Our Directors take pleasure in presenting the 7^th Annual Report (post-IPO) on the Business and Operations of Shiv
Aum Steels Limited (“the Company”) and the Audited Financial Statements for the financial year ended 31^st
March, 2026.

1. FINANCIAL HIGHLIGHTS

The summary of the financial performance for the financial year ended March 31, 2026, and the previous:
financial year ended March 31,2025, is given below:

2. OPERATIONAL REVIEW AND STATUS OF OTHER AFFAIRS

The Company is engaged in the business of iron and steel products. Currently our Company is dealing with
structural steel, coils and plates. There has been no change in the nature of business carried out by the
Company during the period of April 2025 to March 2026 or from then on till the date of this report.

STANDALONE:

The total income of the Company for the financial year under review stood at Rs. 53,724.36/- (in lakhs) as
against Rs. 55,465.87/- (in Lakhs) during the previous financial year. The standalone net profit of the
Company stood at Rs. 744.10/- (in lakhs) as compared to Rs. 894.61/- (in lakhs).

CONSOLIDATED:

The Consolidated Total Income is Rs. 57,757.02/- (in lakhs) for the financial year ended March 31, 2026, as
against Rs. 56,141.85/- (in lakhs) during the previous financial year. The consolidated net profit is Rs. 720.10/-
(in lakhs) for the year ended March 31,2026, as compared to Rs. 886.87/- (in lakhs) in the previous year.

The consolidated financials reflect the cumulative performance of the Company together with its subsidiaries.

3. CASH FLOW STATEMENTS:

As required under Regulation 34 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations,
2015 (the "Listing Regulations") Regulations, 2015, a Cash Flow Statement forms an integral part of the
Annual Report.

4. TRANSFER TO RESERVES:

The Company proposes to transfer its entire surplus in the statement of Profit & Loss amounting to Rs.
571.43/- (in lakhs) to General Reserves during the financial year ended 31^st March, 2026.

5. DIVIDEND

During the year under review, your Board does not recommend any dividend and wishes to plough back the
profits. Further, as per Regulation 43A of the listing regulations, the requirement to formulate a Dividend
Distribution Policy applies to the top 1,000 listed entities based on market capitalization. As our company does
not fall within this threshold, the formulation and disclosure of a Dividend Distribution Policy do not apply to
us.

6. TRANSFER OF UNPAID AND UNCLAIMED DIVIDENDS TO INVESTOR EDUCATION AND
PROTECTION FUND

The Ministry of Corporate Affairs under Sections 124 and 125 of the Companies Act, 2013 requires dividends
that are not enchased/ claimed by the shareholders for a period of seven consecutive years, to be transferred to
the Investor Education and Protection Fund (IEPF). In FY 2025-26, there was no amount due for transfer to
IEPF.

7. SHARE CAPITAL

The authorized share capital of the company is Rs.15,00,00,000/- (Rupees Fifteen Crores Only) divided into
1,50,00,000 (One Crore Fifty Lakh) equity shares of Rs. 10/- (Rupees Ten Only).

The Paid-up capital of the Company is Rs. 13,60,04,000/- (Rupees Thirteen Crores Sixty Lakh and Four
Thousand Only) divided into 1,36,00,400 (One Crore Thirty-Six Lakh and Four Hundred) Equity shares of Rs.
10/- (Rupees Ten Only).

During the financial year under review, the Company has neither issued sweat equity shares nor issued equity
shares with differential rights as to dividend, voting or otherwise.

Company has appointed M/s. Skyline Financial Services Private Limited as the Registrar and Transfer Agent
of the Company.

8. MANAGEMENT’S DISCUSSION AND ANALYSIS REPORT:

Management's Discussion and Analysis Report for the year under review, in terms of the Listing Regulations
and SEBI (Listing Obligations and Disclosure Requirements) (Amendment) Regulations, 2018 (the "Amended
Listing Regulations"), is presented in a separate section forming an integral part of the Annual Report as
“Annexure V”.

9. CHANGE IN NATURE OF BUSINESS, IF ANY

There has been no change in nature of business of the Company during the Financial Year under review.

There have been no changes in its nature of business during the financial year under review. However,

company has received approval from NSE to migrate the Company from the NSE Emerge platform to the NSE
Main Board and migration is successfully completed w.e.f. November 14, 2025.

10. DISCLOSURES BY DIRECTORS

The Board of Directors have submitted notice of interest in Form MBP 1 under Section 184(1) of the
Companies Act, 2013, as well as intimation by Directors in Form DIR 8 under Section 164(2) of the
Companies Act, 2013, and declarations as to compliance with the Code of Conduct of the Company.

Further, under Regulation 34(3) and Schedule V of the Listing Regulation, Certificate of Non-Disqualification
of Directors received from M/s. M Rupareliya & Associates, Practicing Company Secretary, is annexed to the
Board’s Report as “Annexure IX”.

11. COMPANY’S POLICY RELATING TO APPOINTMENT, PAYMENT OF REMUNERATION TO
DIRECTORS, KEY MANAGERIAL PERSONNEL & OTHER EMPLOYEES:

As per the provisions of Section 178(3) of the Companies Act, 2013, on the recommendation of the
Nomination & Remuneration Committee of the Company, the Board of Directors had approved a Policy which
lays down a framework in relation to the appointment and remuneration of Directors, Key Managerial
Personnel, and the other employees and their remuneration.

