The Board of Directors presenring the Annual report of the business and operations of your Company (‘‘M P K
STEELS (I) LIMITED”), along with the audited financial statements, for the financial year ended March 31,
2025.

FINANCIAL HIGHLIGHTS:

The financial performance of your company for the year ending March 31, 2025 is summarized below:

(Amounts in Lakhs.)

TRANSFER TO RESERVES:

During rhc vcar under review, Company has not transferred anv amount to the reserves.

DIVIDEND:

The Company has not recommended any dividend in view of conservation of profits earned during the year.

TRANSFER OF UNCLAIMED DIVIDEND TO INVESTOR EDUCATION & PROTECTION FEND:

The Company has no amount due to he transferred to Investor Education and Protection Fund during the year
under review.

STATE OF COMPANY AFFAIRS:

During the year, the financial performance of the companv has improved as reflected in irs profits and loss
accounts, and highlights of the companies' performances for the financial year 2024-25 as compared to previous
year 2023-24 are given below: -

4- Total revenue is increased from Rs. 18,660.54 Lacs to Rs. 20,658.2(1 Lacs.

4- Profit before Tax is increased from Rs. 830.90 Lacs to Rs. 440.99 Lacs.

4- Net Profit after Tax is increased from Rs. 573.58 Lacs to Rs. 385.23 Lacs.

During the year under review, there has been no change in the nature of business activity of the Companv.

CAPITAL STRUCTURE OF THLl COMPANY:

The Current Capital Structure of the Company is given below: -

Authorized Capital: -

As on Financial Year ended, the Authorized Share Capital of rhc company is Rs. 10,00,00,000/- (Rupees I’en Crore)
divided into 1,00,00,000/- Equity Shares of Rs.10/- each.

The Company has increased irs Authorized Share Capital from Rs. 3,50,00,000/- (Rupees Three Crore Fifty Lakhs
Only) divided into 35,00,000 (Thirty-Five Lakh) equity shares of Rs.10/- (Rupees Ten) each to Rs. 10,00,00,000/-
(Rupees Ten Crore Only) divided into 1,00,00,000 (One Crore) Equity shares of Rs.10/- (Rupees Ten) each by
creation of 65,00,000 (Sixty-Five Lakh) equity shares of Rs. 10/- (Rupees Ten) each in the Extra Ordinary General
Meeting held on 10.01.2025.

Issued Capital, Subscribed & Paid-up Capital: -

During the Financial Year ended, the Issued, Subscribed & Paid-up Share Capital of the Company is Rs.
6,92,33,580/- (Rupees Six Crore Ninety-Two T.nkh Thirrv-Three Thousand Five Hundred Eighty) divided into
69,23,358 (Sixty-Nine Lakh Twenty-Three Thousand Three Hundred Fifty-Eight) Equity shares of Rs.10/- (Rupees
Ten) each.

The Company has increased its Issued Capital, Subscribed & Paid-up from Rs. 3,46,16,790/- (Rupees Three Crore
Forty-Six Lakh Sixteen Thousand Seven Hundred Ninety Onlv) divided into 34,61,679 (Thirty-Pour Lakh Sixry-
One Thousand Six Hundred Seventy-Nine) equity shares of Rs.10/- (Rupees Ten) each to Rs. 6,92,33,580/-
(Rupccs Six Crore Ninety Two Lakh Thirty Three Thousand Five Hundred l lighty) divided into 69,23,358 (Sixty
Nine Lakh Twenty Three Thousand Three I kindred Fifty Right) Kcjuiry shares of Rs.10/- (Rupees Ten) each by
creation of 3,46,16,790/- (Rupees Three Crore Forty Six Lakh Sixteen Thousand Seven Hundred Ninety Only)
divided into 34,61,679 (Thirty Pour Lakh Sixty One Thousand Six 1 kindred Seventy Nine) equity shares of Rs.10/-
(Rupees Ten) each through Bonus issue by passing the Ordinary resolution in the extra- ordinary General meeting
held on March 24, 2025.

