Your Directors are pleased to present the Fortieth Annual Report of Eastcoast Steel Limited
(hereinafter referred to as “the Company”) along with the Standalone Audited Financial
Statements for the Financial Year ended March 31, 2024 (hereinafter referred to as “year
under review” or “year” or “FY 2023-24”).

In compliance with the applicable provisions of Companies Act, 2013, (including any statutory
modification(s) or re-enactment(s) thereof, for time being in force) (hereinafter referred to as
“Act”) and the Securities and Exchange Board of India (Listing Obligations and Disclosure
Requirements) Regulations, 2015 (hereinafter referred to as “SEBI Listing Regulations”), this
Report covers the financial performance and other developments in respect of the Company
during the financial year ended March 31,2024 and upto the date of the Board Meeting held
on May 30, 2024 to approve this Report.

1. financial performance

The financial performance of the Company for the Financial Year ended March 31,
2024 is summarised below:

(Rs. in Lakhs)

2. REVIEW OF OPERATIONS

As reported earlier, the Company had resumed trading in iron & steel products, including
engineering products, in the international market.

During the Financial Year under review, the Company’s Total Revenue stood at Rs.
2147.99 Lakhs as compared to Rs.648.56 Lakhs for the previous Financial Year. The
Profit before tax stood at (Rs.2.68) Lakhs during the Financial Year under review as
against Rs 99.89 Lakhs for the previous Financial Year. The Net Loss after Tax for the
year was Rs. 2.94 Lakhs as against the Profit after tax Rs. 78.87 Lakhs reported in the
previous Financial Year.

The board is confident of pursuing these operations more effectively during the current
year and the years to follow.

3. DIVIDEND AND RESERVES

Considering the losses incurred by the Company in the past and with a view to
conserve the earnings, your Directors have not recommended any dividend to the
equity shareholders for the Financial Year ended March 31, 2024.

Your Company has not transferred any amount to the reserves.

4. CHANGE IN NATURE OF BUSINESS, IF ANY

There has been no change in the nature of business of the Company except remodeling
of the nature of business from manufacturing to trading in iron & steel products, including
engineering products, in the international market. Although the foreign trade has been
confided to steel & engineering products, the company might explore and expand these
activities further as and when opportunities arise in the future within the scope of its
objects as per the latest Memorandum of Association of the Company.

5. SUBSIDIARIES, ASSOCIATES AND JOINT VENTURES

During the Financial Year under review, the Company did not have any Subsidiary,
Joint Venture or Associate Companies.

6. MATERIAL CHANGES AND COMMITMENTS IF ANY, AFFECTING THE FINANCIAL
POSITION OF THE COMPANY OCCURRED BETWEEN THE END OF THE
FINANCIAL YEAR TO WHICH THESE FINANCIAL STATEMENTS RELATE AND
THE DATE OF THE REPORT

No material changes and commitments affecting the financial position of the Company
have occurred in the Company since the end of Financial Year ended March 31, 2024
till the date of this report.

7. SHARE CAPITAL

The paid up Equity Share Capital of the Company was Rs. 539.65 Lakhs
(Rs.5,39,64,680/-) divided into divided into 53.96 Lakhs (53,96,468) shares of Rs. 10/-
each as on March 31,2024.

The Company’s Equity Share Capital is listed on the BSE Limited (“BSE”) and are
infrequently traded shares. The shares of the Company have not been suspended from
trading. The annual listing fee had been paid to the stock exchange before due date.

During the year under review, the Company has not issued any shares or other
convertible securities, bonus shares or made a rights issue of shares or shares with
differential voting rights or granted any stock options or any sweat equity shares.
Further, the Company did not buy back any of its shares.

8. DEPOSITS

The Company has not accepted any deposits from public within the meaning of Section
73 and 74 of the Act and Rules framed thereunder (including any amendments thereof)
during the Financial Year ended March 31,2024 and, as such, no amount on account of
principal or interest on deposit from public was outstanding as on the date of this report.

9. HEALTH, SAFETY AND ENVIRONMENT PROTECTION

Since the Company has not been engaged in any manufacturing activity after the
closure of the plant since 1995, health, safety and environment protection measures
are not applicable to the Company for the time being.

