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Capital Trade Links Ltd			Industry : Finance & Investments


BSE Code:	538476	NSE Symbol:	Not Listed	P/E(TTM):	48.74

ISIN Demat:	INE172D01021	Div & Yield %:	0	EPS(TTM):	0.5

Book Value(Rs):	5.4855701	Market Cap ( Cr.):	313.79	Face Value(Rs):	1

Change Company

To,

The Members,

Capital Trade Links Limited

Your directors presents before you the 39^th Annual Report of the company together with the Audited Financial Performance for the year ended March 31, 2024 (FY 2023-24).

1. FINANCIAL PERFORMANCE

The Company's Financial Performance for the year ended as on 31st March, 2024 when contrasted with the earlier year is summed up hereinunder. The financial statements of the Company are prepared in accordance with the Companies (Indian Accounting Standards) Rules, 2015 (Ind AS) notified under Section 133 of the Companies Act, 2013 as amended from time to time.

(Rs. In Crores)

Sl. No.	Particulars	F.Y. ended 31.03.2024	F.Y. ended 31.03.2023
i.	Revenue from operations	35.55	16.80
ii.	Other Income	8.37	0.03
iii.	Total Income	43.92	16.83
iv.	T otal Expenses	30.65	13.10
v.	Profit before tax (iii-iv)	13.26	3.73
vi.	Tax & Adjustment	3.56	1.23
vii.	Profit After Tax (PAT) (v-vi)	9.70	2.49

2. STATE OF AFFAIRS:

The Directors are pleased to announce that the company has achieved a total income of INR 43.92 crores for FY 2023-24, marking a growth of 161% compared to INR 16.83 crores in the previous fiscal year. Additionally, the company's assets under management have experienced a 36% year-over-year growth, rising from INR 143 crores in the previous fiscal year to INR 194 crores in FY 2023-24. Profit after tax for the year stands at INR 9.7 crores, with a paid-up share capital of INR 6.098 crores.

3. CHANGE IN THE NATURE OF BUSINESS, IF ANY

There is no change in the nature of business of your Company during the year under review.

4. TRANSFER TO RESERVE

As per Section 45 IC of Reserve Bank of India Act, 1934, the Company has transferred Rs. 1.94 crores in Special Reserve Account, aggregating to 20% of its net profit. Your company has retained earnings to the tune of Rs. 48.94 Crores in the FY 2023-24.

5. DIVIDEND

Given the company's current growth stage, it aims to retain all earnings generated from its operations. As a result, the Board has decided not to declare any dividends, despite the growth achieved this year. Considering the prevailing economic conditions, the Directors have chosen to preserve the profits to support further organizational growth and development.

6. UNCLAIMED DIVIDEND

Pursuant to Sections 124 and 125 of the Act read with the Investor Education and Protection Fund Authority (Accounting, Audit, Transfer and Refund) Rules, 2016 (“IEPF Rules”), dividend, if not claimed for a period of seven years from the date of transfer to Unpaid Dividend Account of the Company, are liable to be transferred to IEPF.

Further, all the shares in respect of which dividend has remained unclaimed for seven consecutive years or more from the date of transfer to an unpaid dividend account shall also be transferred to IEPF Authority. The said requirement does not apply to shares in respect of which there is a specific order of Court, T ribunal or Statutory Authority, restraining any transfer of the shares.

In the interest of the shareholders, details of unclaimed dividends and shareholders whose shares are liable to be transferred to the IEPF Authority, are uploaded on the Company's website https://capitaltrade.in/investor Information.php.

The shareholders who have not uncashed their dividend with respect of the FY 2016-17 declared on September 28, 2017 are requested to either correspond with the Company's registered office or email at cs@capitaltrade.in or the Company's RTA by e-mailing at investor@masserv.com for revalidation and encash them before the due dates i.e., before October 23, 2024.