The Policy forms part of the Annual Report as “Annexure I”. Further, as required under Section 134(3) of the
Act, the Nomination and Remuneration Policy of the Company is available on the website of the Company
pursuant to the proviso of Section 178(4) of the Companies Act, 2013, at:-
https://www.shivaumsteels.com/share-holder-information.aspx.

The Policy broadly lays down the guiding principles, philosophy, and the basis for payment of remuneration to
Directors, Key Managerial Personnel, and other employees. The policy also provides the criteria for
determining qualifications, positive attributes, and Independence of the Director, and criteria for appointment
of Key Managerial Personnel / Senior Management while making the selection of the candidates.

12. DETAILS OF SUBSIDIARY, JOINT VENTURE AND ASSOCIATE COMPANIES
Subsidiary Companies:

As of March 31, 2026, the Company's corporate structure comprises of one wholly-owned subsidiary
Company as follows:

1. Shivoham Ventures Private Limited

Further, as on March 31, 2026, Company do not have any step-down subsidiaries.

Associate and Joint Venture Companies:

As on March 31, 2026, the Company does not have any associate and joint venture companies.

Pursuant to the provisions of Section 129(3) of the Companies Act, 2013, a statement containing the salient
features of financial statements of the Company’s subsidiaries in Form AOC-1 is attached to the financial
statements of the Company as “Annexure III”.

13. MATERIAL CHANGES AND COMMITMENTS

There have been no material changes and commitments, which affect the financial position of the Company
which have occurred between the end of the Financial Year and the date of this Report.

14. ANNUAL RETURN

The draft Annual Return of the Company as on March 31, 2026, in the Form MGT-7 in accordance with
Section 92(3) and 134(3) of the Companies Act, 2013, as amended from time to time and the Companies
(Management and Administration) Rules, 2014 is available on the website of the Company at
https://www. shivaumsteels.com/annual-return. aspx.

15. CHANGE IN SHARE CAPITAL:

There was no change in Share Capital of the Company for the period under review.

16. FAMILIARISATION PROGRAMME FOR DIRECTORS

As a practice, all Directors (including Independent Directors) inducted to the Board go through a structured
orientation programme. Presentations are made by Senior Management giving an overview of the operations,
to familiarise the new Directors with the Company's business operations. The Directors are given an
orientation on the products of the business, group structure and subsidiaries, Board constitution and
procedures, matters reserved for the Board, and the major risks and risk management strategy of the Company.

During the year under review, no new Independent Directors were inducted to the Board.

The details of the Familiarisation Programme are available on the Company’s website at
https://www.shivaumsteels.com/share-holder-information.aspx.

17. CREDIT RATING:

The Company’s financial discipline and prudence is reflected in the credit ratings ascribed by the rating
agency, CRISIL Ltd as given below:

18. BOARD OF DIRECTORS AND KEY MANAGERIAL PERSONNEL:i. Constitution of Board

The composition of Board complies with the requirements of the Companies Act, 2013 (“Act”) and
Regulation 17 of SEBI Listing Regulations, 2015 and Companies Act, 2013 and rules made thereunder.

None of the Director of the Company is serving as a Whole-Time Director in any other Listed Company and
the number of their directorship is within the limits laid down under section 165 of the Companies Act, 2013.

ii. Details of Key Managerial Personnel

iii. Change in Directors and Key Managerial personnel

The Board of Directors of the Company is duly constituted with a proper balance of Executive Directors,
Non-Executive Directors, and Independent Directors.

During the review period and as of the report's date,

1. Ms. Aarti Agarwal has resigned from the position of Company Secretary and Compliance Officer of the
Company with effect from May 24, 2025 and Mr. Harshit Jain appointed as Company Secretary and
Compliance Officer of the Company w.e.f. August 01,2025.

2. Mrs. Bharti Daga has resigned from the position of Non-Executive Independent Director and
Chairperson (DIN: 07792791) of the Company w.e.f. March 31, 2026 and the same is acknowledged by
Board on April 15, 2026. Further, the Company has appointed Mr. Ankit S Mehta, Non-Executive
Independent Director (DIN: 01845488) of the Company, as the Chairman of the Company, consequent to
the resignation of Mrs. Bharti Daga w.e.f. April 16, 2026.

3. Mr. Hemant Maheshwari (DIN: 06771309) has been appointed as an additional Non-Executive Director
designated as an Independent Director of the Company w.e.f. June 23, 2026 subject to approval of the
shareholders of the Company.

iv. Retirement by Rotation of the Directors

In accordance with the provisions of the Companies Act, 2013 and the Articles of Association of the
Company, Mr. Jatin Nagin Mehta (DIN: 00176438) and Mr. Krishna Nagin Mehta (DIN: 03581129)
Executive Directors Company, retire by rotation and offers themselves for re- appointment.

