To,
THE MEMBERS
Your Directors have pleasure in submitting their 30th Annual Report of the
Company together with the Audited Statements of Accounts of the Company for the year ended
on March 31, 2023.
1. FINANCIAL RESULTS:
During the year under review, the Company has Total achieved Comprehensive income of
Rs.2011.20 lakhs. However, your Directors look forward to improve the financial position
of the Company and are optimistic about the future growth and performance of the Company.
The summarized financial results of the Company for the period ended March 31,2023 are
as follows:
|
|
(Rs. In Lakhs) |
| Particulars |
2022-23 |
2021-22 |
| Revenue from Operation |
36,663.86 |
34,372.38 |
| Other Income |
566.53 |
503.97 |
| Total Income |
37,230.39 |
34,876.35 |
| Less: Expenditure |
33,166.47 |
33,128.46 |
| Profit/(loss)before Interest, Depreciation, Tax |
4,063.92 |
1,908.17 |
| Less: Interest |
408.98 |
561.10 |
| Less: Depreciation & Amortization Cost |
792.78 |
726.28 |
| Less: Extraordinary items |
- |
- |
| Profit/(loss)Before Tax |
2,862.16 |
460.51 |
| Less: Tax Expenses |
849.77 |
160.27 |
| Profit/(loss)after Tax |
2,012.39 |
300.24 |
| Other Comprehensive Income |
(1.67) |
2.32 |
| Income Tax Relating to above Item |
0.48 |
(0.90) |
| Total Comprehensive Income for the period |
2,011.20 |
302.56 |
2. OPERATIONAL HIGHLIGHTS:
The Gross Revenue from the business during the current year is Rs.36,663.86 lakh as
against Rs.34,372.38 lakh in the previous year. The total revenue during the current year
are Rs.37,230.39 lakh as against Rs.34,876.35 lakh.
3. CHNAGES IN NATURE OF BUSINESS
There is no significant change made in the nature of the company during the financial
year.
4. TRANFER TO INVESTOR EDUCATION & PROTECTION FUND:
Pursuant to the provisions of Section 124 of the Companies Act, 2013 and the Investor
Education and Protection Fund Authority (Accounting, Audit, Transfer and Refund) Rules,
2016 ('IEPF Rules, 2016'), the amount of dividend remaining unclaimed/ unpaid for a period
of seven years from the date of transfer to the "Unpaid Dividend Account" is
required to be transferred to the Investors Education and Protection Fund (Fund)
constituted by the Central Government. The Company had, accordingly, transferred
Rs.1,38,867/- Lakhs being the unpaid and unclaimed dividend amount pertaining to dividend
declared on 2014-15 to the IEPF.
5. TRANSFER TO RESERVES IN TERMS OF SECTION 134 (3) (J) OF THE COMPANIES ACT, 2013
For the financial year ended March 31,2023, the Company had not transferred any sum to
General Reserve Account. Therefore, your Company remained the balance of profit/loss to
Profit and Loss Accounts of the Company to Surplus Account.
6. MANAGEMENT DISCUSSION AND ANALYSIS REPORT:
As required under Regulation 34 of the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015, the Management Discussion and Analysis Report is enclosed
as per "Annexure-A".
7. RETURN OF SURPLUS FUNDS TO SHAREHOLDERS:
The Company bought back 9,00,000 fully paid-up Equity Shares of the Company, each
having a face value of Rs.10/- ("Equity Shares"), representing 4.67% of the
total number of Equity Shares in the paid-up share capital of the Company, at a price of
Rs.77/- per Equity Share paid in cash for an aggregate amount of Rs.6,93,00,000/-
("Buyback Size"), being 7.80% of the aggregate of the fully paid-up Equity Share
capital and free reserves of the Company as per the audited financial statements of the
Company as at March 31,2022. The settlement of bids and payment of buyback consideration
was made on October 07, 2022 and the shares were extinguished on October 14, 2022.
8. MATERIAL CHANGES AND COMMITTMENT AFFECTING FINANCIAL POSITION OF THE COMPANY:
There are no material changes and commitments, affecting the financial position of your
company which has occurred between the end of financial year of the company i.e. March
31,2023 and the date of Director's Report except that the company has buy back its shares
as mentioned in point 7 above.
9. QUALITY INITIATIVE:
The Company continues to sustain its commitment to the highest levels of quality,
superior services management and mature business continuity management.