10. presentation of financial statements

The financial statements of the Company for the Financial Year, on a standalone basis
has been prepared in compliance with the Act, applicable Accounting Standards and
SEBI Listing Regulations and are disclosed in accordance with Schedule III of the Act.

11. DIRECTORS AND KEY MANAGERIAL PERSONNEL (“KMP”)

a) Retirement by rotation

In terms of the provisions of Section 152(6) of the Act, Shri. Prithviraj S. Parikh,
Director (DIN: 00106727), retires by rotation at the forthcoming Annual General
Meeting (“AGM”) and being eligible offers himself for re-appointment. The Board
recommends his re- appointment for your approval.

A resolution seeking shareholders’ approval for his re-appointment forms part of
the Notice of the AGM.

b) Key Managerial Personnel

Pursuant to the provisions of Section 203 of the Act read with the applicable rules
made thereunder, the following employees are appointed as the Whole-Time Key
Managerial Personnel of the Company:

1. Shri. Babush Kamath- Chief Executive Officer and Chief Financial Officer

2. Shri. P. K. R. K. Menon - Company Secretary and Compliance Officer

There was no change in the composition of the Board of Directors and Key
Managerial Personnel during the year under review, except as stated above.

The Company has devised the following Policies viz:

a) Policy for selection of Directors and determining Directors’ independence;
and

b) Remuneration Policy for Directors, Key Managerial Personnel and other
employees.

The Policy for selection of Directors and determining Directors’ independence sets
out the guiding principles for the Nomination and Remuneration Committee for
identifying persons who are qualified to become Directors and to determine the
independence of Directors, in case of their appointment as Independent Directors
of the Company. The Policy also provides for the factors in evaluating the suitability
of individual Board members with diverse background and experience that are
relevant for the Company’s operations.

The Remuneration Policy for Directors, Key Managerial Personnel and other
Employees sets out the guiding principles for the Nomination and Remuneration
Committee for recommending to the Board, the remuneration of the Directors, Key
Managerial Personnel and other Employees of the Company.

The aforesaid Policies are available on the Company’s website at http://
eastcoaststeel.com/.

12. declaration by independent directors

All Independent Directors have furnished the declarations that they meet the criteria
of independence as laid down under Section 149(6) of the Act and Regulation 25(8)
of SEBI Listing Regulations, and abide by the Code for Independent Directors as
prescribed under Schedule IV of the Act. Further, they have confirmed that there has
been no change in the circumstances or situation, which exist or may be reasonably
anticipated, that could impair or impact the ability of Independent Directors to discharge
their duties with an objective independent judgment and without any external influence.

13. BOARD MEETINGS AND AGM

The Board meets at regular intervals as and when required to discuss the business
polices and strategies apart from other routine business matters.

During the Financial Year ended March 31,2024, the Board met 6 (Six) times i.e. on
April 03, 2023, May 30, 2023, August 14, 2023, November 09, 2023, December 08,
2023 and February 14, 2024.

Apart from as aforesaid, the gap between two meetings did not exceed one hundred
and twenty days and the necessary quorum was present for all the meetings held
during the year.

The attendance of the Directors at the Board Meetings and the AGM held during the
Financial Year ended March 31,2024 is as under:

During the year under review, the Independent Directors met without the presence of

non-independent Directors on February 14, 2024 in order to evaluate:

i. The performance of Non-Independent Directors and Board, as a whole.

ii. The performance of Chairman of the Company taking into account the views of all
the Directors on Board.

iii. The quality, quantity and timeliness of flow of information between the management
and the Board that is necessary for the Board to effectively and reasonably perform
their duties.

All the Independent Directors attended the meeting.

14. committees of the board

Pursuant to Regulation 15(2) of the SEBI Listing Regulations, provisions of Corporate
Governance including Composition of Board are not applicable to the Company.

The composition of the Board of Directors is in conformity with the requirements of the
Act read with the Rules framed thereunder.

a) AUDIT COMMITTEE

Constitution of the Audit Committee

A qualified and independent Audit Committee has been set up by the Board in
compliance with the requirements of Section 177 of the Act read with rules framed
thereunder.