D E MATE RI AT .1X AT IO N OF SHARES & LIQUIDITY

As on March 31, 2025, no shares of the Company were held in physical form. The entire shareholding of the
Promoters and Promoter Group was fully dematerialized. Accordingly, the aggregate dematerialized shareholding of
the Company stood at 100%.

EXTRACT OF ANNUAL RETURN

As per rhe provisions of the Companies (Amendment) Act, 2017 notified by the Ministry of Corporate Affairs on
31st July, 2018 read with notification dated 20th August, 2020 amending the provisions of section I34(3)(a) and
section 92(3) of the Companies Act, 2013 respectively, further read with the Companies (Management and
Administration) Amendment Rules, 2021 substituting rhe Rule 12(1) of the Companies (Management and
Administration) Rules, 2014, the requirement for preparing an extract of annual return ro be made part of Board’s
Report has been omitted. Accordingly, the extract of annual return in form MGT-9 is not required to he annexed to
Board’s Report.

WEB ADDRESS OF ANNUAL RETURN

As per section 92(3) and 134 (3) of the Companies Act, 2013, Companies arc required to place the Annual Return
of the company on its website. Since your company have its own website, the Annual Return has been uploaded
and is available on the website. The website link is provided below: https://www.mpksteels.com/annual-
report.php

NUMBER OF MEETINGS OF BOARD OF DIRECTORS:

During rhe period under review, die Company held Twenty-Two Board meetings of the Board of Directors as per
Section 173 of Companies Act, 2013 which is summarized below. The provisions of Companies Act, 2013 were
adhered ro while considering the time gap between two meetings.

A Attended in Person/through video conference.

A Mr. Mangal Morwal was appointed as director as on dated 25.11.2024 and regularized on 05.03.2025.

A Ms. Nidhi Upadhvay was appointed as director as on dated 12.11.2024.

A Mr. (jyan Prakash Tongin was appointed as director as on dated 12.11.2024.

Notes:

None o f the directors hold directorships in won than 20 companies of which directorships in public companies does not exceed 10 in line
with the provisions of Section 165 of the Act.

DIRECTORS RESPONSIBILITY STATEMENT:

To the best of our knowledge and belief and according to the information and explanations obtained bv us, your
Directors make the following statements in terms of Section 134(3)(c) anti 134(5) of the Companies Act, 2013:

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

(b) They have selecred such accounting policies and applied them consistently and made judgments and
estimates that are reasonable anti prudent so as to give a true and fair view of the state ot affairs of the
company ar the end of the financial rear and of the profit/loss of the company for that period;

(c) They have taken proper and sufficient care for the maintenance ot adequate accounting records in
accordance with the provisions of this Act for safeguarding the assets of rhe company anti for preventing and
detec ting fraud and other irregularities;

(d) They have prepared the annual accounts on a going concern basis.

fe) feeing an unlisted company, sub clause (c) of section 134(3) is not applicable.

(f) They have devised proper systems to ensure compliance with the provisions ot all applicable laws and that
such systems were adequate and operating effectively.

AUDITOR’S OF I'HE COMPANY:

Statutory Auditors & Their Report:

M/S Saurabh Agarwal & Associates, Chartered Accountants (FRN: 321106E) bad reappointed as the
Staturorv Auditors of the company in rhe Annual General Meeting held on September 30, 2024 for a period of 5
rears commencing from the financial rear 2024-25 until the conclusion of the Annua) General Meeting for the
financial year 2028-29.

However, due to the requirement of Peer review Auditor’s firm as the appointment of statutory auditors of the
company, M/S Saurabh Agarwal & Associates, Chartered Accountants (FRN: 321106E) has resigned with
immediate effect on October 22, 2024 to provide their services as Statutory Auditors of the company.

So, the company has appointed M/s N L A & Associates, Chartered Accountants (FRN: 023199C), on
04.11.2024 as Statutory Auditor of the company for rite Financial Year 2024-25 in the casual vacancy

The Company has received consent letter from the auditor to the effect that appointment, if made, would be within
the prescribed limits under Section 141(3) (g) of the Companies Act, 2013 and that they arc not disqualified for
appointment

The Statutory Auditors of the Company have submitted Auditors’ Report on the financial statements of the
Company for the financial year ended 31” March. 2025. The reports do not contain any reservation, qualification or
adverse remark.