10. DIVIDEND:
The Board of Directors of your company, after considering holistically the relevant
circumstances, has decided that it would be prudent, not to recommend any Dividend for the
year under review.
11. PERFORMANCE AND FINANCIAL POSITION OF EACH SUBSIDIARIES, ASSOCIATES AND JOINT
VENTURE COMPANIES:
Your company does not have any subsidiary company, associate company or joint venture
company. During the year, no company became or ceased to be subsidiary, joint venture or
associates of your company.
12. SHARE CAPITAL:
The paid up Equity Share Capital of the Company as on March 31, 2023 was Rs.1836.41
Lakhs divided into 18364100 Equity Shares of Rs.10.00/- each. The paid up equity share
capital of the company decrease from 19264100 to 18364100 Equity Shares during the year
due to bought back of 9,00,000 fully paid-up Equity Shares of the Company.
13. BORROWINGS:
The Company has outstanding borrowings as on March 31, 2023:
| Particulars |
Amount (Rs. in lakhs) |
| Secured |
|
| Form Banks (CC, TL, LC & other) Bankers: |
2,008.66 |
| Unsecured |
|
| From Suraj Impex LLP |
1,57.56 |
| Total |
2,166.22 |
14. CORPORATE GOVERNANCE AND SHAREHOLDERS INFORMATION:
Your company provides utmost importance at best Governance Practices and are designated
to act in the best interest of its stakeholders. Better governance practice enables the
company to introduce more effective internal controls suitable to the changing nature of
business operations, improve performance and also provide an opportunity to increase
stakeholders understanding of the key activities and policies of the organization.
Your Company has incorporated the appropriate standards for corporate governance.
Pursuant to Regulation 15(2) of SEBI (Listing Obligations and Disclosure Requirements)
Regulations, 2015. Separate reports on Corporate Governance Report as required by
Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements)
Regulations, 2015 ["SEBI (LODR), 2015"] forms part of this Annual Report.
Details regarding Corporate Governance Report of the Company regarding Compliance of the
Conditions of Corporate Governance pursuant to SEBI (Listing Obligations and Disclosure
Requirements)Regulations, 2015 are annexed herewith as "Annexure-B".
A certificate from M/s Murtuza Mandorwala & Associates, Practicing Company
Secretary, Ahmedabad confirming compliance to the conditions of Corporate Governance as
stipulated under SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015,
is annexed to Corporate Governance Report.
15. CFO CERTIFICATION:
In terms of Regulation 17(8) of the Listing Regulations, the CFO has certified to the
Board of Directors of the Company with regard to the financial statements and other
matters specified in the said regulation for the financial year 2022-23. The certificate
received from CFO is attached herewith as per "Annexure - C".
16. LISTING WITH STOCK EXCHANGES:
The Company confirms that it has paid the Annual Listing Fees for the year 2023-2024 to
BSE where the Company's Shares are listed.
17. DEMATERIALISATION OF SHARES:
99.81% of the company's paid up Equity Share Capital is in dematerialized form as on
March 31, 2023 and balance 0.18 % is in physical form. The Company's Registrars are M/s
MCS share transfer agent Limited, having their office at, 201, Shatdal Complex, 2nd
floor, Opp. Bata Show room, Ashram Road, Ahmedabad, Gujarat - 380009.
18. MEETING OF BOARD OF DIRECTORS AND COMPLIANCE TO SECRETARIAL STANDARD:
I. NUMBER OF BOARD MEETINGS HELD:
The Board of Directors of the Company met Four (4) times during the year. The
intervening gap between the meetings was within the period prescribed under the Companies
Act, 2013
The details of board meetings and the attendance of the Directors are provided in the
Corporate Governance Report which forms part of this Report.
The Company has complied with the provisions of Secretarial Standard 1 (relating to
meetings of the Board of Directors) and Secretarial Standard 2 (relating to General
Meetings) during the year.
II. BOARD COMMITTEES:
The company has 4 (Four) Board Committees as on March 31, 2022.
1. Audit Committee
2. Nomination and Remuneration Committee
3. Stakeholders Relationship Committee
4. Corporate Social Responsibility Committee
The composition of each of the above Committees, their respective roles and
responsibilities are provided in detail in the Corporate Governance Report. The details of
all the committees along with their main terms, composition and meetings held during the
year under review are provided in the Report on Corporate Governance, a part of this
Annual Report.