The composition, quorum, powers, role and scope are in accordance with Section
177 of the Act. All the members of the Audit Committee are financially literate and
have experience in financial management.

The Board has accepted all the recommendations of the Audit Committee during
the Financial Year ended March 31, 2024.

Meeting and Attendance

The Committee met 4 (Four) times during the Financial Year ended March 31,
2024, i.e. on May 30, 2023, August 14, 2023, November 09, 2023 and February
14, 2024. The necessary quorum was present for all the meetings held during the
year.

The composition of the Audit Committee and the details of meetings attended by
members of the committee are given below:

The previous AGM of the Company was held on September 29, 2023 and Shri
P. K. R. K. Menon, Chairman of the Committee, was present at the last AGM to
answer the shareholders’ queries.

b) nomination and remuneration committee

Constitution of the Nomination and Remuneration Committee

The Nomination and Remuneration Committee of the Company is constituted in
compliance with Section 178 of the Act read with rules framed thereunder.

The composition, quorum, powers, role and scope are in accordance with Section
178 of the Act.

The Committee met 1 (One) time during the Financial Year ended March 31,2024.
i.e on February 14, 2024. The necessary quorum was present for the meeting held
during the year.

The composition of the Nomination and Remuneration Committee and the details
of meetings attended by members of the Committee are given below:

The previous AGM of the Company was held on September 29, 2023 and Shri
P. K. R. K. Menon, Chairman of the Committee, was present at the last AGM to
answer the shareholders’ queries.

c) STAKEHOLDERS RELATIONSHIP COMMITTEE

Constitution of the Stakeholders Relationship Committee

The Board has constituted the Stakeholders Relationship Committee comprising
of three members. The composition of the Stakeholders Relationship Committee is
in compliance with the provisions of Section 178 of the Act read with rules framed
thereunder.

The Committee met 4 (Four) times during the Financial Year ended March 31,
2024 i.e., i.e. on May 30, 2023, August 14, 2023, November 09, 2023 and February
14, 2024. The necessary quorum was present for the meeting held during the year.

The composition of the Committee and the attendance of the members of the
Stakeholders Relationship Committee during the Financial Year ended March 31,
2024 are as given below:

The Company obtains yearly certificate from a Company Secretary in Practice
confirming the issue of certificates for transfer, sub-division, consolidation etc.
and submits a copy thereof to the Stock Exchange where the shares of the
Company are Listed in terms of Regulation 40(9) of the SEBI Listing Regulations.
Further, the Compliance Certificate under Regulation 7(3) of the SEBI Listing
Regulations, confirming that all activities in relation to share transfer facility are
maintained by Registrar and Share Transfer Agents is also submitted to the
Stock Exchange where the shares of the Company are Listed on a yearly basis.
The previous AGM of the Company was held on September 29, 2023 and Smt.
Sharmila S. Chitale, Chairman of the Committee, was present at the last AGM to
answer the shareholders queries.

15. CORPORATE GOVERNANCE

Pursuant to Chapter IV of the SEBI Listing Regulations, the provision with regard to
Corporate Governance is not applicable to the Company as the paid up equity share
capital of the Company does not exceed Rs.10 crores and net worth does not exceed
Rs. 25 crores as on the last day of the previous Financial Year.

16. ANNUAL EVALUATION OF THE BOARD, ITS COMMITTEES AND INDIVIDUAL

directors

The Board of Directors has carried out an annual evaluation of its own performance,
Board Committees and individual directors pursuant to the provisions of the Act and the
SEBI Listing Regulations.

The Board evaluated its performance after seeking inputs from all the directors on the
basis of criteria such as the Board composition and structure, effectiveness of board
processes, information and functioning etc. Additionally, the Chairman of the Board was
also evaluated on key aspects of his role, taking into account the views of executive
directors and non-executive directors in the aforesaid meeting.

The performance of the Committees was evaluated by the Board after seeking
inputs from the committee members on the basis of criteria such as the composition
of committees, effectiveness of committee meetings etc. The above criteria are as
provided by the Guidance Note on Board Evaluation issued by SEBI.