The brief resume of Mr. Jatin Nagin Mehta and Mr. Krishna Nagin Mehta, the nature of their expertise in
specific functional areas, names of the companies in which they have held their directorships, their
shareholdings etc. are furnished in the Annexure - A to the notice of the ensuing AGM.

v. Independent Directors

Our Company has received annual declarations from all the Independent Directors of the Company
confirming that they meet with the criteria of Independence provided in Section 149(6) of the
Companies Act, 2013 and Regulations 16(1)(b) & 25 of the SEBI Listing Regulations, 2015 and there
has been no change in the circumstances, which may affect their status as Independent Director during
the year. In the opinion of the Board, the Independent Directors fulfil the said conditions of
independence. The Independent Directors have also confirmed that they have complied with the
Company’s Code of Business Conduct & Ethics. In terms of requirements of the Listing Regulations, the
Board has identified core skills, expertise and competencies of the Directors in the context of the
Company’s businesses for effective functioning.

Further, in terms of Section 150 of the Companies Act, 2013 read with Rule 6 of the Companies
(Appointment and Qualification of Directors) Rules, 2014, Independent Directors of the Company have
confirmed that they have registered themselves with the databank maintained by the Indian Institute of
Corporate Affairs.

In the opinion of the Board, the Independent Directors are independent of the management; possess the
requisite integrity, experience, expertise, proficiency, and qualifications.

During the year under review, the Independent Directors of the Company had no pecuniary relationship
or transactions with the Company, other than sitting fees, and reimbursement of expenses, if any.

The Independent Directors met on 18^th March, 2026 without the attendance of Non-Independent
Directors and members of the Management. The Independent Directors reviewed the performance of
Non-Independent Directors and the Board as a whole; the performance of the Chairman of the Company,
taking into account the views of Executive Directors and Non-Executive Directors and assessed the
quality, quantity and timeliness of flow of information between the Company Management and the
Board that is necessary for the Board to effectively and reasonably perform their duties.

19. DECLARATION BY INDEPENDENT DIRECTORS:

The Independent Directors have submitted their declaration of independence, stating that:

a) They continue to fulfil the criteria of independence provided in Section 149(6) of the Companies Act,
2013, along with Rules framed thereunder and Regulation 16(1)(b) of Listing regulations; and

b) There has been no change in the circumstances affecting/ their status as Independent Directors of the
Company

The Independent Directors have also confirmed that they have complied with the Company’s Code of
Conduct. In terms of Section 150 of the Companies Act, 2013 and rules framed thereunder, the Independent
Directors have also confirmed their registration (including renewal of applicable tenure) and compliance with
the online proficiency self-assessment test (unless exempted) with the Indian Institute of Corporate Affairs
(IICA).

20. BOARD MEETINGS

Thirteen Board Meetings were held during the Financial Year ended March 31, 2026 i.e. May 22, 2025,
August 01, 2025, August 11, 2025, August 18, 2025, August 25, 2025, September 05, 2025, October 15, 2025,
October 29, 2025, November 06, 2025, November 28, 2025, December 31, 2025, February 13, 2026, and
March 18, 2026 and the maximum gap between any two Board Meetings was less than One Hundred and
Twenty days.

The names of members of the Board, their attendance at the Board Meetings is as under:

21. BOARD COMMITTEES:

The Board Committees play a vital role in strengthening the Corporate Governance practices and focus
effectively on the issues and ensure expedient resolution of the diverse matters. The Committees also make
specific recommendations to the Board on various matters when required. All observations, recommendations
and decisions of the Committees are placed before the Board for information or for approval.

As on March 31, 2026, the Board has following 4 (Four) Committees in accordance with Companies Act, 2013
and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015:

1. Audit Committee

2. Nomination and Remuneration Committee

3. Stakeholder Relationship Committee

4. Corporate Social Responsibility Committee

i. AUDIT COMMITTEE

During the year under review, audit committee met four (4) times i.e. on May 22, 2025, September 05,
2025, November 06, 2025 and February 13, 2026. The composition of the Audit Committee as of March
31, 2026, and details of the Members' participation at the Meetings of the Committee are as follows:

Composition & Attendance

• oversight of the company’s financial reporting process and the disclosure of its financial information to ensure
that the financial statement is correct sufficient and credible;

• recommendation for appointment, remuneration and terms of appointment of auditors of the company;

• approval of payment to statutory auditors for any other services rendered by the statutory auditors;

• reviewing, with the management, the annual financial statements and auditor’s report thereon before
submission to the board for approval;

• reviewing, with the management, the quarterly/Half yearly financial statements before submission to the board
for approval; reviewing, with the management, the statement of uses / application of funds raised through an
issue (public issue, rights issue, preferential issue, etc.), the statement of funds utilized for purposes other than
those stated in the offer document / prospectus / notice and the report submitted by the monitoring agency
monitoring the utilization of proceeds of a public or rights issue, and making appropriate recommendations to
the board to take up steps in this manner;

• reviewing and monitoring the auditor’s independence and performance, and effectiveness of audit process;

• approval or any subsequent modification of transactions of the company with related parties;

• scrutiny of inter-corporate loans and investments;

• valuation of undertakings or assets of the Company, wherever it is necessary; reviewing, with the management,
performance of statutory and internal auditors, adequacy of the internal control systems and risk management
systems; reviewing the findings of any internal investigations by the internal auditors into manners where there
is suspected fraud or irregularity or a failure of internal control systems of a material nature and reporting the
matter to the board; discussion with internal auditors of any significant findings and follow up there on;

• to look into the reasons for substantial defaults in the payment to the depositors, debenture holders,
shareholders (in case of non-payment of declared dividends) and creditors;

• to review the functioning of the Whistle Blower mechanism; approval of appointment of chief financial officer
after assessing the qualifications, experience and background, etc. of the candidate;

• Carrying out any other function as is mentioned in the terms of reference of the audit committee.

ii. NOMINATION & REMUNERATION COMMITTEE:

During the year under review, committee met three (3) times i.e., on May 22, 2025, August 01, 2025 and
September 05, 2025. The composition of the Nomination and Remuneration Committee as at March 31,
2025, and details of the Members' participation at the Meetings of the Committee are as under.