7. SHARE CAPITAL

The shareholders of the Company at their Extra Ordinary general Meeting held on November 22, 2023 approved the increase in Authorized Share Capital from INR 7,00,00,000 (Rupees Seven Crores Only) consisting of 7,00,00,000 (Seven Crores) Equity Shares of Re. 1/- (Rupee One only) to INR 32,00,00,000 (Rupees Thirty-Two Crores Only) consisting of 32,00,00,000 (Thirty-Two Crores) Equity Shares of Re. 1/- (Rupee One only).

As on March 31, 2024, the Authorized Share Capital of the Company is Rs. 32,00,00,000/- divided into

32,00,00,000 Equity Shares of Re. 1/- each. The issued, subscribed and paid-up equity share capital of the Company as on March 31, 2024, was Rs. 6,09,80,000/- (Rupees Six Crores Nine Lakhs Eighty Thousand Only) divided into 6,09,80,000 equity shares of Re. 1/- each.

8. DEPOSIT

The company is a Non-Deposit Taking-Non-Systematically Important NBFC (NBFC ND-NSI). As per the Reserve Bank Guidelines, the company is NBFC ND-NSI as the Company is not holding or accepting deposits as on the date of Balance Sheet.

Further, the company being a Loan Company falls in the category of Investment and Credit Company (NBFC-ICC) as per classification notified by RBI.

9. LISTING ON STOCK EXCHANGE

The shares of the Company are listed on the main platform of BSE Limited. The International Securities Identification Number (ISIN) of the company is INE172D01021 and the Scrip code is 538476.

10. ADEQUACY OF INTERNAL FINANCIAL CONTROLS

The Company has designed and implemented an internal financial controls system, taking into account the key components of various critical processes, both physical and operational. This system includes design, implementation, maintenance, and periodic internal reviews to ensure operational effectiveness and sustainability. These controls ensure the orderly and efficient conduct of business, adherence to company policies, safeguarding of assets, prevention of errors, accuracy and completeness of accounting records, and timely preparation of reliable financial information. The internal financial controls related to the financial statements are adequate and operating effectively.

The Audit Committee of the Board regularly reviews the adequacy and effectiveness of these internal controls, providing recommendations for improvements as needed.

11. BOARD OF DIRECTORS AND KEY MANAGERIAL PERSONNEL (KMP):

The Company's Board have optimum combination of executive and non-executive directors which is in conformity with Section 149 of the Companies Act-2013 and Regulation 17 of the SEBI (Listing Obligations and Disclosure Requirements), 2015 with considerable experience and expertise across a range of fields such as finance, accounts, general management and business strategy. The details of the directors and their meetings held during the year have been given in the Corporate Governance Report, which forms part of the Annual Report.

• CHANGES IN DIRECTORS AND KMP DURING THE YEAR:

Appointment of Directors

• Mr. Anil Aggarwal (DIN: 10059847) was appointed as Additional (Non-Executive, Independent) Director of the company on May 17, 2023.

• Mr. Mahendra Kumar Sharma (DIN: 10167061) was appointed as Additional (Non-Executive, Independent) Director of the company on May 17, 2023. His appointment was approved by the shareholders of the company at their AGM held on August 16, 2023.

• Ms. Parul Singh (DIN: 09811725) was appointed as Additional (Non-Executive, Independent) Director of the company on August 23, 2023. Her appointment was approved by the shareholders of the company at the EGM held on November 22, 2023.

• Mr. Ram Parvesh Yadav (DIN: 03265121) was appointed as Additional (Non-Executive, Independent) Director of the company on September 23, 2023. His appointment was approved by the shareholders of the company at the EGM held on November 22, 2023.

Cessation of Directorship

• Ms. Vanisha Kumari Vinay Arora (DIN: 08641753) Independent Director resigned from the company w.e.f. June 05, 2023.

• Mr. Anil Aggarwal (DIN: 10059847) Additional (Non-Executive, Independent) Director resigned from the company w.e.f. July 11, 2023.

• Mr. Amarnath (DIN:06524521) Independent Director resigned from the company w.e.f. September 28, 2023.

Change in Key Managerial Personnel:

• Mr. Satish Kumar resigned from the designation Chief Financial Officer of the company on May 16, 2023 (from the close of business hour) and was re designated as the General Manger (Accounts) of the company. Mr. Sunil Gupta was appointed as Chief Financial Officer of the company with effect from May 17, 2023.

Director liable to retire by rotation:

Pursuant to the requirements of section 152(6) (c) of the Companies Act, 2013, Mr. Krishan Kumar, Non-Executive director of the company (DIN: 00004181), retires by rotation at the ensuing AGM and being eligible, offers himself for re-appointment. The Board recommends the re-appointment of Mr. Krishan Kumar (DIN: 00004181) as Director of the Company, retiring by rotation. Brief details of Mr. Krishan Kumar have been given in the notice convening the Annual General Meeting.

12. INDEPENDENT DIRECTORS

The Company has received necessary declaration from all the independent directors that they meet the criteria of Independence throughout the year as provided under Section 149(6) of the Companies Act, 2013 and Regulation 16(1)(b) of the Listing Regulations. The Independent Directors have also confirmed that they have complied with the Company's Code of Business Conduct & Ethics.

None of the company's directors is disqualified from being appointed as Director, as on March 31, 2024, in terms of Section 164(2) of the Companies Act 2013. A certificate to this effect, duly signed by the Practicing Company Secretary is annexed to the Corporate Governance Report as 'Annexure IV'.

13. INDEPENDENT DIRECTORS' MEETING

As per Section 149, Schedule IV of the Companies Act, 2013, and Rules made thereunder, read with the Listing Regulations, the Independent Directors of the Company met amongst themselves without the presence of Non-Independent Directors and members of Management. The details of the meeting are provided in the Corporate Governance Report, which is part of this Annual Report.

14. MEETINGS OF BOARD OF DIRECTORS

All the board meetings were held in compliance with section 173 of the Companies Act, 2013 as the intervening gap between the meetings was within the period prescribed under the Companies Act, 2013 and SEBI (Listing Obligations and Disclosure Requirements), 2015.

The Board unites at regular intervals to discuss and decide on the Company's business policies and strategies, apart from other agenda items. The Board met 5 (Five) times during the year under review, details of which are given in the Corporate Governance Report, which is part of this Annual Report. The maximum gap between any two meetings did not exceed one hundred and twenty (120) days.

The Company has complied with the requirements prescribed under the Secretarial Standards issued by the Institute of Company Secretaries of India on meetings of the board of directors (SS-1) and general meetings (SS-2).

15. COMMITTEES OF BOARD

The provisions of the Companies Act, 2013 and the Securities Exchange Board of India (Listing Obligations and Disclosures Requirements), Regulation, 2015 have prescribed and mandated forming of Committees of the Board for efficient working and effective delegation of work and to ensure transparency in the practices of the Company. Accordingly, the Committees formed by the Board are as follows:

a. Audit Committee:

Pursuant to Section 177 of the Companies Act, 2013 the Board has formed an Audit Committee. The Board of Directors of the Company has accepted all the recommendations

of the Committee.

b. Nomination and Remuneration Committee:

The policy of the company on director's appointment and remuneration, including the criteria for determining qualifications, positive attributes, independence of a director and other matters, as required under sub-section (3) of section 178 of the Companies Act,2013 is available on our website at https://www.capitaltrade.in/ctl_policies.php.

c. Stakeholders' Relationship Committee:

The Board has, in accordance with the provisions of Section 178(5) of the Companies Act, 2013 constituted Stakeholder Relationship Committee.

d. Risk Management Committee:

This committee has been constituted for monitoring and managing the different types of risks, pursuant to the requirement of Scale Based Regulations issued by Reserve Bank of India.

16. ANNUAL EVALUATION OF DIRECTORS, COMMITTEES AND THE BOARD

As required by Companies Act, 2013, the meeting of independent directors was held on 31^st March 2024 to evaluate the performance of Non independent director, the Chairman and the Board of Directors of the company, against predefined and identified criteria. The criteria for evaluation of the performance of independent director, the Chairman and the Board was finalized by Nomination and Remuneration Committee. Pursuant to the provisions of the Companies Act, 2013 and Regulation 17 of SEBI (Listing Obligations and Disclosure Requirements), 2015, the Board has carried out the annual performance evaluation of its own performance, the directors individually as well as the evaluation of the working of its various committees as per the criteria laid down by the Nomination and Remuneration Committee.

17. VIGIL MECHANISM

The Board of Directors of the Company, pursuant to the provisions of Section 177(9) of the Companies Act, 2013 read with Rule 7 of the Companies (Meetings of Board and its Powers) Rules,

2014 and Regulation 22 of SEBI (Listing Obligations and Disclosures Requirements), Regulation,

2015 framed a “Vigil Mechanism Policy” for Directors and employees of the Company to provide a mechanism to ensure adequate safeguards to Employees and Directors from any victimization on raising of concerns of any violations of Legal or Regulatory requirements, incorrect or misrepresentation of any Financial Statements, Reports, etc. The Employees of the Company have the right/option to report their concerns/grievances to the Chairperson of the Audit Committee.

The Company as part of the 'vigil mechanism' has in place a Board approved 'Whistle Blower Policy' to deal with instances of fraud and mismanagement, if any. There was no reporting made by any employee in violations of applicable laws, regulations and the Code of Conduct for the F.Y. 2023-24.

18. DIRECTOR RESPONSIBILTY STATEMENT

To the best of their knowledge and belief and according to the information and explanations obtained by them, your Directors make the following statements in terms of Section 134(3)(c) of the Act:

i. that in preparation of the annual financial statements for the year ended March 31, 2024, the applicable accounting standards have been followed along with proper explanation relating to material departures;

ii. that appropriate accounting policies have been selected & applied consistently & judgments and estimates made are reasonable & prudent so as to give a true & fair view of the state of affairs of the Company at the end for the financial year and of the profits of the Company for the financial year ended March 31, 2024;

iii. that proper & sufficient care has been taken for the maintenance of adequate accounting records in accordance with the provisions of the Act, for safeguarding the assets of the Company & for preventing & detecting fraud & other irregularities;

iv. that the annual accounts have been prepared on a going concern basis;

v. that the Company had laid down internal financial controls to be followed and that such internal financial controls are adequate and were operating effectively; and

vi. that systems to ensure compliance with the provisions of all applicable laws were in place and that such systems were adequate and operating effectively

19. REPORT ON PERFORMANCE OF SUBSIDIARIES, ASSOCIATES AND JOINT VENTURES COMPANIES

The Company does not have any subsidiary, associate, or joint venture, therefore the statement containing the salient features of the financial statement of subsidiaries, associates or joint ventures under the first proviso to sub-section (3) of section 129 of the Companies Act, 2013 in Form AOC-1 is not applicable.

20. PARTICULARS OF CONTRACTS OR ARRANGEMENT WITH RELATED PARTIES

During the financial year 2023-24, pursuant to Section 188 of the Act and Regulation 23 of SEBI Listing Regulations, all Related Party Transaction(s) (RPTs) were placed before the Audit Committee for its prior approval. These were reviewed by the Audit Committee periodically. All related party transactions during the year were conducted at arms' length and were in the ordinary course of business.

Further, there being no 'material' RPTs as defined under Regulation 23 of SEBI Listing Regulations, there are no details to be disclosed in form AOC-2 in that regard.

21. DISCLOSURE OF RELATED PARTY TRANSACTION

During the year 2023-24, pursuant to Section 188 of the Act and Regulation 23 of SEBI Listing Regulations, all RPTs were placed before the Audit Committee for its prior approval. These were reviewed by the Audit Committee periodically. Details of transactions with related parties during the year under review are provided in the Note No. 29 to the financial statements. All related party transactions during the year were conducted at arms' length and were in the ordinary course of business.

22. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND OUTGO

Report under Section 134 (3) (m) of the Companies Act 2013 read with Rule 8(3) of the Companies (Accounts) Rules, 2014 pertaining to the Conservation of Energy and Technology Absorption is not applicable to the Company. There was no foreign exchange inflow or outflow during the year under review.

23. BUSINESS RESPONSIBILITY REPORT

The Business Responsibility Report as required by Regulation 34(2) of the SEBI Listing Regulations, 2015, is applicable to the Top 1000 companies as on March 31, 2024, based on the market capitalization of the company. Therefore, the requirement of preparing the Business Responsibility Report is not applicable to the company.

24. ANNUAL RETURN

In pursuance to the provisions of Section 92(3), Section 134(3) (a) of the Companies Act, 2013 and Rule 12 of Companies (Management and Administration) Rules, 2014, the copy of Annual Return for the Financial year ended 31st March, 2024 is available on the website of the Company at https://www.capitaltrade.in/investor_Information.php.

25. RISK MANAGEMENT POLICY

The Board of Directors has established a Risk Management Policy to prevent events, situations, or circumstances that could negatively impact the Company's businesses. This policy provides a structured approach to managing uncertainty and integrating risk considerations into decisionmaking across all business divisions and corporate actions. Key business risks and their mitigation strategies are incorporated into the Annual/Strategic Business Plans and reviewed periodically during Management Reviews.

The Risk Management Committee has not identified any risks that, in their opinion, could threaten the Company's existence. Detailed discussions of relevant risks and concerns are included in the Management Discussion and Analysis Report, which is part of the Annual Report.

26. CORPORATE SOCIAL RESPONSIBILTY

The provision of the Companies Act, 2013 with respect to the Corporate Social Responsibility are applicable now and in this respect the company has framed the CSR Policy.

27. AUDITORS AND AUDITOR'S REPORTS

A. Statutory Auditor

During the year under review, on 6th February, 2024, the Board of Directors, based on the recommendation of the Audit Committee but subject to approval of shareholders to be obtained at the General meeting of the company, recommended the appointment of M/s Raj Gupta and Co. Chartered Accountants (FRN: 000203N) as Statutory Auditors of the Company to fill the casual vacancy caused due to the resignation of M/s A.C. Gupta & Associates (FRN 008079N). M/s A.C. Gupta & Associates, Chartered Accountants, resigned on February 3, 2024, from the designation of Statutory Auditor of the company citing the fact that the validity of their Peer Review Certificate had elapsed on 31.12.2023 and the renewal of Peer Review Certificate was pending. They further stated that, given the uncertain time frame it was unlikely to get renewed before the issue of Limited Review Report for the quarter ended December 2023. The said appointment is pursuant to applicable provisions of the Companies Act 2013 and the SEBI Listing Regulations, 2015. The existing/outgoing Auditors have not raised any concern or issue and there is no reason other than as mentioned in their resignation letter. M/s Raj Gupta and Co. Chartered Accountants shall hold office upto the ensuing annual general meeting of the company.

The statutory auditors have confirmed they are not disqualified from being appointed as auditors of the Company. No Observations / Qualifications / Disclaimers are made by the Statutory Auditors in their Report for the Financial year 2023-24. Therefore, it does not call for any further explanation or comments from the Board under Section134(3) of the Companies Act, 2013.

The Auditors' Report on the financial statements of the Company for the financial year ending March 31, 2024, is unmodified i.e.it does not contain any qualification, reservation or adverse remark. The Auditors' Report is enclosed with the financial statements forming part of the annual report.

B. Secretarial Auditor

Pursuant to the provisions of Section 204 read with Section 134(3) of the Act and rules made there under, the Board has appointed M/s Atiuttam Singh & Associates, Practicing Company Secretary, New Delhi for conducting Secretarial Audit of company for the financial year 2023-24. The Secretarial Audit Report in Form MR-3 for the FY 2023-24, is hereby attached with this Report marked as “Annexure III”. Following observations made by Secretarial Auditor-

1. Option to participate Board Meeting through Electronic Mode was not given in Notice of 5th Board Meeting dated 2nd February 2024 as required under para 1.3.4 of Secretarial Standard on meetings of the Board of Directors (SS-1) issued by the Institute of Company Secretaries India (ICSI) as notified by the Central Government under section 118(10) of the Companies Act, 2013 and mandatorily applicable.

The Notice of Board Meeting inadvertently omitted the option to participate electronically. The company will ensure to take steps to prevent such oversights in the future.

• Delay in submission of DNBS 4A return for the first quarter of FY 2023-24 as required to be filed to RBI within 15 days from the end of the quarter.

DNBS 4A was meant to be submitted on the RBI XBRL ORFS portal. However, the company encountered difficulty accessing the return on the portal. This technical issue was promptly brought to the attention of the RBI DOS department. Following resolution, access to the return was available in September 2023. Consequently, the return pertaining to the first quarter of FY 2023-24 was duly submitted thereafter.

• Delay in submission of DNBS 4B return for the month April to July of FY 2023- 24 as required to be filed to RBI within 10 days from the end of the month.

DNBS 4B was meant to be submitted on the RBI XBRL ORFS portal. The company encountered difficulties accessing the return on the portal. This technical issue was escalated to the RBI DOS department for resolution. Following diligent efforts, the issue was rectified, and access to the return was available in September 2023. Consequently, the return for the months of April to July of FY 2023-24 was submitted thereafter.

• Delay in uploading of Proceeding of Annual General Meeting dated 16th August 2023 as required under Regulation 30(6)(ii) of SEBI (LODR) Regulation, 2015.

There was 12 hours delay in uploading proceeding of Annual General Meeting held on 16th August 2023 due to oversite. The company will ensure to take steps to prevent such oversights in the future.

28. REPORTING OF FRAUDS:

During the year under review, the Statutory Auditor or Secretarial Auditor have not reported any instances of fraud in the Company committed by officers or employees of the Company to the Audit Committee under Section 143(12) of the Companies Act, 2013.

29. COST AUDIT:

The provisions of Section 148 read with the Companies (Cost records and Audit) Rules, 2014, pertaining to maintaining of the Cost records and the cost audit, is not applicable to the Company.

30. MANAGEMENT DISCUSSION AND ANALYSIS:

As required under Regulation 34 of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”) and Circular/ Notifications/ Directions issued by Reserve Bank of India from time to time, the Management Discussion and Analysis of the financial condition and result of operations of the Company for the year under review is presented and attached with this Report and marked as “Annexure VI”.

31. CORPORATE GOVERNANCE & CERTIFICATE:

As per Regulation 34(3) read with Schedule V of the SEBI Listing Regulations, 2015, a separate section on corporate governance practices followed by the Company together with a certificate from

the Practicing Company Secretary confirming compliance forms an integral part of this Report marked as “Annexure IV”.

Further, in compliance of Regulation 17(5) of the SEBI Listing Regulations, 2015, your Company has adopted a 'Code of Conduct and Ethics' for its Directors and Senior Executives.

32. PARTICULARS OF INVESTMENTS, LOANS, GUARANTEES AND SECURITIES.

NBFC has been exempted from disclosing particulars of Investments, Loans, Guarantees and acquisition of Securities pursuant to Section 186 of the Companies Act, 2013. However, the brief particulars can be found in the Financial Statement of the Company for financial year 2023-24.

33. DISCLOSURE OF ORDERS PASSED BY REGULATORS OR COURTS OR TRIBUNAL

No orders have been passed by any Regulator or Court or Tribunal which can have an impact on the going concern status of the Company or its operations in future.

34. REMUNERATION POLICY

In accordance to the provision of Section 178 of The Companies Act, 2013 and other applicable provision of SEBI Listing Regulations, 2015, the company has formulated remuneration policy which inter alia, includes the criteria for determining qualifications, experiences, positive attributes and independence of a Directors and other senior officials, who are one level below the Board of Directors of the company. Complete Policy is also available on the website of the Company at https://www.capitaltrade.in/ctl_policies.php.