In a separate meeting of Independent Directors, performance of Non-Independent
Directors, the Board as a whole and the Chairman of the Company was evaluated,
taking into account the views of executive directors and non-executive directors.
Performance evaluation of Independent Directors was done by the entire board,
excluding the Independent Director being evaluated.

17. TRAINING IMPARTED TO THE INDEPENDENT DIRECTORS

Every Independent Director, Executive Director / Senior Managerial Personnel is
familiarized about the Company’s strategy, operations, organisation structure, human
resources, quality, finance and risk management.

Further, at the time of appointment of an Independent Director, the Company issues a
formal letter of appointment outlining his/her role, functions, duties and responsibilities
as a Director. The terms and conditions of letter of appointment is available on the
Company’s website at http://eastcoaststeel.com/.

18. CRITERIA FOR DETERMINING QUALIFICATIONS, POSITIVE ATTRIBUTES AND
INDEPENDENCE OF A DIRECTOR

The company has adopted a policy on Director’s appointment and remuneration
including criteria for determining qualifications, positive attributes, independence of
Director and also remuneration for key managerial personnel and other employees.
The policy is available on the website of the Company at http://eastcoaststeel.com/.

19. management discussion and analysis report

The Management Discussion and Analysis Report, capturing your Company’s
performance, industry trends and other material changes with respect to your
Company’s and its subsidiaries, wherever applicable and future outlook as stipulated
under the SEBI Listing Regulations is forming an integral part of the Annual Report.

20. details of loans availed from directors or their relatives

The Company has not availed any loans from its Directors or from their relatives during
the period under review.

21. PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS

There were no Loan, guarantee given or investment made or security provided pursuant
to Section 186 of the Act during the Financial Year under review.

22. PARTICULARS OF CONTRACTS OR ARRANGEMENT MADE WITH RELATED

parties

All the related party transactions entered into by the Company during the Financial Year
were on an arm’s length basis and were carried out in the ordinary course of business.
There are no materially significant related party transactions made by the Company
during the year under consideration with the Promoters, Directors or Key Managerial
Personnel which may have a potential conflict with the interest of the Company at
large. All the related party transactions as required under Ind-AS 24 ‘Related Party
Disclosures’ are reported in other explanatory information, forming part of the financial
statements.

Details of related party transactions are regularly placed before the Audit Committee
and also before the Board for its approval. Wherever required prior approval of the Audit
Committee is obtained.

The Company has not entered into any related party transaction during the Financial
Year pursuant to the provisions of Section 188 of the Act read with Companies (Meetings
of Board and its Powers) Rules, 2014, as amended from time to time. Hence, disclosure
in Form AOC-2 has not been given.

23. PARTICULARS OF EMPLOYEES

The information required under Section 197 of the Act read with rule 5(1) of the
Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014
are given below:

a) The Board affirms that the remuneration paid is as per the Remuneration Policy of
the Company.

b) The percentage increase in the median remuneration of employees in the Financial
Year is - Nil.

c) Average percentile increase already made in the salaries of employees other than
the managerial personnel in the last Financial Year and its comparison with the
percentile increase in the managerial remuneration and justification thereof and
point out if there are any exceptional circumstances for increase in managerial
remuneration: Average percentile increase already made in the salaries of
employees other than the managerial personnel in the last Financial Year is Nil
and the percentile increase in the managerial remuneration is Nil.

d) Number of permanent employees on the rolls of the Company as on March 31,
2024 is 5.

e) The ratio of the remuneration paid to each Director to the median remuneration of
the employees of the Company during the Financial Year ended March 31,2024:

f) The percentage increase in remuneration of Director: Nil

g) The percentage increase in remuneration of Chief Financial Officer and Chief
Executive OfficeM3.95%

h) The percentage increase in remuneration of Company Secretary: Nil

i) There has been no remuneration or sitting fees paid to the Directors during the
year under review.

The Company does not have any employee who is drawing a remuneration of
Rs.102 Lakhs per annum or Rs.8.50 Lakhs per month as stipulated in the Act
and the rules made thereunder. Hence, disclosures required under Rule 5(2) and
5(3) of the Companies (Appointment and Remuneration of Managerial Personnel)
Rules, 2014 have not been provided, during the year under review.