Composition & Attendance

* Mrs. Bharti Daga has resigned from the Company w.e.f. March 31, 2026 and the same is acknowledged
by Board on April 15, 2026. Further, the Company has appointed Mr. Harsh Lapsia a Independent
Director of the Company as member of this committee w.e.f. April 16, 2026.

The terms of reference of the Committee, as per the Companies Act 2013 and listing regulations, include the

following:

1. Formulation of the criteria for determining qualifications, positive attributes and independence of a
director and recommend to our Board a policy relating to the remuneration of the directors, key
managerial personnel and other employees;

2. Formulation of criteria for evaluation of independent directors and our Board;

3. Devising a policy on Board diversity;

4. Identifying persons who are qualified to become directors and who may be appointed in senior
management in accordance with the criteria laid down, and recommend to our Board their appointment
and removal;

5. Considering and recommending grant of employee’s stock option, if any, and administration and
superintendence of the same; and

6. Carrying out any other function contained in the equity listing Obligations and Disclosure Requirements
as and when amended from time to time.

7. The Nomination and Remuneration Committee shall meet as and when required. The quorum shall be two
members present.

The details of the Remuneration Policy of the Company are annexed as “Annexure I” to this report.

iii. STAKEHOLDERS’ RELATIONSHIP COMMITTEE

During the year under review, the committee met once i.e. on May 22, 2025. The composition of the

Stakeholder Relationship Committee as at March 31, 2026, and details of the Members' participation at the

Meetings of the Committee are as under.

Composition & Attendance

Role of the committee:

The terms of reference of the Committee includes:

• considering and resolving the grievances of security holders of the Company including Allotment and listing
of our shares in future;

• Redressing of shareholders and investor complaints such as non-receipt of declared dividend, annual report,
transfer of Equity Shares and issue of duplicate/split/consolidated share certificates;

• Monitoring transfers, transmissions, dematerialization, re-materialization, splitting and consolidation of Equity
Shares and other securities issued by our Company, including review of cases for refusal of transfer/
transmission of shares and debentures;

• Reference to statutory and regulatory authorities regarding investor grievances;

• To otherwise ensure proper and timely attendance and redressal of investor queries and grievances;

• And to do all such acts, things or deeds as may be necessary or incidental to the exercise of the above powers
the Board may decide from time to time and / or enforced by any statutory notification, amendment or
modification, as may be applicable.

During the year, no complaints were received from shareholders. There are no balance complaints. The Company
had no share transfers pending as of March 31,2026.

22. GENERAL MEETING AND POSTAL BALLOT:

During the year under review, following meeting of shareholders were held:

23. BOARD’S PERFORMANCE EVALUATION:

The Board of Directors carried out an annual evaluation of the Board itself, its committees and individual
Directors. The entire Board carried out performance evaluation of each Independent Director excluding the

Independent Director being evaluated. The Nomination Remuneration Committee also carried out evaluation
of every director’s performance.

The evaluation was done after taking into consideration inputs received from the Directors, setting out
parameters of evaluation. Evaluation parameters of the Board and Committees were mainly based on
Disclosure of Information, Key functions of the Board and Committees, Responsibilities of the Board and
Committees, etc.

Individual Directors including the Chairman of the Board and Independent Directors were based on knowledge
to perform the role, time and level of participation, performance of duties and level of oversight and
professional conduct etc.

The performance evaluation of the Independent Directors, i.e., Mr. Pramod Sheena Basrur, Mrs. Bharti Daga,
Mr. Ankit Suryakant Mehta and Mr. Harsh Jayant Lapsia, was also carried out.

Independent Directors in their separate meeting evaluated the performance of Non-Independent Directors,
Chairman of the Board and the Board as a whole.

24. CORPORATE SOCIAL RESPONSIBILITY (CSR):

The Company considers Corporate Social Responsibility (“CSR”) as a process by which an organization
thinks about and evolves its relationships with stakeholders for the common good, and demonstrates its
commitment in this regard.

The Company has constituted a Corporate Social Responsibility (CSR) Committee in accordance with Section
135 of the Companies Act, 2013 read with Companies (Corporate Social Responsibility Policy) Rules, 2014
and Companies (CSR Policy) Amendment Rules, 2021.The Corporate Social Responsibility policy formulated
by the CSR Committee and approved by the Board remains unchanged. The policy is available on the
Company's website at https://www.shivaumsteels.com/share-holder-information.aspx.

