regulation made there under read with the Companies (Accounts Rules) Amendment Rules, 2018, Cost audit is not applicable to the Company and therefore maintenance of cost records as specified under section 148(1) ofthe Act, is not required.
iii. Secretarial Auditors and Secretarial Audit Report
In terms of Section 204(1) of Companies Act, 2013, read with Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, the Company has appointed M/s Anand Nimesh & Associates, Company Secretaries, Delhi as the secretarial auditor of the Company for the financial year ending 31st March, 2022.
The Secretarial Audit Report submitted by M/s Anand Nimesh & Associates, Company Secretaries in prescribed format in MR-3 to the shareholders of the Company is annexed to this Report as "Annexure-IV".
Explanation to the observation in secretarial audit report:
1. BSE vide its Letter No. DSC/DL/SK/IP/534/2017-18 dated October 27, 2017 had granted In-principal approval for Listing of 7,991,900 equity shares, however trading approval was granted only for 3,627,400 equity shares and 4,364,500 equity shares has been kept in abeyance.
In this regard, it is submitted that
1. The Company has made an application dated 22.04.2022 along with the required documents/information with regard to granting trading approval of post-merger shares i.e. 43,64,500 to SEBI and the same is under examination by the concerned department of SEBI.
M/s Anand Nimesh & Associates, Company Secretaries in Practice have been re-appointed by the Board of Directors on recommendation of Audit Committee in pursuant to the provisions of the Section 204 of the Companies Act, 2013 and the rules made there under (including any statutory modification(s) or re-enactment thereof for the time being in force for the financial year 2022-23.
iv. Internal Auditor
Pursuant to the provisions of the Section 138 of the Companies Act,2013 and the rules made there under (including any statutory modification(s) or re-enactment thereof for the time being in force), the Board of Directors on recommendation of Audit Committee appointed M/s Goel Vikas & Co., Chartered Accountant as Internal Auditors of the company for the financial year 2021-22 and the report submitted by them was placed before the audit committee and Board of Directors.
It is hereby informed that Pursuant to the provisions of the Section 138 of the Companies Act,2013 and the rules made there under (including any statutory modification(s) or re-enactment thereof for the time being in force), the Board of Directors on recommendation of Audit Committee appointed M/s Goel Vikas & Co., Chartered Accountant as Internal Auditors of the company for the financial year 2022-23 at such remuneration as fixed by Board in consultation with Audit Committee.
20. Particulars of loans, guarantees or investments made under Section 186 of the Companies Act, 2013
Details of loans, guarantees and investments covered under the provisions of Section 186 of the Act are given in the Note No. 5 to the financial statements.
21. Particulars of contract or arrangements with related parties referred to in Section 188(1)
With reference to Section 134 (3)(h) of the Act, all the contracts and arrangements with related parties under Section 188(1) of the Act, entered by the Company during the financial year, were approved by the Audit Committee and wherever required, also by the Board of Directors.
All related party transactions that were entered into during the financial year were on arm's length basis, in the ordinary course of business and were in compliance with the applicable provisions of the Act and the SEBI Listing Regulations.
The disclosure of material related party transactions as required under Section 134(3) (h) of the Act in Form No. AOC-2 is annexed to this Report as "Annexure-V".
All related party transactions are approved/ reviewed by the Audit Committee on quarterly basis, with all the necessary details and are presented to the Board and taken on record. The Board has formulated policy on Related Party Transactions and it may be accessed at the website of the company http://www.srusteels.in/pdfs/investor- policies/Policy-on-Related-Party-Transactions-2022.pdf
All the related party transactions under Ind AS-24 have been disclosed at Note No. 35 to the standalone financial statements forming part of this Annual Report.
A confirmation as to compliance of Related Party Transactions as per Listing Regulations is also sent to the Stock Exchanges along with the quarterly compliance report on Corporate Governance. Disclosure of related party transactions on a consolidated basis is also sent to the Stock Exchanges after publication of standalone financial results for the half year.
22. Internal Financial Control
According to Section 134 (5) (e) of the Companies Act, 2013 read with rule 8 of the Companies (Accounts) Rules, 2014, 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 Company's policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information.
The Company believes that a strong internal control framework is very much essential and is part of good corporate governance practices. Your Company has in place well defined and adequate internal financial control framework commensurate with the size and complexity of its business to ensure proper recording of financial & operational information, compliance of various internal control and other regulatory/statutory compliances. All internal Audit findings and control systems are periodically reviewed by the Audit Committee of the Board of Directors, which provides strategic guidance on internal control.