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

24. VIGIL MECHANISM / WHISTLE BLOWER POLICY

Pursuant to Section 177(9) and (10) of the Act read with the rules framed thereunder, the
Company has formulated a Whistle Blower Policy for Directors and Employees to report
to the management about the unethical behavior, fraud or violation of Company’s Code
of Conduct. The mechanism provides for adequate safeguards against victimisation
of Employees and Directors who use such mechanism and makes provision for direct
access to the Chairman of the Audit Committee and no personnel of the Company have
been denied access to the Audit Committee. The policy is available on the website of
the Company at http://eastcoaststeel.com/

25. DISCLOSURE UNDER THE SEXUAL HARASSMENT OF WOMEN AT WORKPLACE
(PREVENTION, PROHIBITION AND REDRESSAL) ACT

The Company is committed to provide an environment, which is free of discrimination,
intimidation and abuse. Pursuant to Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Act, 2013 and rules made thereunder, the
Company has a Policy for prevention of Sexual Harassment in the Company. All
employees (permanent, contractual, temporary and trainees) are covered under this
policy. Internal Complaints Committee has also been set up to redress the complaints
received regarding sexual harassment. There were no cases reported during the
Financial Year ended March 31,2024.

26. DETAILS OF SIGNIFICANT MATERIAL ORDERS PASSED BY THE REGULATORS/
COURTS/ TRIBUNAL IMPACTING THE GOING CONCERN STATUS AND
COMPANY’S OPERATION IN FUTURE

There are no significant material orders passed by the Regulators/ Courts/ Tribunal
which would impact the going concern status of the Company and its future operations.
Hence, disclosure pursuant to Rule 8(5)(vii) of Companies (Accounts) Rules, 2014 is
not applicable.

Other Material Orders

M.B. Gupta HUF through Karta Mahesh Chand Gupta and others have filed C.P. No:
347/2020 and I.A. No: 701/2020 before the National Company Law Tribunal, Chennai,
against the Company and others, as and by way of re-litigation of grievances which
were already dealt with in the previous round of litigation in C.P. No. 56 of 2013 filed by
Mr. Suresh Kumar Jalan and others before the erstwhile Company Law Board, Chennai,
which were dismissed by the said judicial authority on 11 May 2015 and such dismissal
having also been confirmed in Company Appeal No: 20 of 2015 by the Hon’ble High
Court, Madras on 26 August 2019.

The Company and others have filed C.P. No: 248 of 2020 and I.A. No. 1177 of 2020
before the National Company Law Tribunal, Chennai, challenging the maintainability of
the aforesaid petition filed by the Petitioners viz. M.B. Gupta HUF and others, which are
pending for hearing before the Hon’ble Tribunal and these are scheduled to be heard
as adjourned to 05th July 2024.

In the meanwhile, M/s Suresh Kumar Jalan and others have filed a new petition against
the company and others before the National Company Law Tribunal, Chennai reiterating
the allegations of the petition filed by M/s M.B. Gupta and others vide reference C.P. 38
of 2023 which also stands adjourned to 05th July 2024.

Mr. Sureshkumar Jalan has filed a criminal complaint too, in respect of corporate
disputes before the CB CID Police Puducherry against the company and its directors
and the Company is taking steps to defend the same in accordance with the law.

27. RISK MANAGEMENT POLICY

The Company in order to comply with the provisions of the Act and to provide an
effective mechanism for implementing risk management system had adopted the policy
on risk management for evaluating and monitoring various risks that could threaten the
existence of the Company. The Company had not faced any major risks and no major
deviations from the actuals as attained by the Company. The Audit Committee has

reviewed the policy periodically. The Board takes overall responsibility for the overall
process of risk management in the organisation.