During the financial year 2025-26, the Company has in place a CSR policy laid down in accordance with the
provisions of the Companies Act, 2013, and rules made thereunder. The Company under its CSR policy,
affirms its commitment of seamless integration of marketplace, workplace, environment and community
concerns with business operations by undertaking activities/initiatives that are not taken in its normal course of
business and/or confined to only the employees and their relatives and which are in line with the broad based
list of activities, areas or subjects that are set out under schedule VII of the Companies Act, 2013.

The Annual Report on CSR activities as required under the Companies (Corporate Social Responsibility
Policy) Rules, 2014 and Companies (CSR Policy) Amendment Rules, 2021 is enclosed herewith as Annexure
XI to this Report. One meeting of the Committee was conducted during FY 2025-26 on March 18, 2026 and
all CSR committee members had attended the meeting.

The company has spent an amount of Rs. 17,00,000 (Rupees Seventeen Lakhs Only) on CSR activities as
specified in Schedule VII of the Companies Act, 2013, against 2% of the average profit for the last three years.

The company has spent an amount of Rs. 17 Lakhs to support their efforts, which focus on various charitable
activities, primarily in education, healthcare, and empowerment initiatives. The trust aims to improve the lives
of underprivileged individuals and communities through programs such as providing free or subsidized
dialysis, distributing educational resources, and offering support for basic needs.

An Annual Report on CSR activities in terms of Section 134(3)(o) of the Companies Act, 2013 read with the
Companies (Corporate Social Responsibility) Rules, 2014, is attached herewith as 'Annexure XI to this
Report.

Composition & Attendance

25. AUDITORSi) STATUTORY AUDITORS

M/s Agrawal, Jain & Gupta, Chartered Accountants, Mumbai was re-appointed as Statutory Auditors of the
Company in the Annual General Meeting of the members of the Company held on 17^th September, 2021 for a
period of 5 years starting from FY 2021-22 to FY 2025-26 at a remuneration decided between the Board and
the Auditors.

Accordingly, further upon recommendation of Audit Committee, the Board of Directors of the Company in
their meeting held on August 11, 2026 have recommended the appointment of M/s Agrawal, Jain & Gupta
(Firm Registration Number: 013538C) as the Statutory Auditors of the Company. M/s Agrawal, Jain & Gupta
who will hold office for a period of two years from the conclusion of ensuing Annual General Meeting (AGM)
till the conclusion of 9^th AGM.

The auditors have confirmed their eligibility under Section 141 of the Companies Act, 2013 and the Rules
framed there under. As required under Listing Regulations, the Auditors have also confirmed that they hold a
valid certificate issued by the Peer Review Board of the Institute of Chartered Accountants of India.

ii) INTERNAL AUDITORS

The Board of Directors, based on the recommendation of the Audit Committee and pursuant to the provisions
of section 138 of the Act read with the Companies (Accounts) Rules, 2014, has reappointed M/s. DG Parekh &
Co, Chartered Accountants, Mumbai (FRN No.107451W) as the Internal Auditors of your Company for the
financial year 2025-26 to FY 2027-28. The Internal Auditor conducts the internal audit of the functions and
operations of the Company and reports to the Audit Committee and Board from time to time.

iii) SECRETARIAL AUDITORS

Pursuant to the provisions of Section 204 of the Act and the Companies (Appointment and Remuneration of
Managerial Personnel) Rules, 2014, the Board of Directors have appointed CS Mayuri Rupareliya of M/s. M
Rupareliya & Associates, Practicing Company Secretary, Rajkot (COP No. 18634, ACS-A51422), as
Secretarial Auditors of the Company for the financial year FY 2025-26 to FY 2027-28.

M/s M Mayuri Rupareliya, Practicing Company Secretaries, have confirmed they are not disqualified from
being appointed as the Secretarial Auditors of the Company and satisfy the prescribed eligibility criteria. The
Secretarial Audit Report and Certificate on Corporate Governance for the financial year 2025-26 is annexed
herewith as “Annexure II and VIII”

iv) COST AUDITOR:

The Company does not fall within the provisions of Section 148 of the Companies Act, 2013, as read with the
Companies (Cost Records and Audit) Rules, 2014. Therefore, the maintenance of cost records and the
applicability of cost audits, as specified by the Central Government under Section 148 of the Companies Act,

2013, are not applicable to the Company.

26. AUDITOR’S REPORT

The Auditor’s Report and Secretarial Auditor’s Report do not contain any qualifications, reservations, or
adverse remarks impacting on financial or compliance controls. The Report of the Auditors is given as an
Annexure, which forms part of this report.

27. VIGIL MECHANISM / WHISTLE-BLOWER POLICY:

Under the provisions of Section 177(9) of the Companies Act, 2013, read with the Rules made thereunder, the
Company has adopted a Whistle-Blower Policy for Directors and Employees to report genuine concerns and to
provide adequate safeguards against victimization of persons who may use such a mechanism.

The functioning process of this mechanism has been more elaborately mentioned in the Corporate Governance
Report, which forms part of this Annual Report. The said Policy is available on the Company’s website at
https://www.shivaumsteels.com/share-holder-information.aspx.