The Notes on Financial Statements referred to in the Auditors’ Report are self explanatory and do not call tor any
further comments.

Further the tenure of M/s N L A & Associates, Chartered Accountants (FRN: 023199C) as the Statutory
Auditors of the company comes to an end on 31” March 2025. So, the Board of Directors recommends the
reappointment of the M/s N L A & Associates, Chartered Accountants (FRN: 023199C) as the Statutory
Auditors of the company for the period of 5 years commencing from the conclusion of the ensuing Annual General
Meeting until the conclusion of the Annual General Meeting to be held in the year 2030. Their continuance of
appointment to be confirmed and approved at the ensuing Annual General Meeting.

The Auditors have confirmed their eligibility and willingness to accept the reappointment. The Reappointment of
Auditors is subject to the approval of shareholders at Annual General Meeting.

Cost Auditor

Pursuant to Section 148 of the Companies Act, 2013 read with The Companies (Cost Records and Audit)
Amendment Rules, 2(U4, M/s Goyal & C<>., Cost Accountants (Registration No. 005883) has appointed as Cost
Auditor of the company to conduct audit of cost records maintained by the company for the Financial Year 2024-
25.

The Cost Auditors of the Company have submitted their Report for the financial t ear ended 31st March, 2025. The
reports do not contain any reservation, qualification or adverse remark.

'ITic Notes on cost records referred to in their report arc self-explanatory and do not call tor any further comments.
Secretarial Audit & Report

During the year under review, the Secretarial Audit is not applicable on the company as it is not covered under the
provisions of Section 204 of the Companies Act, 2013 and The Companies (Appointment and Remuneration of
Managerial Personnel) Rules, 2014.

Internal Audit

During the year under review, the Internal Audit is not applicable on the company as it is not covered under the
provisions of Section 138 of the Companies Act, 2013 and The Companies (Accounts) Rules, 2014.

PARTICULARS OF EMPLOYEES

There were no employees employed bv the company falling within Section 10? read with Rule, 3 of the Companies
(Appointment and Remuneration of Managerial Personnel) Rules, 2014 hence relevant disclosures are not required.

REPORTING OF FRAUDS BY AUDITORS:

During the year under review, the Statutory Auditor has not reported any instances of frauds committed in the
Company bv its Officers or Employees under Section 143 (12) of the Companies Act, 2013.

INFORMATION ABOUT SUBSIDIARY/ TV/ ASSOCIATE COMPANY:

There arc no subsidiaries, associate companies and joint venture companies of the Company as on the date of the
closure of the financial year. Accordingly, the reporting on the performance and financial position of the
Subsidiaries, joint ventures & associate companies in the Board’s Report is not applicable.

PARTICULARS OF LOANS. GUARANTEES OR INVESTMENTS:

During the Financial Year 2024-25, the company lias not made any investment through not more than two layers of
investment companies and the particulars of Loan given, Guarantees given and Investments made and securities
provided along with the purpose for which the loan or guarantee, security provided to be utilized by the receipt arc
provided in the audited Financial statements of the Company read with noted on accounts forming part of the
financial statements.

DISCLOSURE IN REFERENCE OF SUB RULE 1 CLAUSE (Cl SUB CLAUSE IVI1U OF RULE 2 OF
COMPANIES ^ACCEPTANCE OF DEPOSITS) RULES 2014:

During the period under review, the company has accepted some unsecured loan from its directors which was not
covered under the definition of deposits and as per the aforesaid rule of the Companies Act, 2013, the required
declaration from the director duly received by the company that rhe amount given by them is not acquired by
borrowing or accepting loan or deposits from others.

RELATED PARTY TRANSACTIONS AND POLICY ON RELATED PARTY TRANSACTION:

All related party transactions that were entered into during the financial year were on an arm's length basis and were
in the ordinary course of business. There are no materially significant related party transactions made bv the
Company with Promoters, Directors, Kev Managerial Personnel or other designated persons which may have a
potential conflict with the interest ot the Company. Particular of Transactions with Related parties are stated in
Note 34 of notes on accounts forming part of the Financial Statements.