The Board shall take note of any future threats and shall report to the Company for
formulating an effective mechanism and strategy.The risk management policy is
available on the website of the Company at http://eastcoaststeel.com/

28. SECRETARIAL AUDITORS
Appointment

Pursuant to the provisions of Section 204 of the Act and Companies (Appointment
and Remuneration of Managerial Personnel) Rules, 2014, M/s. Balraj Vanwari &
Associates, Practicing Company Secretaries, (CP: 11708; A.C.S. 2762), have been
appointed as the Secretarial Auditors to conduct the Secretarial Audit of the Company
for the Financial Year ended March 31, 2024.

Secretarial Audit Report

The Report of the Secretarial Audit in Form MR-3 for the Financial Year ended March
31, 2024, is annexed herewith as “Annexure- A” and forms part of this report.

The Secretarial Audit Report does not contain any adverse remark, reservation,
qualification or disclaimer remark.

29. STATUTORY AUDITORS
Appointment

M/s. Paresh Rakesh & Associates LLP (earlier known as M/s. Paresh Rakesh &
Associates), Chartered Accountants (FRN: 119728W/W100743) were appointed as
Statutory Auditors of the Company, for a term of 5 (five) consecutive years i.e. upto the
conclusion of 42nd AGM to be held in the year 2025, at the AGM held on September
30, 2020.

The Company has received written consent and certificate of eligibility pursuant to the
provisions of Sections 139, 141 and other applicable provisions of the Act and rules
framed thereunder (including any statutory modification(s) or re-enactment(s) thereof
for the time being in force) from M/s. Paresh Rakesh & Associates LLP, Chartered
Accountants.

Statutory Auditor’s Report

The Auditors’ Report as issued by M/s. Paresh Rakesh & Associates LLP, Chartered
Accountants for the Financial Year ended March 31,2024, on the financial statements
of the Company is a part of this Annual Report. There are no qualifications, reservations
or adverse remarks or disclaimers made by the Statutory Auditors, in their report for the
Financial Year ended March 31,2024.

Disclosure under Section 143(12) of Act

The Statutory Auditors of the Company have not reported any fraud or irregularities,
as specified under the Second provision of Section 143(12) of the Act (including any
Statutory modification(s) or re-enactment(s) for the time being in force), read with Rule
13 of the Companies (Audit and Auditors) Rules, 2014, during the Financial Year under
review.

30. extract of the annual return

Pursuant to Section 134(3)(a) read with Section 92(3) of the Act, Annual Return of the
Company is available on the website and can be accessed at http://eastcoaststeel.
com/

31. COMPLIANCE OF SECRETARIAL STANDARDS

The Company has complied with the applicable Secretarial Standards issued by the
Institute of Company Secretaries of India, i.e., SS-1 and SS-2, relating to “Meetings of
the Board of Directors” and “General Meetings”, respectively.

32. COST AUDIT

The Company is not required to maintain cost record as prescribed by the Central
Government under the provisions of Section 148 of the Act in view of the closure of the
plant in 1995 and cessation of manufacturing activities. No manufacturing activities or
related services have been undertaken by the Company since then.

33. INTERNAL FINANCIAL CONTROL SYSTEMS AND THEIR ADEQUACY

The Company has in place a robust internal financial control system, commensurate
with the size of its operations and nature of its business activities. The Company has
a standard operating procedure for various activities and operations and follows this
standard operating procedure for its internal control procedures. The Internal Auditor
monitors and evaluates the efficacy and adequacy of internal financial control system
in the Company, its compliance with operating systems, accounting procedures,
application of the instructions and policies fixed by the senior management at all
locations of the Company. The Audit Committee reviews the report on Internal Control
submitted by the Internal Auditors on a quarterly basis.

Based on the assessment carried out by the Audit Committee, the internal financial
controls were adequate and effective and no reportable material weakness or significant
deficiencies in the design or operation of internal financial controls were observed
during the Financial Year ended March 31, 2024.

34. DETAILS OF APPLICATION MADE OR ANY PROCEEDING PENDING UNDER
THE INSOLVENCY AND BANKRUPTCY CODE, 2016 (31 OF 2016) DURING THE
PERIOD UNDER REVIEW ALONGWITH THEIR STATUS AS AT THE END OF THE

period

No applications were made or any proceedings are pending by or against the Company
under the Insolvency and Bankruptcy Code, 2016 (31 of 2016) during the period under
review or as at the end of the period.