28. INTERNAL CONTROL SYSTEM AND THETR ADEQUACY:

The Company has a proper and adequate system of internal controls. This ensures that all transactions are
authorized, recorded and reported correctly, and assets are safeguarded and protected against loss from
unauthorized use or disposition. In addition, there are operational controls and fraud risk controls, covering the
entire spectrum of internal financial controls. An extensive program of internal audits and management
reviews supplements the process of internal financial control framework. Properly documented policies,
guidelines and procedures are laid down for this purpose. The internal financial control framework has been
designed to ensure that the financial and other records are reliable for preparing financial and other statements
and for maintaining accountability of assets. In addition, the Company has identified and documented the risks
and controls for each process that has a relationship to the financial operations and reporting.

The Company also has an Audit Committee to interact with the Statutory Auditors, Internal Auditors and
Management in dealing with manners within its terms of reference. This Committee mainly deals with
accounting manners, financial reporting and internal controls.

The Company confirms that its internal financial controls were adequate and operating effectively throughout
the financial year under review.

29. RISK ASSESSMENT AND MANAGEMENT:

Our Company has been continuously reviewing and streamlining its various operational and business risks
involved in its business as part of its risk management policy. Your Company also takes all efforts to train its
employees from time to time to handle and minimize these risks. The policy is available on the company
website https ://www. shivaumsteels.com/share-holder-information. aspx.

30. LISTING WITH STOCK EXCHANGES:

The Equity Shares of the Company is listed on National Stock Exchange of India Limited (“NSE”). Further,
trading in the Equity Shares was not suspended on the Stock Exchanges during the financial year under review.
The Company has paid the requisite Annual Listing Fees for the year 2026-27 to NSE Limited.

31. COMPLIANCE WITH SECRETARIAL STANDARDS:

In terms of Section 118(10) of the Act, the Company is complying with the Secretarial Standards issued by the
Institute of Company Secretaries of India and approved by Central Government with respect to Meetings of the
Board of Directors and General Meetings.

The Company is fully compliant with the applicable Secretarial Standards (SS), viz. SS-1 & SS-2 on Meetings
of the Board of Directors and General Meetings, respectively.

32. PARTICULARS OF EMPLOYEES AND REMUNERATION

Disclosures pertaining to remuneration and other details are required under Section 197(12) of the Companies
Act, 2013 read with Rule 5(1) and 5(2) of the Companies (Appointment and Remuneration of Managerial
Personnel) Rules, 2014 is forming part of the Directors’ Report for the year ended March 31, 2026 and is
annexed to this Report and marked as Annexure- I.

During the financial year 2025-26, no employee, whether employed for whole or part of the year, was drawing
remuneration exceeding the limits mentioned under Section 197(12) of the Companies Act, 2013 read with
Rule 5(2) of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014.

33. POLICIES AND DISCLOSURE REQUIREMENTS

In terms of provisions of the Companies Act, 2013 the Company has adopted various policies, which are
available on its website https://www.shivaumsteels.com/share-holder-information.aspx.

34. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION, FOREIGN EXCHANGE
EARNINGS AND OUTGO1. Conservation of Energy:

a. The steps taken or impact on conservation of energy - The company constantly strives to reduce
and control power consumption continuously by innovative methods thereby contributing to the goal
of better environment. However, adequate measures have been initiated for the conservation of
energy.

b. The steps taken by the Company for utilizing an alternate source of energy - The Company shall
consider on adoption of an alternate source of energy as and when necessary.

c. The Capital Investment on energy conservation equipment - No Capital Investment yet.

2. Technology absorption:

a. The efforts made towards technology absorption. - Minimum technology required for Business is
absorbed.

b. The benefits derived, like product improvement, cost reduction, product development, or
import substitution - Not Applicable

c. In case of imported technology (imported during the last three years reckoned from the
beginning of the financial year) - Not Applicable.

1. The details of the technology imported.

2. The year of import.

3. Whether the technology has been fully absorbed;

4. if not fully absorbed, areas where absorption has not taken place, and the
reasons thereof.

3. The expenditure incurred on Research and Development - Not Applicable.4. Foreign Exchange earnings and Outgo:

35. PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS:

Particulars of loans given, investments made, guarantees given and securities provided are provided in the
financial statements which forms an integral part of this Report.

36. RELATED PARTY TRANSACTIONS AND CONTRACTS OR ARRANGEMENTS WITH RELATED
PARTIES:

The Company has entered into transactions within the meaning of section 188 and Companies (Meetings of
Board and its Powers) rules, 2014 with its related parties during the year ended on 31^st March, 2026. However,
the disclosure of transactions with related party for the year, as per Accounting Standard -18 Related Party
Disclosures is given in Note to accounts of the Balance Sheet as on 31^st March, 2026.

All contracts / arrangements / transactions entered by the Company during the financial year with related
parties were in the ordinary course of business and on an arm’s length basis. The details of
transactions/contracts/arrangements referred to in Section 188(1) of Companies Act, 2013 are furnished in
Form AOC-2 and is attached as “Annexure X” and forms part of this Report

The Policy on the Related Party Transactions as approved by the Board is uploaded on the website of the
Company https://www. shivaumsteels.com/share-holder-information. aspx.

There were no materially significant transactions with the related parties during the Financial Year which were
in conflict with the interest of the Company.

37. PUBLIC DEPOSITS

Your Company has not accepted any fixed deposits within the meaning of Section 73 and 74 of the Companies
Act, 2013 read with Companies (Acceptance of Deposit) Rules, 2014 and as such no principal or interest was
outstanding as on the date of the Balance sheet.