The policy lays down the framework for dealing with Related Party Transactions in a transparent and fair manner. A
copy of the policy is available on the Company’s website at: https://www.mpksteels.com/code-and-
policics.php.

APPOINTMENT OF' INDEPENDENT DIRECTORS IN THE BOARD AND DECLARATION
UNDER SECTION 149f6L

The Company has two (02) Independent Directors in compliance with the requirements of the Companies Act,
2013. The declarations have been received from both Independent Directors confirming that they meet the criteria
of independence as prescribed under Section 149(b) of the Companies Act, 2013. In the opinion of the Board, the

Independent Directors fulfill the conditions specified in the Act and the applicable Rules for their appointment, and
they arc independent of the management.

The details of the Independent Directors are as follows:

MEETINGS OF INDEPENDENT DIRECTORS

The Company’s Independent Directors meet at least once in every financial year without the presence of Executive
Directors or management personnel. Such meetings are conducted informally to enable Independent Directors to
discuss matters pertaining to the Company’s affairs and put forth their views to the I.ead Independent Director.

During the year under review, the independent directors met on 15.12.2024 inter alia, to discuss:

V Evaluation ot the performance of Non-independent Directors and the Board of Directors as a whole.

y Evaluation of the performance of the chairman of die Company, taking into account the views of the
Executive and Non- Executive directors.

y Evaluation of the quality, content and timeliness of flow of information between the management and the
board that is necessary for the board to effectively and reasonably perform its duties.

y Review the mechanism of safeguard the interests of all Stakeholders.

POLICY ON CODE FOR INDEPENDENT DIRECTORS AND POLICY ON FAMILIARIZATION
OF INDEPENDENT DIRECTORS

In accordance with the provisions of Section 149(B) read with Schedule IV and Section 179 of the Companies Act,
2013, the Companies (Meetings of Board and irs Powers) Rules, 2014, Regulation 25 of the SEIM (Listing
Obligations and Disclosure Requirements) Regulations, 2015, the SEBI (Prohibition of Insider Trading)
Regulations, 2015, and other applicable regulatory provisions, the Board of Directors has adopted the Code for
Independent Directors and the Policy on Familiarization of Independent Directors.

The Code for Independent Directors outlines the duties, roles, and responsibilities of Independent Directors, in
line with the principles of good corporate governance and the statutory framework. The Familiarization Policy
aims to provide Independent Directors with insights into the Company’s operations, business model, industry
context, and their specific roles and responsibilities to enable them to contribute effectively to the Board and
Committec proceedings.

The Code for Independent Directors is available on the Company’s website at:

https://www.mpkstecls.com/codc-and-policics.php

NOMINATION AND REMUNERATION COMMITTEE AND COMPANY’S POLICY ON
DIRECTOR’S APPOINTMENT AND REMUNERATION:

The Nomination and Remuneration Committee has been constituted as per provisions of Section 178 of
Companies Act, 2013, the rule framed there-under. The functions ol the Committee are as per the provisions of the
Companies Act, 2013 besides others which may he delegated to it by the Board, The Committees’ role is to
recommend the appointment, remuneration, etc. of Directors, Key Managerial Personnel and Senior Management
Staff, to fix the criteria for appointment of Directors, KMPs & senior management staff and also to evaluate the
performance.

1 he Nomination and Remuneration Policy is available on the Company’s website at:
https://wwvv.mpksrcels.com/code-and-policies.php.

The Committee has constituted by the Hoard of Directors in their meeting held on February 25, 2025. The
company is having Nomination and Remuneration Committee comprising of the following directors and there was
no Committee meeting held during the t ear:

COMPOSITION OF AUDIT COMMITTEE:

The Audit Committee has been constituted as per Section 177 of the Companies Act, 2013. The management is
responsible for the Company’s internal controls and the financial reporting process while the statutory auditors arc
responsible for conducting independent audits of the Company’s financial statements in accordance with the
generally accepted Auditing Practices and for issuing reports based on such audits. The Audit Committee has been
constituted to assist die Board in overseeing the quality- and integrity of the accounting, auditing and reporting
policies/practices of the Company and its compliance with the legal and regulatory requirements. The Committee,
accordingly, monitors various issues which include accounting and financial reporting process of the Company,
maintenance of adequate internal financial controls, audit of the Company's financial statements, the appointment,
independence and performance of the Auditor.