35. COMPLIANCE WITH RBI GUIDELINES

Your Company is compliant with all the applicable RBI regulatory norms. Since the company is Nonsystematically Non important Non deposit taking NBFC, the company is complying with all the provisions of the master directions and other applicable circulars, issued in this regard from time to time.

The Company continues to have a provisioning policy which is in line with the RBI norms. It fulfils norms and standards laid down by the RBI relating to the recognition and provisioning of nonperforming assets, capital adequacy, statutory liquidity ratio, etc.

36. MATERIAL CHANGES AND COMMITMENT AFFECTING FINANCIAL POSITION OF THE COMPANY

There are no material changes or commitments affecting the financial position of the Company between the end of the financial year and the date of this report.

37. DISCLOSURE AS PER RULE 5 OF THE COMPANIES (APPOINTMENT & REMUNERATION OF MANAGERIAL PERSONNEL) RULES, 2014

As required under Section 197(12) of the Companies Act, 2013 read with Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 the statement giving required details is hereby attached with this Report & forming part of this report marked as “Annexure II”.

38. DISCLOSURE OF COMPANY UNDER THE SEXUAL HARASSMENT OF WOMEN AT WORKPLACE (PREVENTION, PROHIBITION AND REDRESSAL) ACT, 2013

The company has in place a policy for prevention of sexual harassment in line with the requirements of the Sexual Harassment of Women at the Workplace (Prevention, Prohibition and Redressed) Act, 2013 (POSH Act). The company has complied with the provisions relating to the constitution of Internal Complaints Committee (ICC) under the POSH Act. The Company has not received any complaints on sexual harassment during the year.

39. IBC CODE & ONE TIME SETTLEMENT

There has not been any instance of one - time settlement of the company with any bank or financial Institution.

40. ENHANCING SHAREHOLDERS' VALUE:

The Company recognizes its members as its most vital stakeholders. Therefore, the Company's operations are dedicated to attaining high levels of operational performance and cost efficiency, fostering growth, and strengthening its productive assets and resources while maintaining a strong corporate reputation. Additionally, the Company is committed to creating value for all its stakeholders by ensuring that its corporate actions have a positive impact on socioeconomic and environmental factors, contributing to sustainable growth and development.

41. CUSTOMER ENGAGEEMENT

The company is dedicated to fairness in both form and spirit in its dealings with customers. One of its primary objectives is to communicate transparently about terms, rights, and liabilities, empowering customers to make informed financial decisions.

T o achieve this, the company fosters a culture of 'Customer Obsession,' aiming to provide a seamless experience throughout the entire customer journey—from pre-disbursal to loan closure and beyond with additional value-added services. This approach allows the company to effectively measure the success of its customer engagement initiatives.

42. CAUTIONARY STATEMENT:

Statements in this Directors' Report describing the Company's objectives, projections, estimates, expectations or predictions may be “forward-looking statements” within the meaning of applicable securities laws and regulations. Actual results could differ materially from those expressed or

implied. Important factors that could make difference to the Company's operations include changes in Government regulations, Tax regimes, economic developments within India and other ancillary factor.

43. APPRECIATION

We extend our heartfelt gratitude to the Government of India, Reserve Bank of India, Securities and Exchange Board of India, BSE Limited, Ministry of Finance, Ministry of Corporate Affairs, Registrar of Companies, and other government and regulatory authorities, as well as our lenders, financial institutions, and the Company's bankers for their invaluable guidance and support. We sincerely appreciate their continued cooperation and assistance and look forward to their ongoing support in the future.

We also wish to thank our bankers, investors, customers, shareholders, stakeholders, and all other business associates for their unwavering support and trust in us.

Finally, the directors express their deep appreciation for all the employees, whose dedication, teamwork, active involvement, commitment, and professionalism have made the company's growth possible.

Finally, the Directors thank you for your continued trust and support.

By Order of the board

For CAPITAL TRADE LINKS LIMITED

Sd/-

Krishan Kumar Chairman DIN:00004181

Place: Delhi Date: 16.07.2024