35. DISCLOSURE REGARDING EXERCISE OF VOTING RIGHTS BY EMPLOYEES
UNDER SECTION 67(3)(c) OF ACT

Disclosure under Section 67(3)(c) of the Act read with Rule 16(4) of Companies (Share
Capital and Debentures) Rules, 2014, with respect to voting rights not exercised directly
by the employees of the Company is not required to be given.

36. DIRECTORS’ RESPONSIBILITY STATEMENT

Pursuant to Section 134(5) of the Act, your Directors, based on the representations
received from the Operating Management and after due enquiry, hereby confirm that:

a) In the preparation of annual accounts for the Financial Year ended March 31,
2024, the applicable accounting standards had been followed along with proper
explanation relating to material departures;

b) They had in consultation with Statutory Auditors, selected 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 31,2024 and Loss of the Company for the year ended on that date;

c) They 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) They have prepared the annual accounts for the Financial Year ended March 31,
2024 on a “going concern” basis;

e) They have laid down internal financial controls, which are adequate and operating
effectively;

f) They have devised proper system to ensure compliance with the provisions of all
applicable laws and such systems are adequate and operating effectively.

37. CORPORATE SOCIAL RESPONSIBILITY (CSR) INITIATIVES

Provisions of Section 135 of the Act and the Companies (Corporate Social Responsibility
Policy) Rules, 2014, as amended from time to time, are not applicable to your Company
as the Company does not fall under any of the criteria specified therein.

38. CODE FOR PREVENTION OF INSIDER TRADING

Your Company has adopted a Code of Conduct to regulate, monitor and report trading
by designated persons and their immediate relatives as per the requirements under the
Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations,
2015. This Code of Conduct also includes code for practices and procedures for fair
disclosure of unpublished price sensitive information which has been made available on
the Company’s website and can be accessed at http://eastcoaststeel.com/

39. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN

EXCHANGE EARNINGS AND OUTGO

(A) Conservation of Energy

(i) The steps taken or impact on conservation of energy:

The Company makes conscious efforts to reduce its energy consumption.
Some of the measures undertaken by the Company during the year, were
use of LED Lights at office premises instead of conventional lighting, usage

of energy efficient air-conditioning and energy efficient office equipments
such as printer, scanner and photocopy machines. The Company has been
reducing dependence on paper communications and encourages use of
electronic means of communication which serves towards environmental
protection and sustainable growth.

(ii) Steps taken by the Company for utilizing alternate source of energy:

Apart from steps mentioned above to conserve energy, the management has
been continuously exploring feasible alternate sources of energy.

(iii) The capital investment on energy conservation equipment:

There is no capital investment on energy conservation equipment during the
year under review.

(B) Technology Absorption

(i) The efforts made towards technology absorption:

The Company evaluates technology developments on a continuous basis and
keeps the organisation updated.

(ii) The benefits derived:

The Company has benefited from technology development. It has helped to
understand in better way the requirement for the business.

(iii) The Company has not imported any technology from the beginning of
the Financial Year.

(iv) The Company has not incurred any expenditure on Research and
Development during the year under review.

(C) Foreign Exchange Earnings and Outgo

(Rs. Lakhs)

40. cautionary statement

Statements in these reports describing company’s projections statements, expectations
and hopes are forward looking. Though, these expectations are based on reasonable
assumptions, the actual results might differ. Several factors could make a significant
difference to the Company’s operations. These include economic conditions,
government regulations, taxation, natural calamity and currency rate changes, among
others over which the Company does not have any direct control.

41. acknowledgement

Your Directors place on record their sincere appreciation for the assistance and
guidance extended by Stock Exchange, Depositories, other statutory bodies and
Company’s Bankers for the assistance, cooperation and support.

Your Directors also gratefully acknowledge all stakeholders of the Company viz.
customers, members, vendors and other service providers for the excellent support
received from them during the year. The commitment and contribution of the employees
are also acknowledged and appreciated.

For and on behalf of the Board of Directors
Eastcoast Steel Limited

Sd/-

P. K. R. K. Menon

Place: Mumbai Chairman

Date : May 30, 2024 DIN : 00106279