38. UNSECURED LOAN FROM DIRECTORS:

During the year under review, the Company has not borrowed an unsecured loan from any of the Directors of
the Company.

39. CODE OF CONDUCT FOR PROHIBITION OF INSIDER TRADING

Based on the requirements under SEBI (Prohibition of Insider Trading) Regulations, 2015, as amended from
time to time, the code of conduct for prevention of insider trading (“Code”), as approved by the Board from
time to time, are in force at the Company. The objective of this Code is to protect the interest of shareholders
at large, to prevent misuse of any price sensitive information and to prevent any insider trading activity by
dealing in shares of the Company by its Directors, designated employees and other employees.

The Company also adopts the concept of Trading Window Closure, to prevent its Directors, Officers,
designated employees and other employees from trading in the shares of the company at the time when there is
unpublished price sensitive information. The Policy is available on the website of the Company
https://www.shivaumsteels.com/share-holder-information.aspx.

40. FRAUD REPORTING:

There have been no frauds reported by the Auditors of the Company to the Audit Committee or the Board of
Directors under sub-section (12) of section 143 of the Companies Act, 2013 during the financial year.

41. DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS,
COURTS AND TRIBUNALS

No significant and material order has been passed by the regulators, courts, tribunals impacting the going
concern status and Company’s operations in future.

42. PREVENTION OF SEXUAL HARASSMENT AT WORKPLACE:

The Company has in place an Anti-Sexual Harassment Policy in line with the Requirements of the Sexual
Harassment of Women at the Workplace (Prevention, Prohibition &Redressal) Act, 2013 and an Internal
Complaints Committee has been set up to redress complaints received regarding Sexual Harassment at
workplace, with a mechanism of lodging & redress the complaints. All employees (permanent, contractual,
temporary, trainees, etc.) are covered under this policy.

Our Directors further state that pursuant to the requirements of Section 22 of Sexual Harassment of Women at
Work place (Prevention, Prohibition & Redressal) Act, 2013 read with Rules there under, the Company has not
received any complaint of sexual harassment during the year under review.

All employees in the organization are being made to attend the POSH awareness sessions which also covers
gender sensitization. No pending complaints to be resolved for the financial year under review.

43. CORPORATE GOVERNANCE

Pursuant to SEBI (LODR) Regulations, 2015, the report on Corporate Governance during the period under
review with the Certificate issued by M/s M Mayuri Rupareliya & Associates, Practicing Company
Secretaries, on compliance in this regard and is attached as - “Annexure V” and forms part of this Report.

44. MATERNITY BENEFIT PROVIDED BY THE COMPANY UNDER THE MATERNITY BENEFIT
ACT 1961:

The Company has complied with the provisions of the Maternity Benefit Act, 1961, including all applicable
amendments and rules framed thereunder. The Company is committed to ensuring a safe, inclusive, and
supportive workplace for women employees. All eligible women employees are provided with maternity
benefits as prescribed under the Maternity Benefit Act, 1961, including paid maternity leave, nursing breaks,
and protection from dismissal during maternity leave.

The Company also ensures that no discrimination is made in recruitment or service conditions on the grounds
of maternity. Necessary internal systems and HR policies are in place to uphold the spirit and letter of the
legislation.

45. HUMAN RESOURCES:

Your Company is an equal opportunity employer and practices fair employment policies. Your Company is
confident that its Human Capital will effectively contribute to the long-term value enhancement of the
organization.

46. GENDER-WISE COMPOSITION OF EMPLOYEES

In alignment with the principles of diversity, equity, and inclusion (DEI), the Company discloses below the
gender composition of its workforce as of March 31, 2026.

• Male Employees: 31

• Female Employees: 01

• Transgender Employees: 0

This disclosure reinforces the Company’s efforts to promote an inclusive workplace culture and equal
opportunity for all individuals, regardless of gender

47. CODE OF CONDUCT

Your Company has laid down a Code of Conduct for all the Board Members and Senior Management
Personnel of the Company. All Directors and Senior Management Personnel of the Company have affirmed
compliance with the Company’s Code of Conduct for the financial year ended March 31, 2026 in accordance
with Regulation 17(5) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The
Code aims at ensuring consistent standards of conduct and ethical business practices across the Company. The
Company has posted the Code of Conduct for Directors and Senior Management on the company’s website
https://www.shivaumsteels.com/share-holder-information.aspx.

48. DIRECTORS’ RESPONSIBILITY STATEMENT

In terms of the provisions of section 134(5) of the Companies Act, 2013 and to the best of their knowledge and
belief and according to the information and explanations obtained by them and save as mentioned elsewhere in
this Report, the attached Annual Accounts and the Auditors’ Report thereon, your Directors confirm that:

a) In the preparation of the annual accounts for the year ended March 31, 2026, the applicable accounting
standards read with requirements set out under Schedule HI to the Act, have been followed and there are
no material departures from the same.

b) The Directors have selected such accounting policies and applied them consistently and made judgments
and estimates that are reasonable and prudent so as to give a true and fair view of the state of affairs of the
Company as at March 31, 2026 and of the profit of the Company for the year ended on that date.

c) The Directors have taken proper and sufficient care for the maintenance of adequate accounting records in
accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing
and detecting fraud and other irregularities.

d) The Directors have prepared the annual accounts on a 'going concern' basis.

e) They have laid down internal financial controls to be followed by the Company, and such internal
financial controls are adequate and operating effectively.

f) The Directors have devised proper systems to ensure compliance with the provisions of all applicable laws
and that such system is adequate and operating effectively.