19. GENERAL MEETING:
During the Year Under review 29th Annual General Meeting for the Financial
Year 2021-22 was held on Tuesday, June 14, 2022.
20. DIRECTORS RESPONSIBILITY STATEMENT:
Pursuant to Section 134(5) of the Companies Act, 2013, Directors of your Company hereby
state and confirm that:
a) In the preparation of the annual accounts for the year ended March 31, 2023, the
applicable accounting standards have been followed along with proper explanation relating
to material departures;
b) They 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
of the company for the same 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) They have prepared the annual accounts on a going concern basis;
e) They have laid down internal financial controls with reference to financial
statements in the company were operating effectively.
f) They have devised proper systems to ensure compliance with the provisions of all
applicable laws and these are adequate and are operating effectively.
21. AUDIT OBSERVATIONS:
There are no qualifications, reservations or adverse remarks made by M/s. Rinkesh Shah
& Co., Chartered Accountants, the Statutory Auditors of the Company, in their report.
The observations made by the Statutory Auditors in their report for the financial period
ended March 31, 2023 read with the explanatory notes therein are self explanatory and
therefore, do not call for any further explanation or comments from the Board under
Section 134(3) of the Companies Act, 2013.
AUDITORS:
i) Statutory Auditors:
M/s. Rinkesh Shah & Co., Chartered Accountants completed their first term as the
Statutory Auditors of the Company. In accordance with Section 139(2) of the Act and the
transitional provisions provided under the Companies (Audit and Auditors) Rules, 2014, M/s
Rinkesh Shah & Co., are eligible for re-appointment for another term of 5 years.
M/s. Rinkesh Shah & Co., Chartered Accountants, was appointed as Statutory Auditors
for a period of 5 year(s) in the 29th Annual General Meeting held on May 03,
2022 to hold the office till the conclusion of 34th Annual General Meeting of
the Company to be held in the year 2027. Pursuant to the provisions of Section 139 of the
Companies Act, 2013 read with the Companies (Audit and Auditors) Rules, 2014,
The consent of M/s. Rinkesh Shah & Co., Chartered Accountants, Ahmedabad along with
certificate under Section 139 of the Act has been obtained to the effect that their
appointment, if made, shall be in accordance with the prescribed conditions and that they
are eligible to hold the office of Auditors of the Company.
ii) Cost Auditors:
M/s. Kiran J. Mehta & Co., Cost Accountants (FRN: 000025) appointed by the Board of
Directors of the Company, to conduct the audit of the Cost records of the Company for the
financial year 2023-24 be paid at such remuneration as shall be fixed by the Board of
Directors of the Company.
iii) Secretarial Audit:
As per the provisions of Section 204 read with Section 134(3) of the Companies Act,
2013, our Company needs to obtain Secretarial Audit Report from Practicing Company
Secretary and therefore, M/s Murtuza Mandorwala & Associates, Practicing Company
Secretary, Ahmedabad had been appointed to issue Secretarial Audit Report for the period
ended on March 31, 2023.
Secretarial Audit Report issued by M/s Murtuza Mandorwala & Associates, Practicing
Company Secretary in Form MR-3, attached and marked as "Annexure D", for
the period under review forms part of this report. Further, the Secretarial Audit Report
does not contain any qualification, reservation, adverse remark or disclaimer except the
following remark:
Secretarial Auditor Remark 1
Company has delayed in submission of disclosure of related party transactions to Stock
exchange as per Regulation 23(9) of The Securities and Exchange Board of India (Listing
Obligations and Disclosures and Requirement) Regulation 2015.
Reply-Company has paid the Fine Amount as levied by BSE and had complied with the
Regulation 23(9) of The Securities and Exchange Board of India (Listing Obligations and
Disclosures and Requirement) Regulation 2015.
Secretarial Auditor Remark 2
During the year under review company has transferred 9, 200 Equity shares to IEPF
Account but failed to send physical notice to shareholder at the latest available address
in compliance with Rule 6(3)(a)The Investor Education and Protection Fund Authority
(Accounting, Audit, Transfer and Refund) Rules, 2016.
Reply - Management will take care to comply with from now for Rule 6(3)(a) The Investor
Education and Protection Fund Authority (Accounting, Audit, Transfer and Refund) Rules,
2016.
In terms of Regulation 24(A)(2) of SEBI (LODR) Regulations, 2015, the Secretarial
Compliance Report for the financial year ended March 31,2023 has been submitted to the
Stock Exchanges by the Company. The said Secretarial Compliance Report may be accessed
from the website of the Company at https://www.surajgroup.com/investor_relations#b3-new.
22. CORPORATE SOCIAL RESPONSIBILITY (CSR):
In terms of section 135 and Schedule VII of the Companies Act, 2013, the Board of
Directors of your Company has constituted a CSR Committee. The Committee comprises with
two Independent Directors one Whole Time Director and one is executive director (Chairman
& CFO). The CSR Policy may be accessed on the Company's website at the web link:
https://www.surajgroup.com/ pdfs/Policy/csr_policy.pdf
23. VIGIL MECHANISM:
In pursuant to the provisions of section 177(9) & (10) of the Companies Act, 2013,
a Vigil Mechanism for directors and employees to report genuine concerns has been
established.
24. RISK MANAGEMENT:
The Company has formulated the Risk Management Policy which indicates Company's
standards for risk taking while conducting business and to provide an easy-to-access guide
any time you have a question. The Risk Management Committee will currently cover Market
Risk, Credit Risk, Process Risk and other risks as detailed in these documents. Each risk
is covered within this Policy. This Policy will apply across all products, throughout the
firm.
25. PARTICULARS OF CONTRACTS OR ARRANGEMENTS MADE WITH RELATED PARTIES:
All contracts/transactions entered into by the Company during the financial year with
related parties were in the ordinary course of business and on an arm's length basis.
No material Related Party Transactions, i.e. transactions exceeding ten percent of the
annual consolidated turnover as per the last audited financial statements, were entered
during the year by your Company. Accordingly, the disclosure of Related Party Transactions
as required under Section 134 (3) (h) of the Act in Form AOC-2 is not applicable. All
Related Party Transactions are placed before the Audit Committee for review and approval.
Prior omnibus approval is obtained for Related Party Transactions for transactions which
are of repetitive nature and entered in the ordinary course of business and are at arm's
length.
All Related Party Transactions are subjected to independent review by a reputed
accounting firm to establish compliance with the requirements of Related Party
Transactions under the Act and SEBI LODR Regulations. Your Company has formulated a Policy
on Related Party Transactions which is also available on Company's website
https://www.surajgroup.com/pdfs/Policy/Policy-for- Related-Party-Transaction.pdf
26. DIRECTORS & KEY MANAGERIAL PERSONNEL:
The Board of the Company comprises of Eight (08) directors; one Executive Chairman, one
Managing Director, two Whole-time Directors and remaining four being Independent
Directors. As on the date of this report, the Board of the company constitutes of the
following directors:
| Name of Directors |
DIN/PAN |
Designation |
| Mr. Ashok Tarachand Shah |
00254255 |
Chairman & CFO |
| Mr. Kunal Tarachand Shah |
00254205 |
Managing Director |
| Mr. Gunvantkumar Tarachand Shah |
00254292 |
Whole Time Director |
| Ms. Shilpa Mangaldas Patel |
07014883 |
Whole Time Director |
| Mr. Ketan Ratilal Shah |
00583064 |
Non-Executive Independent Director |
| Mr. Dipakbhai Himatbhai Shah |
00565892 |
Non-Executive Independent Director |
| Mr. Anil Kanwal Gidwani |
09019265 |
Non-Executive Independent Director |
| Mr. Rajesh Chimanlal Kharadi |
09019293 |
Non-Executive Independent Director |
| Mr. Maunishkumar Sanatkumar Gandhi |
APRPG2323J |
Company Secretary & Compliance Officer |
The brief resume of the Directors and other related information has been detailed in
Corporate Governance Report of Company.
The Company has received declarations from their Directors that none of them is
disqualified u/s 164 (2).
I. Retirement by Rotation:
Apart from this, there is no change in the Directors and key managerial personnel of
the company.
In accordance with the provisions of section 152[6] of the Act and in terms of Articles
of Association of the Company, Mr. Ashok Shah (DIN:00254255) and Mr. Gunvant Shah
(DIN:00254292) being liable to retire by rotation, shall retire at the ensuing Annual
General Meeting and being eligible, offer himself for reappointment. The Board recommends
his reappointment.
ii. Board Evaluation:
The board of directors has carried out an evaluation of its own performance, Board
Committees and individual directors, pursuant to the provisions of Companies Act and
Listing Regulations.
The manner in which the evaluation has been carried out has been explained in the
Corporate Governance Report.
III. Nomination and Remuneration Policy:
The policy on nomination and remuneration of Directors, Key Managerial Personnel and
other employees has been formulated in terms of the provision of The Companies act, 2013
and SEBI (LODR) Regulation, 2015 in order to pay equitable remuneration to the Directors,
Key Managerial Personnel and employees of the Company and to harmonise the aspiration of
human resources consistent with the goals of the Company.
The Remuneration Policy has been updated on the website of the Company at: https://
www.surajgroup.com/pdfs/Policy/Nomination_and_remuneration_policy.pdf.
IV. Certificate of Practicing Company Secretary:
The Company has obtained a certificate from M/s. Murtuza Mandorwala & Associates,
Practicing Company Secretary, Ahmedabad stating that none of the Directors on the Board of
the Company have been debarred/ disqualified from being appointed / continuing as
Directors of any company, by the SEBI and Ministry of Corporate Affairs or any such
Statutory authority, under "Annexure- E".
V. Remuneration Ratio of the Directors/Key Managerial Personnel (KMP)/Employees:
The information required pursuant to Section 197 read with Rule 5 of The Companies
(Appointment and Remuneration of Managerial Personnel) Rules, 2014 and Companies
(Particulars of Employees) Rules, 1975, in respect of employees of the Company and
Directors is furnished hereunder:
| Sr. No. |
Name |
Designation |
Remuneration paid F.Y. 2022-23 'in
Lakh |
Remuneration paid F.Y. 2021-22 'in
Lakh |
Increase in remuneration from
previous year 'in Lakh |
| 1 |
Mr. Ashok Shah |
Chairman & CFO (ED) |
70.80 |
58.20 |
12.60 |
| 2 |
Mr. Gunvant Shah |
Whole time Director |
51.00 |
43.20 |
7.80 |
| 3 |
Mr. Kunal Shah |
Managing Director |
60.00 |
51.00 |
9.00 |
| 4 |
Ms. Shilpa Patel |
Whole time Director |
18.12 |
15.18 |
2.94 |
| 5 |
Mr. Maunish Gandhi |
Company Secretary |
6.47 |
5.85 |
0.62 |
27. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION, FOREIGN EXCHANGE EARNINGS AND OUTGO:
Information required under section 134(3)(m) of the Companies Act, 2013 read with Rule
8 of the Companies (Accounts) Rules, 2014, is given in the "Annexure-F" to
this report.
The Company has commissioned wind mills at various sites in Gujarat for "Green
Energy Generation", thus continuing to contribute, in a small way, towards a greener
and cleaner earth.
28. DECLARATION BY INDEPENDENT DIRECTORS:
The company has received necessary declaration from the Independent Directors as
required under Section 149(7) of the Companies Act and LODR Regulations confirming that
they meet the criteria of independence as laid down in Section 149(6) of the Act and that
of LODR Regulations. Independent Directors are in compliance with the Code of Conduct
prescribed under Schedule IV of the Companies Act, 2013.In the opinion of Board, the
Independent Directors of the company possess the integrity, requisite experience and
expertise, relevant for the industry in which the company operates. Further, all the
Independent Directors of the Company have successfully registered with the Independent
Director's Databank of the Indian Institute of Corporate Affairs. The online proficiency
self assessment test conduct by the said institute have been cleared by all the
independent directors.
29. BUSINESS RESPONSIBILITY REPORT:
As stipulated under the SEBI (Listing Obligations and Disclosure Requirements)
Regulations, 2015, the Business Responsibility Report describing the initiatives taken by
the Company from an environmental, social and governance perspective is not applicable to
your company as per the exemptions provided under SEBI (Listing Obligations and Disclosure
Requirements)Regulations, 2015.
30. PREVENTION OF SEXUAL HARASSMENT OF WOMEN AT WORK PLACE:
Your Company has in place a formal policy for the prevention of sexual harassment of
its women employees in line with "The Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Act, 2013". The Company has formed Internal
Complaint Committee who periodically conducts sessions for employees across the
organization to build awareness about the Policy and the provisions of Prevention of
Sexual Harassment Act.
31. ANNUAL RETURN:
The Annual Return in Form No. MGT-7 of the Company can be accessed from the website of
the Company at https://www.surajgroup.com/investor_relations.
32. PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS MADE UNDER SECTION 186 OF THE
COMPANIES ACT, 2013:
During the year under review company has not granted any Loans, given Guarantees or
invested any amount which are covered under the provisions of Section 186 of the Companies
Act, 2013.
33. DEVELOPMENT AND IMPLEMENTATION OF A RISK MANAGEMENT POLICY:
The Company has been addressing various risks impacting the Company and the policy of
the Company on risk management is provided below:
| Key Risk |
Impact to Suraj Ltd |
Mitigation Plans |
| Foreign Exchange Risk |
Company exports all the products to various countries. Any
volatility in the currency market can impact the overall profitability. |
The Company commands excellent business relationship with
the buyers. In case of major fluctuation either upwards or downwards, the matter will be
mutually discussed and compensated both ways. |
| Human Resource Risk |
Company's ability to deliver value is dependent on its
ability to attract, retain and nurture talent. Nonavailability of the required talent
resource can affect the overall performance of the Company. |
By continuously benchmarking of the best HR practices
across the industry and carrying out necessary improvements to attract and retain the best
talent. By putting in place production incentives on time bound basis and evaluating the
performance at each stage of work helps to mitigate this risk. |
| Competition Risk |
Company is always exposed to competition Risk from various
Countries. The increase in competition can create pressure on margins, market share etc. |
By continuous efforts to enhance the brand image of the
Company by focusing on quality, Cost, timely delivery and customer service to mitigate the
risks so involved. |
| Compliance Risk - Increasing regulatory requirements |
Any default can attract penal provisions. |
By regularly monitoring and review of changes in
regulatory framework and by monitoring of compliance through legal compliance Management
tools and regular internal audit. |
| Industrial Safety |
The industry is labour intensive and are exposed to
accidents, health and injury risk due to machinery breakdown, human negligence etc. |
By development and implementation of critical safety
standards across the various departments of the factory, establishing training need
identification at each level of employee helps to mitigate the risk so involved. |
34. SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS:
There are no significant and material orders passed by the Regulators/Courts which
would impact the going concern status of the Company and its future operations.
35. DEPOSIT:
In terms of the provision of Sections 73 and 74 of the Companies Act, 2013 read with
the relevant rules, your Company has not accepted any fixed deposits during the year under
review
36. DISCLOSURE ABOUT COST AUDIT & COST RECORD:
As per the Cost Audit Orders, Cost Audit & Record is applicable to the Company for
F.Y. 2022-23 and company has filed required form CRA 2 & CRA 4 within the prescribed
time limit.
In view of the same and in terms of the provisions of Section 148 and all other
applicable provisions of the Companies Act, 2013, read with the Companies (Audit and
Auditors) Rules, 2014, M/s. M/s Kiran J. Mehta & Co., Cost Accountants have been
appointed as Cost Auditors to conduct the audit of cost records of your company for the
financial year 2023-24. The remuneration proposed to be paid to them requires ratification
of the shareholders of the Company. In view of this, your ratification for payment of
remuneration to Cost Auditors is being sought at the ensuing AGM.
37. COMPLIANCE OF SEBI (PROHIBITION OF INSIDER TRADING) REGULATIONS, 2015 ("PIT
REGULATIONS") AND CODE OF FAIR PRACTICES AND DISCLOSURE (FAIR DISCLOSURE CODE):
The Company has formulated Code of Conduct for Prevention of Insider Trading in SURAJ
LIMITED Securities ("PIT Code") and Fair Disclosure Code in accordance with PIT
Regulations with an objective of protecting the interest of Shareholders at large and
preventing misuse of any Unpublished Price Sensitive Information (UPSI). The PIT Code and
Fair Disclosure Codes are available on the website of the Company on
https://www.surajgroup.com/pdfs/Policy/Revised-Code-
PIT-Fair-Disclosure-of-UPSI-wef-01.04.2019.pdf.
38. ACKNOWLEDGEMENT:
Directors take this opportunity to express their thanks to various departments of the
Central and State Government, Bankers, Material Suppliers, Customers and Shareholders for
their continued support and guidance. The Directors wish to place on record their
appreciation for the dedicated efforts put in by the Employees of the Company at all
levels.
| Date: May 04, 2023 |
By the order of the Board |
| Place: Ahmedabad |
SURAJ LIMITED |
| Registered Office: |
|
| 'Suraj House', |
ASHOK SHAH |
| Opp. Usmanpura Garden, |
Chairman & CFO |
| Ashram Road, Ahmedabad-380014 |
(DIN:00254255) |
| CIN NO: L27100GJ1994PLC021088 |
|
|