The Policy of Audit Committee is available on the Company’s website at: https://vvww.mpkstcels.com/codc-
and-policies.php

The Committee has constituted by the Board of Directors in their meeting held on February 25, 2025. The
Committee comprised of 3 members during the financial year. The detail of the composition of rite Audit
committee along with their meetings held/attended is as follows:

The meetings of rhe Audit Committee were duly held on 28.03.2025 during the financial year to discuss and
deliberate on the relevant matters.

COMPOSITION OF STAKEHOLDER RELATIONSHIP COMMITTEE:

The Stakeholders Relationship Committee (SRC) of the Company has been constituted in accordance with the
provisions of Section 178 of the Companies Act, 2013 and Regulation 20 of the SF.B1 (listing Obligations and
Disclosure Requirements) Regulations, 2015. The Committee is entrusted with the responsibility of resolving the
grievances of shareholders and other security holders of the Company anti ensuring the timely and efficient
handling of investor-related matters.

The Policy of Stakeholder Relationship Committee is available on the Company’s website at:
https://www.mpkstcels.com/codc-and-policies.php

The Committee has constituted by the Board of Directors in their meeting held on February 25, 2025. The
Committee comprises the following members:

INITIAL PUBLIC OFFERING COMMITTEE:

The IPO Committee shall meet as and when required to fulfill its responsibilities and shall periodically report its
actions and recommendations ro the Board of Directors. Its role includes engaging intermediaries, overseeing the
preparation and tiling of otter documents, determining capital structure changes, coordinating with regulatorv
authorities, deciding on IPO timing and pricing, executing necessary agreements, and taking all actions incidental to
the IPO process.

Our Company has constituted an Initial Public Offering Committee pursuant ro the provisions of rhe Companies
Act, 2013 which was approved by a Meeting of the Board of Directors held on February 25, 2025.

The Initial Public Offering Committee comprises the following Directors:

FINANCE COMMITTEE:

Our Company has constituted a Finance Committee pursuant to the provisions of the Companies Act, 2013 which
was approved by a Meeting of the Board of Directors held on February 25,2025

The Finance Committee comprises the following 3 (three) Directors:

Meeting's

The Finance Committee shall meet as and when required to discharge its responsibilities and shall report its
decisions and actions taken to the Board at regular intervals

Role of the Finance Committee is as follows

a) To borrow monies from banks, financial institutions, or other entities, w ithin the limits approved by the Board.

b) To invest the funds of the Company in accordance with the investment policies and approvals of the Board.

c) To grant loans, provide guarantees, or offer securities on behalf of the Company, in compliance with applicable
laws and internal policies.

MATERIAL CHANGES AND COMMITMENTS. IF ANY. CRITERIA SPECIFY:

During the year, the status of the company has converted from Private Limited to Public Company in the Extra
Ordinary General Meeting held on 12.11.2024. Further, the company has filed the Draft Rod Herring Prospectus
with BSE on 30.03.2025.

Apart from that, there have been no materia! changes and commitments affecting financial position of the
Company which have occurred between the end of rhe financial year and the date of this report.

ENERGY CONSERVATION. TECHNOLOGY ABSORPTION & FOREIGN EXCHANGE
EARNINGS AND OUTGO:

Information on conservation of Energy, Technology absorption, Foreign Exchange earnings and outgo required to
be disclosed under Section 134 of the Companies Act, 2013 rend with Companies (Accounts) Rules, 2014 are
provided hereunder:

BOARD OF DIRECTORS & KMP:

The board of directors of the company duly constituted during the year and there were changes in the constitution
of board during the year.

'Hie following persons were appointed to the positions of Directors and Key Managerial Personnel (KMP) during
the financial t ear 21)24—25:

Appointment of Independent Directors

Mr. Gyan Prakash Tongia (DIN: 02186651) has appointed as an Independent Director of the company for the
period of five consecutive year’s w.e.f. i2.11.2024.

Mr. Mangal Morwal (DIN: 10045669) has appointed as an Independent Director of the Company for the period of
five consecutive year’s w.e.f. 25.11.2024 and regularized on 05.03.2025.

Appointment of Director

Ms. Nidhi Upadhyay was appointed as Non-Executive Director of the Company w.e.f. 12.11.2024.

Appointment and Resignation of Company Secretary'

Ms. Radha Khandelwal is appointed as the Company Secretary (Key Managerial Personnel) of the company w.e.f.
01.03.2025. After the closure of the financial year, Ms. Radha Khandelwal resigned from the position of Company
Secretary w.e.f. 07.04.2025.

Subsequently, Ms. Priyanka Jain was appointed as the Company Secretary w.e.f. 01.05.2025.

Appointment of Chief Financial Officer and Change in Designation

Mr. Manoj Upadhyay was appointed as the Chief Financial Officer (Key Managerial Personnel) of the Company
w.e.f. 01.11.2024.

On the same date, Mr. Manoj Upadhyay’s designation was changed from Director to Managing Director.

Director Retiring by Rotation

In accordance with the provisions ot Section 152(6) of the Companies Act, 2013 and ihc Articles of Association of
the Company, Mr. Manoj Upadhyay will retire by rotation at the ensuing Annual General Meeting and being
eligible, has offered himself for re-appointment.

Present directors & KMP of the comnanv arc as follows:

DEPOSITS

During die year ended 31^M March, 2025, the Company has not accepted deposits from the public falling within the
ambit of Section 73 of the Companies Act, 2013 and the Rules framed there under and hence no amount on
account of principal or interest on public deposits was outstanding as on the date of the Balance Sheet.

CORPORATE SOCIAL RESPONSIBILITIES (CSRV

The company does not meet the criteria of Section 135 of Companies Act, 2013 read with the Companies
(Corporate Social Responsibility Police) Rules, 2014 during the period under review. So there is no requirement to
constitution of Corporate Social Responsibility Committee.

BOARD EVALUATION:

The board is not required to evaluate its own performance as well as performance of its committee and individual
Directors as per provisions of section 134 (3) (p) of the Companies Act, 201.3 as the provision of section 134(3)(p)
relating to board evaluation is not applicable on the company.

INTERNAL FINANCIAL CONTROL SYSTEMS AND THEIR ADEQUACY:

The Company has adequate system of internal control to safeguard and protect from loss, unauthorized use or
disposition of its assets. All the transactions sure propcrlv authorized, recorded and reported to the Management.
The Company is following all the applicable Accounting Standards for properly maintaining the books of accounts
and reporting financial statements.

VIGIL MECHANISM / WHISTLE BLOWER POLICY:

Pursuanr to the provisions of Section 177 of the Companies Act, 201.3 and Regulation 22 of the SERI (lasting
Obligations and Disclosure Requirements) Regulations, 2015, the Company has duly established a Vigil Mechanism
/ Whistle Blower Police to provide a secure anti confidential channel for directors and employees to report genuine
concerns related to unethical practices, actual or suspected fraud, or violation of the Company’s Code of Conduct.

The Vigil Mechanism ensures protection against victimization of emplovces and directors who avail of the
mechanism, and also allows for direct access to the Chairperson of the Audit Committee in exceptional cases. The
Audit Committee oversees the functioning of the Vigil Mechanism and reviews the status of anv complaints
received under the policy.

In line with this policy, the Chief Financial Officer (CEO) of the Company has been designated as the Vigilance
Officer, responsible for receiving and processing all whistle blower complaints. The Vigilance Officer shall evaluate
the concerns received and report any significant findings, including confirmed incidents of fraud or misconduct,
directly to the Managing Director for further action.

The Policy of Whistle Blower is available on the Company’s website at: https://www.mpkstecls.com/codc-
and-policies.php

BUSINESS RISK MANAGEMENT & POLICY

The Company has formulated and implemented a comprehensive Risk Management Policy that defines the risk
management framework, delineates roles and responsibilities, and identifies key risk areas, 'file policy is periodically
reviewed by the Risk Management Committee to ensure its continued relevance and effectiveness in addressing the
dynamic business environment.

Risks are defined as events, situations, or circumstances that may adversely affect the Company’s operations or
objectives. The Companv recognizes that risk management is a structured and proactive approach to managing
uncertainty and potential threats.

A formal and integrated risk management framework has been adopted to ensure that key risks are identified,
assessed, monitored, and mitigated in a consistent and coordinated manner across all functions of the organization..

'The Policy of Risk Management is available on the Company’s website at: https://www.mpksteels.com/code-
and-policies.php

POLICY ON CODE OF CONDUCT FOR DIRECTORS AND SENIOR MANAGEMENT

The Board of Directors has adopted a formal Code of Conduct for Directors and Senior Management. The Code
lays down the principles and standards of ethical conduct to be followed by Directors and Senior Management
personnel in the discharge of their duties. It ensures transparency, accountability, and good governance practices
within the Company.

The Code of Conduct has been made available on the Company’s website at https://www.mpkstecls.com/code-
and-policies.php,

All Directors and Senior Management personnel have affirmed compliance with the Code for the financial year
ended.

POLICY ON CODE OF PRACTICES AND PROCEDURES FOR FAIR DISCLOSURE OF
UNPUBLISHED PRICE SENSITIVE INFORMATION

In accordance with the provisions of Regulation 8 and other applicable provisions of the SKBI (Prohibition of
Insider Trading) Regulations, 2015, the Board of Directors has adopted a formal Policy on Code of Practices and
Procedures for hair Disclosure of Unpublished Price Sensitive Information.

The Policy lays down principles and practices to ensure fair, timely, and adequate disclosure of Unpublished Price
Sensitive Information (UPSI) to maintain uniformity and prevent the misuse of such information. It promotes
transparency, good governance, and adherence to regulatory compliance within the Companv.

The Policy has been made available on the Company’s website at https://www.mpksteels.com/code-and-
policies.php.

ADOPTION OF POLICY ON PRESERVATION AND ARCHIVAL OF DOCUMENTS

Pursuant to the provisions of Section 179 of the Companies Act, 2013, read with the Companies (Meetings of
Board and its Powers) Rules, 2014, and in accordance with Regulation 9 of the SF.BI (Listing Obligations and
Disclosure Requirements) Regulations, 2015, the Board of Directors has adopted a Policy on Preservation of
Documents and Archival of Documents.

The policy has been formulated to ensure proper preservation, maintenance, and archiving of all statutory and
business documents of the Company, both in physical and electronic form, as per regulatory' requirements. It
provides a structured approach to classify, retain, and dispose of records to support transparency, accountability,
and compliance.

The Policy is av ailable on the Company’s website at https://\vww.mpksteels.com/code-and-policies.php.

ADOPTION OF POLICY ON DETERMINATION OF MATERIALITY FOR DISCLOSURE PR¬
EVENTS TO STOCK EXCHANGES

Pursuant to Regulation 30 of the SKBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, the
Board of Directors has adopted a Policy on Determination of Materiality for Disclosure of Events to Stock
Exchanges.

The policy sets out the criteria for determining materiality of events or information that are required to be disclosed
to the stock exchanges in a timely and transparent manner. It aims to ensure that investors are provided with
accurate and adequate information to enable informed investment decisions and to maintain compliance with
disclosure obligations under applicable laws.

The Policy is available on the Company’s website at https://www.mpkstecls.com/codc-and-policics.php.
POLICIES ADOPTED BY OUR COMPANY

The Company has duly adopted all applicable policies in accordance with the provisions of the Companies Act,
2013, and the SKBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, as amended from time to

time. These policies have been formulated to ensure transparency, good governance, and regulation compliance in
all operations of the Company.

All such policies are available and accessible on the official website of the Company at
https://www.inpkstcds.com/codc-and-policics.php.

DISCLOSURES UNDER SEXUAL HARASSMENT OF WOMEN AT WORK PL ACC (PREVENTION,
PROHIBITION ANDREDRESSAJD ACT, 2013:

The Company has in place Prevention of Sexual Harassment (PoSH) Policy in line with the requirements of Ihc
Sexual Harassment of Women at the Workplace (Prevention, Prohibition &Rcdressal) Act, 2013. All employees
(permanent, contractual, temporary, trainees) are covered under this Policy. The Company provides a sate and
dignified work environment for employee which is free of discrimination, further the Company conducts awareness
Programme at regular interval of time.

The objective of this police is to provide protection against sexual harassment to women at workplace and for
redressal of anv such complaints of harassment. 'I"he Company has constituted Internal Complaints Committee
under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, to redress
the complaints, received, it any.

The Policy is available on the Company’s website at https://www.mpksteels.com/codc-and-policics.php.

An Internal Complaints Committee is constituted for our Company by the Board to look into the matters
concerning sexual harassment pursuant to resolution of the Board of Directors dated February 25, 2025 and was
further reconstituted tin May 02, 2025. The Internal Complaints consists of the following 4 (four) members:

The Company did not receive any complaints of sexual harassment during the year under review as well as in the
preceding year.

During the financial year under review, the Company has complied with all the provisions of the POSI f Act and the
rules framed thereunder. Further details are as follow:

MATERNITY BENIFITS:

The Company affirms that it has duly complied with all provisions of the Maternity Benefit Act, 1961, and has
extended all statutory benefits to eligible women employees during the year.

HUMAN RESOURCES

The Company’s well-disciplined and dedicated workforce, which has served the organization for over two
decades, forms the backbone of its sustained achievements. The management continues to adopt a
structured approach towards performance appraisal and provides training at regular intervals to enhance
employee skills and efficiency. The Company places strong emphasis on talent recognition and has
consistently adhered to the principle of rewarding performance in a fair and transparent manner.

GREEN? INITIATIVE

Your Company lias implemented the “Green Initiative” to enable electronic delivery ot
noticc/documents/annnal reports to shareholders. I or members, who have not registered their e-mail
addresses, please update your e-mail ids with your respective Depository Participants and/or with the
Company.

GENERAL:

'lour 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:

1. There were no significant or material orders passed by the Regulators or Courts or Tribunals which
impact the going concern status ami Company's operations in future.

11. The Company has complied with Secretarial Standards' issued by the Institute of Company
Secretaries of India on board and General Meetings.

III. There was no commission paid by the company 10 iis managing director or whole-time directors,
so no disclosure required m pursuance to the section 19^(14) ot I he Companies Act, 2013.

IV. No application has been made under rhe Insolvency and bankruptcy Code: hence the requirement
to disclose the details of application made or any proceeding pending under the Insolvency and
Bankruptcy Code, 2016 (31 of 2016) during the year along with their status as at the end of the
financial year is not applicable: and

V. The requirement to disclose the details of difference between amount of the valuation done at the
time of onetime settlement and the valuation done while taking loan from the Banks or financial
Institutions along with the reasons thereof, is not applicable.

VI. All other applicable information's to be reported in Board's Report are either nil or not applicable
on the Company.

ACKNOWLEDGEMENT

The Directors thank the Company’s employees, customers, vendors, investors and academic partners tor their
continuous support. The Directors also thank the Government ot India, Governments ot various states in India,
Governments of various countries anti concerned Government department and agencies for their co-operation.

The Directors appreciate and value the contribution made by even- member ot the Company.

BY THE ORDER OF THE BOARD
For M P K STEELS (I) LIMITED

For M P K STEELS (I) LIMITED For M P K STEELS (I) LIMITED

•••••’'*................ Director ......................Director

SURESH KUMAR SHARMA MANOJ UPADHYAY

DIRECTOR MANAGING DIRECTOR

DIN: 00706956 DIN: 00706964

Date: 23rd June, 2025
Place: Jaipur