23. Risk Management Policy
Pursuant to the provisions of Section 134 (3) (n) of the Companies Act, 2013, the Company has put in place comprehensive risk assessment and minimization procedures, which are reviewed by the Board periodically. In order to effectively and efficiently manage risk and address challenges, the Company has formulated Risk Management Policy.
The risk management approach is based on the clear understanding of the variety of risks that the organization faces, disciplined risk monitoring and measurement and continuous risk assessment and mitigation reserves. The objective of any risk identification and assessment process is to evaluate the combination of like hood and level of negative impacts from an event. The three main components of risk assessment are business risk, service/ operational risk and external risk. The Company manages the risk in line with current risk management best practices. This facilitates the achievement of our objectives, operational effectiveness and efficiency, protection of people and assets, informed decision-making and compliance with applicable law and regulations. The Board has formulated policy on Risk Management Policy and it may be accessed at the website of the company at http://srusteels.in/pdfs/investor-policies/Risk%20 Managment%20Policv.pdf
24. Committees of Board
(i) Corporate Social Responsibility (CSR)
In pursuant to Section 135 of the Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014, Every company having net worth of rupees five hundred crore or more, or turnover of rupees one thousand crore or more or a net profit of rupees five crore or more during the immediately preceding financial year shall constitute a Corporate Social Responsibility Committee of the Board consisting of three or more Directors, out of which at least one director shall be an independent director.
During the year under review none of the condition as prescribed under Section 135 of the Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014 are applicable to the company; hence the provision is not applicable.
(ii) Audit Committee
Audit Committee of the Company meets the requirements of Section 177 of the Companies Act, 2013 and Regulation 18 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015. The details of the composition of the Audit Committee as required under the provisions of Section 177(8) of the Companies Act, 2013 are given in the Corporate Governance Report which forms part of this annual report.
The terms of reference of Audit Committee are confined to Companies Act 2013 & Regulation 18 of the SEBI (Listing Obligations and Disclosure Requirements), Regulations, 2015 read with Part-C of Schedule II.
During the year under review, the Board has accepted all the recommendations of the Audit Committee. The details of meetings with attendance thereof and terms of reference of Audit Committee have been provided in the Corporate Governance Report which forms part of this report.
(iii) Nomination and Remuneration Committee
The Company has formed the Nomination and Remuneration Committee in accordance with the provisions of the Section 178 Companies Act 2013 and Regulation 19 of SEBI (Listing Obligation and Disclosure Requirement) Regulations, 2015. The details about the composition of the said committee of the Board of Directors along with attendance thereof have been provided in the Corporate Governance Report forming part of this report.
(iv) Stakeholder Relationship Committee
The Company has also formed Stakeholder's Relationship Committee in compliance to the Companies Act, 2013 & Regulation 20 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The details about the composition of the said committee of the Board of Directors along with attendance thereof have been provided in the Corporate Governance Report forming part of this report.
25. Disclosure on Pubic Deposit
During the year under review, the Company has neither accepted nor renewed any deposits in terms of Chapter V of the Companies Act, 2013 and Rules framed thereunder.
26. Managing the Risks of Fraud, Corruption and Unethical Business Practices
Disclosure on Vigil Mechanism / Whistle Blower Policy
The Company has established a Vigil Mechanism/ Whistle blower Policy as a part of its vigil mechanism. The purpose of this Policy is to enable any person including the directors, employees, other stakeholders, etc. to raise concerns regarding unacceptable and improper practices and/or any unethical practices in the organization without the knowledge of the management.
All employees shall be protected from any adverse action for reporting any unacceptable or improper practice and/or any unethical practice, fraud or violation of any law, rule or regulation, potential or actual violation, leakage of unpublished price sensitive information without fear of reprisal.
The Company believes in the conduct of its affairs and its constituents by adopting the highest standards of professionalism, honesty, integrity, and ethical behavior, in line with the Code of Conduct ('Code'). All the stakeholders are encouraged to raise their concerns or make disclosures on being aware of any potential or actual violation of the Code, policies or the law. Periodic awareness sessions are also conducted for the same.
The Board has formulated policy on Vigil Mechanism/ Whistle blower Policy and the same may be accessed at the website of the Company i.e. http://srusteels.in/pdfs/investor-policies/Policy%20on%20Vm% 20&%20While%20Blowing.pdf
27. Significant and material orders passed by the regulators or courts or tribunals impacting the going concerns status and company's operations in future
The Company has not received any significant or material orders passed by any regulatory authority, court or tribunal which shall impact the going concern status and Company's operations in future.
28. Corporate Governance
Good Corporate practice is a norm at SRU Steels Limited. The Company is committed to focus on long term value creation and protecting stakeholders' interests by applying proper care, skill and diligence to business decisions. Besides complying with the legal framework of Corporate Governance Practices. As per the requirement of Regulation 34(3) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 executed with the Stock Exchange(s), Your Company has complied with the Corporate Governance norms as stipulated under the Listing Regulations. A detailed report on Corporate Governance forms part of this Annual Report.
29. Management Discussion & Analysis Report
As per requirements of Listing Regulations, a detailed review of the developments in the industry, performance of the Company, opportunities and risks, internal control systems, outlook etc. of the Company is given under the head Management Discussion and Analysis Report, which forms part of this Annual Report.
30. Sexual Harassment of Woman at work place
The Company has zero tolerance for sexual harassment at workplace and had in place policy on Prevention, Prohibition and Redressal of Sexual Harassment for women at workplace in accordance with the requirements ofSexualHarassment of Women at Workplace(Prevention, Prohibition & Redressal) Act, 2013 ('POSH Act) and Rules made thereunder.
With the objective of providing a safe working environment, the Company has constituted Internal Committee at its locations to redress complaints received regarding sexual harassment. The policy has set guidelines on the redressal and enquiry process that is to be followed by complainants and the ICC, whilst dealing with issues related to sexual harassment at the work place.
During the year, company has not received any sexual harassment complaints.
31. Independent Director's familiarisation Programme
The Company has formulated a programme for familiarization of Independent Director with regard to roles, rights, responsibilities, nature of the industry in which the Company operates, the business model of the Company etc. The details of the Familiarization Programmes as conducted by the Company are available on the website of the Company at www.srusteels.in. However, during the year under review, there was no change in the nature of business of the company and its business vertical/structure/operational strategy, etc., which would have necessitated fresh Familiarization Programme for Independent Directors.
The details of familiarisation program may be accessed on the Company's website http://srusteels.in/pdfs/investor-policies/ Familirisation %20 Programme % 20for %20Indepdent%20 Directors.pdf
32. Buy Back of Securities
Your Company has not bought back its securities during the year under review.
33. Sweat Equity, Bonus Shares or Employee Stock Option
Your Company has neither issued any Sweat Equity shares nor Bonus Shares nor any Stock Option Scheme during the year under review.
34. Secretarial Standards
The applicable Secretarial Standards, i.e. SS-1 and SS-2, relating to 'Meetings of the Board of Directors' and 'General Meetings', respectively, have been duly followed by the Company.
35. Investor Services
To improve investor services, your Company has taken the following initiatives:-
• An Investor Relation Section on the website of the Company (www.srusteels.in) has been created to help investors to know the policies and rights of investors.
• There is a dedicated e-mail id srusteels@yahoo.in for sending communications to the Company Secretary. Members may lodge their requests, complaints and suggestions on this e-mail as well.
36. Following policies are also adopted by the board and are linked with the website of company at www.srusteels.in
1. Archival Policy on Preservation of Documents of the Company. URL for the same is: http://srusteels.in/pdfs/investor-policies/ Website%20Archival%20Policy.pdf
2. Policy on determination of materiality of the events/ information for making disclosure by the Company. URL for the same is: http://srusteels.in/pdfs/investor-policies/POLICY%20ON%20 DETERMINATION%20OF%20MATERIALITY%20OF%20 EVENTS%20FOR%20MAKING%20DISCLOSURE.pdf
3. Policy on Preservation of Records. The same may be accessed at http://srusteels.in/pdfs/investor-policies/Preservation%20of% 20Documents.pdf
4. Policy on Code of Conduct for the Board of Director and Senior Management Personnel can be assessed at http://srusteels.in/ pdfs/investor-policies/Code%20of%20Conduct%20%20Board% 20%20&&%20Senior%20Management.pdf
5. Policy on Related Party Transaction. The same may be accessed at: http://www.srusteels.in/pdfs/investor-policies/Policy-on- Related-Party-Transactions 2022.pdf
6. Policy on performance Evaluation and URL for the same is: http:// srusteels.in/pdfs/investorpolicies/Performance%20Evaluation %20Policy.pdf
37. Application/proceeding under the Insolvency and Bankruptcy Code, 2016
During the year, the Company has not made any application under the Insolvency and Bankruptcy Code, 2016 (IBC) and there is no proceeding pending under IBC.
38. One-time settlement with any bank or Financial Institution
There was no instance of one-time settlement with any Bank or Financial Institution.
Acknowledgements
Your Directors place on record their appreciation for the assistance, help and guidance provided to the Company by the Bankers and Authorities of State Government and Central Government from time to time. Your Directors also wish to place on record their sincere thanks and appreciation for the continuing support and unstinting efforts of investors, vendors, dealers, business associates and employees in ensuring an excellent all around operational performance.