49. FINANCE AND ACCOUNTS

Financial Statement has been prepared in accordance with accounting standards as issued by the Institute of
Chartered Accountants of India and as specified in Section 133 of the Companies Act, 2013 and the relevant
rules thereof and in accordance with Regulation 33 of SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015.

The estimates and judgments relating to the Financial Statements are made on a prudent basis, so as to reflect
in a true and fair manner, the form and substance of transactions and reasonably present the Company’s state
of affairs, profits and cash flows for the year ended March 31, 2026. The Company has neither revised the
financial statements nor the report of Board of Directors.

50. AUDIT TRAIL APPLICABILITY (AUDIT AND AUDITORS) RULES 2014 - RULE 11 OF THE
COMPANIES ACT 2013.

The Company has used accounting software for maintaining its books of account for the financial year ended
March 31, 2026, which has a feature of recording audit trail (edit log) facility, and the same has operated
throughout the year for all relevant transactions recorded in the software.

As proviso to Rule 3(1) of the Companies (Accounts) Rules, 2014 is applicable from April 1, 2023, reporting
under Rule 11(g) of the Companies (Audit and Auditors) Rules, 2014 on preservation of audit trail as per the
statutory requirements for record retention is applicable for the financial year ended March 31, 2026.

51. BUSINESS RESPONSIBILITY REPORT

Your Company does not fall under top 500 listed entities as per Market Capitalization. Hence, the Business
Responsibility Report for the financial year, as stipulated under Regulation 34 of the SEBI (Listing Obligations
and Disclosure Requirements) Regulations, 2015 is not attached to this Annual Report.

52. DISCLOSURE W.R.T. DEMAT SUSPENSE ACCOUNT/UNCLAIMED SUSPENSE ACCOUNT:

There are no demat suspense account/unclaimed suspense account during the year under review as per SEBI
(LODR) Regulations, 2015.

53. APPOINTMENT OF DESIGNATED PERSON (MANAGEMENT AND ADMINISTRATION) RULES
2014 - RULE 9 OF THE COMPANIES ACT 2013.

In accordance with Rule 9 of the Appointment of Designated Person (Management and Administration) Rules
2014, it is essential for the company to designate a responsible individual for ensuring compliance with
statutory obligations.

The company has proposed and appointed a Designated person in a Board meeting, and the same has been
reported in the Annual Return of the company.

54. DISCLOSURES:

The following disclosures are not applicable to the company:

1. 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.

2. The details of difference between amount of the valuation done at the time of one-time settlement and the
valuation done while taking loan from the Banks or Financial Institutions along with the reasons thereof.

3. The Company does not have any scheme or provision of money for the purchase of its own shares by
employees or by trustees for the benefit of employees.

4. During the financial year, there has been no revision in the Financial Statements or the Board’s Report.

5. The Company has not issued any shares with differential rights as to dividend, voting, or otherwise.

55. CAUTIONARY STATEMENTS:

Statements in this Annual Report, particularly those which relate to Management Discussion and Analysis
describing the Company’s objectives, projections, estimates, and expectations, may constitute ‘forward
looking statements’ within the meaning of applicable laws and regulations. Actual results might differ
materially from those either expressed or implied in the statement, depending on the circumstances.

56. ACKNOWLEDGEMENT

Your directors take this opportunity to place on record their sincere appreciation for the co-operation and
assistance the Company has received and would like to place on record its appreciation of the devoted services
of the employees; support and co-operation extended by the valued business associates of the Company.

The Directors state that the Company has in place proper system to ensure compliance with the provisions of
the applicable Secretarial Standards (SS-1 and SS-2) issued by the Institute of Company Secretaries of India,
and that they, have been duly followed by the Company to the best of its knowledge and belief.

Registered Office: By order of the Board of Directors

515, The Summit Business Bay, For Shiv Aum Steels Limited

Opp. PVR, Western Express Highway,

A.K. Road, Andheri (E ),

Mumbai - 400093 ^Sd/-

Tel : 022-26827900/01/02/03/04

Fax: 022-226827899 ^Sanjay ^{Narendra Bansal}

CIN: L27105MH2002PLC135117 ^{Whole-time Director}

Website: www.shivaumsteels.com ^DIN^: 00235509

Email: cs@shivaumateels.com. ^Mumbai, ^Tuesday, ^{August 11}, ²⁰²⁶

info@shivaumsteels.com

Sd/-

Utsav Sanjay Bansal
Whole-time Director
DIN: 03130373

Mumbai, Tuesday, August 11, 2026

1

Mrs. Bharti Daga has resigned from the Company w.e.f. March 31, 2026 and the same is acknowledged
by Board on April 15, 2026. Further, the Company has appointed Mr. Ankit S Mehta a Non-Executive
Independent Director of the Company and member of this committee w.e.f. April 16, 2026.

Role of the committee:

The role of the Committee, inter-alia, includes: