To,
The Members
Softrak Venture Investment Limited
Your Directors have pleasure in presenting their 31st Annual Report on the
business and operations of the Company together with its Audited Accounts for the
financial year ended on March 31, 2024. The Management Discussion and Analysis is also
included in this Report.
1. FINANCIAL RESULTS AND OPERATIONAL REVIEW:
The highlights of the financial results of the Company for the financial year ended
March 31, 2024 are as under:
(In lacs)
Particulars |
Year Ended |
|
31.03.2024 |
31.03.2023 |
| Gross Sales/Income |
309.47 |
65.03 |
| Depreciation |
- |
- |
| Profit/(Loss) before Tax |
288.65 |
2.48 |
| Taxes/ Deferred Taxes |
72.65 |
0.73 |
| Profit/(Loss) After Taxes |
216 |
1.74 |
| P& L Balance b/f |
(189.79) |
(191.49) |
| Profit/(Loss) carried to Balance Sheet |
26.20 |
(189.79) |
2. BRIEF DESCRIPTION OF THE COMPANY’S WORKING DURING THE YEAR / STATE OF
COMPANY ‘S AFFAIR:
During the year under review the total income was Rs. 309.47 Lacs as compared to Rs.
65.03 Lacs of the previous year. After making all necessary provisions for current year
and after taking into account the current year net profit and total provisions for
taxation, the surplus carried to Balance Sheet is Rs. 216 Lacs. The Promoters, Board of
Directors and entire management team are putting their stern effort to achieve targeted
turnover in the segment of Investment projects.
3. CHANGE IN THE NATURE OF BUSINESS:
The Company is engaged in the Business of software and computer technology. The Company
is also expanding its commercial activities by actively participating in to various
Government Tenders. There was no change in the nature of the business of the Company
during the year under review.
4. CHANGE OF NAME:
The Company has not changed its name during the year under review.
5. SHARE CAPITAL:
The paid-up Equity Share Capital as on March 31, 2024 was Rs. 4,50,77,900/-.
A) Issue of equity shares with differential rights:
During the year under review, the Company has not issued any shares with differential
voting rights.
B) Issue of sweat equity shares:
During the year under review, the Company has not issued any sweat equity shares.
C) Issue of employee stock options:
During the year under review, the Company has not issued any employee stock options.
D) Provision of money by company for purchase of its own shares by employees or by
trustees for the benefit of employees: The Company has no scheme of provision of money
for purchase of its own shares by employees or by trustees for the benefit of employees.
Hence the details under rule 16 (4) of Companies (Share Capital and Debentures) Rules,
2014 are not required to be disclosed.
6. DIVIDEND:
The Board of Director of the Company has recommended final dividend of 0.5% on face
value of Rs. 10/- each i.e. Rs.0.05 paise per equity share for the financial year 2023-24,
subject to the approval of shareholders in the ensuing 31st Annual General
Meeting.
7. REPORT ON PERFORMANCE AND FINANCIAL POSITION OF SUBSIDIARIES, ASSOCIATES AND
JOINT VENTURE COMPANIES:
The Company has no Subsidiary/Joint Ventures/Associate Companies during the year under
review. Hence, details for the same are not required to mention.
8. DIRECTORS AND KMP:
Mr. Raghvendra Kulkarni (DIN: 06970323), Managing Director of the Company will retire
by rotation at the ensuing 31st Annual General Meeting and being eligible
offers himself for reappointment.
a) Key Managerial Personnel:
The following are the Key Managerial Personnel of the Company.
| Mr. Raghvendra Kulkarni |
Managing Director |
| Ms. Arpita Mittal |
Company Secretary & Compliance Officer |
| Mr. Vipul Jana |
CFO |
b) Directors:
The following are the Directors of the Company.
| Ms Bhoomiben Patel |
Non-Executive - Independent Director |
| Mr. Sunny Darji |
Non-Executive - Independent Director |
| Mr. Sarjeevan Singh |
Non-Executive - Independent Director |
c) Changes in Directors and Key Managerial Personnel:
During the year, no changes took place in the composition of the Directors and Key
managerial Personnel of the Company.
d) Declaration by an Independent Director(s) and reappointment, if any:
All Independent Directors have given declarations that they meet the criteria of
independence as laid down under Section 149(6) of the Companies Act, 2013 and Regulation
25 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
The Independent Directors have complied with the Code of Conduct for Independent
Directors prescribed in Schedule IV of the Companies Act, 2013 and the Code of conduct
formulated by the Company as hosted on the Company’s Website i.e.,
www.softrakventure.in.
9. ANNUAL RETURN:
Pursuant to Sub-section 3(a) of Section 134 and Sub-section (3) of Section 92 of the
Companies Act, 2013 read with Rule 12 of Companies (Management and Administration) Rules,
2014, the copy of the draft Annual Return of the Company for the Financial Year ended on
31st March 2024 in Form MGT-7 is uploaded on website of the Company and can be
accessed at https://www.softrakventure.in/annualreports.php
10. NUMBER OF MEETINGS OF THE BOARD:
The meetings of the Board of Directors are held at periodical intervals and are
generally at the registered office of the Company, Ahmedabad. The meeting dates are
decided well in advance and the agenda and notes on agenda are circulated in advance to
the directors. All material information is incorporated in the notes on agenda for
facilitating meaningful and focused discussion at the meeting. Where it is not perusable
to attach supporting or relevant documents to the agendas, the same is tabled before the
meeting. In case of business exigencies or urgency of matters, resolutionsare passed by
circulation. Senior Management persons are often invited to attend the Board Meetings and
provide clarifications as and when required.
During the year the Board of Directors met Five times (05). The dates of the Board
Meetings are mentioned below:
| 27/05/2023 |
26/07/2023 |
11/08/2023 |
14/11/2023 |
10/02/2024 |
11. DECLARATION BY INDEPENDENT DIRECTORS
All Independent Directors have given declarations that they meet the criteria of
Independence as laid down under Section 149 (6) of the Companies Act, 2013 and Regulation
25 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The
terms and conditions of the Independent Directors are incorporated on the website of the
Company www.softrakventure.in.
12. DIRECTOR’S RESPONSIBILITY STATEMENT :
The Directors’ Responsibility Statement referred to in clause (c) of sub-section
(3) of Section 134 of the Companies Act, 2013, shall state that
a. In the preparation of the annual accounts, the applicable accounting standards had
been followed along with proper explanation relating to material departures;
b. The directors had selected such accounting policies and applied them consistently
and made judgments and estimates that are reasonable and prudent so as to give a true and
fair view of the state of affairs of the company at the end of the financial year and of
the profit and loss of the company for that period;
c. The directors had taken proper and sufficient care for the maintenance of adequate
accounting records in accordance with the provisions of this Act for safeguarding the
assets of the company and for preventing and detecting fraud and other irregularities;
d. The directors had prepared the annual accounts on a going concern basis; and
e. The directors had laid down internal financial controls to be followed by the
company and that such internal financial controls are adequate and were operating
effectively.
f. The directors had devised proper systems to ensure compliance with the provisions of
all applicable laws and that such systems were adequate and operating effectively.
13. DETAILS OF COMMITTEE OF DIRECTORS:
Detailed note on Composition of Audit Committee of Directors, Nomination and
Remuneration Committee of Directors, CSR Committee, Finance & Investment Committee and
Stake Holders Relationship Committee of Directors, number of meetings held of each
Committee during the financial year 2023-24 and meetings attended by each member of the
Committee as required under the Companies Act, 2013 are provided in Corporate Governance
Report.
14. DETAIL OF FRAUD AS PER AUDITORS REPORT:
There is no fraud in the Company during the Financial Year ended 31st March,
2024. This is also being supported by the report of the auditors of the Company as no
fraud has been reported in their audit report for the financial year ended 31st March,
2024.
15. AUDITORS:
A. Statutory Auditors:
The Company’s Auditors, M/s. Meet Shah & Associates, (Firm Regn. No. 142114W)
(Membership No. 169259), Chartered Accountants, Ahmedabad who was appointed in the Annual
General Meeting in the year 2019 for a block of 5 years until the conclusion of the Annual
General Meeting to be held in 2024.
M/s. Meet Shah & Associates, (Firm Regn. No. 142114W) (Membership No. 169259),
Chartered Accountants Ahmedabad, Statutory auditors of the Company, hold office till the
conclusion of the 31st Annual General Meeting of the Company. The Board has
recommended the appointment of M/s. A. L. Thakkar & Co., Chartered Accountants,
Ahmedabad (FRN: 120116W) as Statutory Auditors of the Company in the place of the retiring
auditors for a term of five consecutive years, from the conclusion of the ensuing 31st
Annual General Meeting of the Company till the conclusion of the 36th Annual
General Meeting to be held in the year 2029, for approval of shareholders of the Company,
based on the recommendation of the Audit Committee in compliance with the mandatory
rotation of auditors as per provisions of the Companies Act, 2013.
B. Secretarial Audit:
Pursuant to the provisions of Section 204 of the Companies Act, 2013 and the Companies
(Appointment and Remuneration of Managerial Personnel) Rules, 2014, the Company has
appointed CS Rupali Modi, Practicing Company Secretary, to undertake the Secretarial Audit
of the Company. The Secretarial Audit Report is annexed herewith as "Annexure
-A".
16. BOARD’S COMMENT ON THE AUDITORS ‘ REPORT :
There were no qualifications, reservations or adverse remarks made by Statut or y
Auditors in their Audit report. Observation made by the Statutory Auditors in their Report
are self-explanatory and therefore, do not call for any further comments under section
134(3)(f) of the Companies Act, 2013.
The Secretarial Auditor has raised following qualifications in their Audit Report:
(a) The Company has not updated/published the website of the Company in compliance with
the regulation 46 of the SEBI (Listing Obligation and Disclosure Requirement) Regulations,
2015 during under review.
(b) The Company has not published its financial results in Newspaper as required under
Regulation 47 of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015.
(c) The Company has complied with regulation 30 of the SEBI (Listing Obligation and
Disclosure Requirement) Regulations, 2015 during under review except submission of
Declaration of final dividend to the stock exchange within 30 minutes from the conclusion
of the board meeting where the final dividend is considered and approved by the Board
subject to approval of members.
(d) The Company has not maintained the statutory registers in accordance with the
provisions of the Companies Act, 2013 under review.
(e) It has been found that some of the minutes are incomplete and some of the Minutes
of the Company are not properly maintained on the minutes paper in accordance with the
provisions of the Companies Act, 2013 and Secretarial Standard -1 as amended from time to
time under review.
(f) The Company has not maintained the attendance sheet in accordance with the
provisions of the Companies Act, 2013 and Secretarial Standard -1 as amended from time to
time under review.
(g) As per our limited verification of audited books of account, it came to our
observation that loan and advances are repayable on demand and no schedule of repayment
has been stipulated and no Board Resolution for granting of loan under section 186 of the
Companies Act, 2013, has been found during the year under the review;
MANAGEMENT RESPONSE IN RESPECT OF ABOVE QUALIFICATIONS RAISED BY SECRETARIAL AUDITOR OF
THE COMPANY:
Reply / Explanation of Management with reference to above qualification mentioned at
serial no. (a) to (g) is mentioned below:
a. Company has developed it’s website however pursuant to change of name of the
Company the same was under maintenance for a particular period of time. But presently it
is functioning properly. b. Though the Company had not published the financial results in
newspapers however, Company has placed the same on the website of the Company. Future
compliance is ensured in this matter. c. The Company had submitted the declaration of
final dividend to the stock exchange within 30 minutes from the conclusion of the Board
Meeting where the final dividend is considered and approved by Board subject to approval
of members but due to some technical glitch prevailing on the website of BSE Ltd. the same
was reflected after 30 minutes. d. As the Company is a listed entity therefore Register of
Members and Register of Transfer and beneficial owners are required to be maintained by
Registrar and Transfer Agent. However, Company has maintained the other Statutory
Registers as per the provisions of the Companies Act, 2013. e. Due to inadvertence the
certain minutes of meeting of Board of Directors were not properly printed however Company
has rectified the same and future compliance is ensured in this matter. f. Company has
maintained the Attendance Register of all Board Meetings but the same was lost and unable
to locate the same for a particular period of time. However, at present the same is being
found out and complied with the provisions of the Act. g. Pursuant to the compliance of
relevant accounting Standards the Statutory Auditors of the Company has not shown the
schedule of repayment for loans and advances which are payable on demand. Further the
Company was not required to pass any resolution under Section 186 of the Companies Act,
2013 however, Company has passed necessary resolution under Section 179 of the Companies
Act, 2013 and accordingly complied with the provisions of the Act.
17. TRANSFER TO RESERVES:
During the year under review, the Board does not propose to carry any amount to
reserves out of profit.
18. DEPOSITS:
During the year under review the Company has not accepted any deposits to which the
provisions of section 73, 74 of the Companies Act, 2013 read with Acceptance of Deposits
Rules, 2014 as amended are applicable.
19. PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS UNDER SECTION 186:
Details of Loans, Guarantees and Investments covered under the provisions of Section
186 of the
Companies Act, 2013 are given in the notes to the Financial Statements.
20. PARTICULARS OF CONTRACTS OR ARRANGEMENTS WITH RELATED PARTIES:
The company has not entered into any contracts or arrangements with related parties
during the year under review.
21. SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS:
There are no significant material orders passed by the Regulators /Courts which would
impact the going concern status of the Company and its future operations.
22. PROCEEDINGS UNDER INSOLVENCY AND BANKRUPTCY CODE, 2016:
During the year under review, there were no proceedings that were filed by the Company
or against the Company, which are pending (except the previous years which was already
disclosed) under the Insolvency and Bankruptcy Code, 2016 as amended, before National
Company Law Tribunal or other Courts.
23. DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS OR
TRIBUNALS IMPACTING THE GOING CONCERN STATUS AND CO MPANY’ S OPERATIONS IN FUTURE:
The Company has not obtained any order passed by the regulators or courts or tribunals
impacting the going concern status and Company’s operations in future.
24. BOARD EVALUATION:
The Company has devised a Policy for performance evaluation of the Board, Committees
and other individual Directors (including Independent Directors) which includes criteria
for performance evaluation of the Non-Executive Directors and Executive Directors. The
evaluation process inter alia considers attendance of Directors at Board and committee
meetings, acquaintance with business, communicating inter-se board members, effective
participation, domain knowledge, compliance with code of conduct, vision and strategy,
benchmarks established by global peers, etc., which is in compliance with applicable laws,
regulations and guidelines.
The Board carried out annual performance evaluation of the Board, Board Committees and
Individual Directors and Chairman. The Chairman of the respective Board Committees shared
the report on evaluation with the respective Committee members. The performance of each
Committee was evaluated by the Board, based on report on evaluation received from
respective Board Committees.
The reports on performance evaluation of the Individual Directors were reviewed by the
Chairman of the Board.
In compliance with the provisions of the Companies Act, 2013 and SEBI (Listing
Obligations and Disclosures Requirements) Regulations, 2015, the performance evaluation
was carried out as under Board:
Board:
In accordance with the criteria suggested by the Nomination and Remuneration Committee,
the Board of Directors evaluated the performance of the Board, having regard to various
criteria such as Board composition, Board processes, Board dynamics etc. The Independent
Directors, at their separate meetings, also evaluated the performance of the Board as a
whole based on various criteria specified by Companies Act, 2013. The Board and the
Independent Directors were of the unanimous view that performance of the Board of
Directors as a whole was satisfactory.
Committees of the Board:
The performance of the Audit Committee, the Nomination and Remuneration Committee and
the Stakeholders Relationship Committee was evaluated by the Board having regard to
various criteria such as committee composition, committee processes, committee dynamics
etc. The Board was of the unanimous view that all the committees were performing their
functions satisfactorily and according to the mandate prescribed by the Board under the
regulatory requirements including the provisions of the Act, the Rules framed there under
and the SEBI (Listing Obligations and Disclosures Requirements) Regulations, 2015.
Individual Directors:
Independent Directors: -
In accordance with the criteria suggested by the Nomination and Remuneration Committee,
the performance of each Independent Director was evaluated by the entire Board of
Directors (excluding the Director being evaluated) on various parameters like engagement,
leadership, analysis, decision making, communication, governance and interest of
stakeholders. The Board was of the unanimous view that each Independent Director was a
reputed professional and brought his/her rich experience to the deliberations of the
Board. The Board also appreciated the contribution made by all the Independent Directors
in guiding the management in achieving higher growth and concluded that continuance of
each Independent Director on the Board will be in the interest of the Company.
Non-Independent Directors: -
The performance of each of the Non-Independent Directors (including the chairman) was
evaluated by the Independent Directors at their separate meeting. Further, their
performance was also evaluated by the Board of Directors. The various criteria considered
for the purpose of evaluation included leadership, engagement, transparency, analysis,
decision making, functional knowledge, governance and interest of stakeholders. The
Independent Directors and the Board were of the unanimous view that each of the
non-independent directors was providing good business and people leadership.
25. CORPORATE SOCIAL RESPONSIBILITY:
In terms of the provisions of Section 135 of the Act and Rule 9 of the Companies
(Accounts) Rules, 2014, the Company has not been required to formulate and implement any
Corporate Social Responsibility Initiatives as the said provisions are not applicable to
the Company during the year under review.
26. BUSINESS RISK MANAGEMENT:
The Company has laid down a Risk Management Policy and identified threat of such events
which if occurs will adversely affect either / or, value to shareholders, ability of
company to achieve objectives, ability to implement business strategies, the manner in
which the company operates and reputation as "Risks". Further such Risks are
categorized in to Strategic Risks, Operating Risks & Regulatory Risks. A detailed
exercise is carried out to identify, evaluate, manage and monitoring all the three types
of risks.
27. INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY:
The Company has an Internal Control System, commensurate with the size, scale and
complexity of its operations. During the year under review, the company retained external
audit firm to review its existing internal control system with a view of tighten the same
and introduce system of self-certification by all the process owners to ensure that
internal controls over all the key business processes are operative. The scope and
authority of the Internal Audit (IA) function is defined in the Internal Audit Charter.
The Internal Audit Department monitors and evaluates the efficacy and adequacy of
internal control system in the Company, its compliance with operating systems, accounting
procedures and policies at all locations of the Company and its subsidiaries. Based on the
report of internal audit function, process owners undertake corrective action in their
respective areas and thereby strengthen the controls. Significant audit observations and
corrective actions thereon are presented to the Audit Committee of the Board.
28. DETAILS IN RESPECT OF ADEQUACY OF INTERNAL FINANCIAL CONTROLS WITH REFERENCE TO THE
FINANCIAL STATEMENTS:
The Company has adequate of internal financial controls with reference to the Financial
Statements during the year under review.
29. DETAILS OF ONE TIME SETTLEMENT AND VALUATION THEREOF:
During the year under review, there were no instances of onetime settlement with any
Banks or Financial Institutions and hence no 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.
30. VIGIL MECHANISM / WHISTLE BLOWER POLICY:
In pursuant to the provisions of section 177(9) & (10) of the Companies Act, 2013,
and Regulation 22 of SEBI (Listing Obligations and Disclosure Requirements) Regulations,
2015, a Vigil Mechanism for Directors and Employees to report genuine concerns has been
established. The Company has a vigil mechanism named Whistle Blower Policy to deal with
instances of fraud and mismanagement, if any. The details of the Whistle Blower Policy are
explained in the Corporate Governance Report and also posted on the website of the
Company.
31. EMPLOYEE RELATIONS:
Employee relations throughout the Company were harmonious. The Board wishes to place on
record its sincere appreciation of the devoted efforts of all employees in advancing the
Company’s vision and strategy to deliver good performance.
32. NOMINATION & REMUNERATION POLICY OF THE COMPANY:
The Board has, on the recommendation of the Nomination & Remuneration Committee
framed a policy for selection and appointment of Directors, Senior Management and their
remuneration. The Remuneration Policy is stated in the Corporate Governance Report and is
also available on the Company’s website at www.softrakventure.in The same can be
accessed through the weblink https://www.softrakventure.in/policies.php
33. CORPORATE GOVERNANCE REPORT AND MANAGEMENT DISCUSSION & ANALYSIS REPORT:
The Company has been proactive in the following principles and practices of good
corporate governance. A report in line with the requirements of Regulation 27(2) of SEBI
(Listing Obligations and Disclosure Requirements) Regulations, 2015 the report on
Management Discussion and Analysis and the Corporate Governance practices followed by the
Company and the Auditors Certificate on Compliance of mandatory requirements are given as
an "Annexure "B & C" respectively to this report.
Your Company is committed to the tenets of good Corporate Governance and has taken
adequate steps to ensure that the requirements of Corporate Governance as laid down in
Regulation 27(2) of SEBI (Listing Obligations and Disclosure Requirements) Regulations,
2015 are complied with.
As per 27(2) of SEBI (Listing Obligations and Disclosure Requirements) Regulations,
2015 with the Stock Exchanges, the Corporate Governance Report, Management Discussion and
Analysis and the Auditor’s Certificate regarding compliance of conditions of
Corporate Governance are attached separately and form part of the Annual Report.
34. CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE EARNINGS AND
OUTGO:
The Particulars regarding Conservation of Energy, Technology Absorption and Foreign
Exchange Earnings and
Outgo, pursuant to Section 134 of the Companies act 2013 read with the Companies
(Account) Rules, 2014 are
NIL.
35. MATERIAL CHANGES AND COMMITMENTS, IF ANY, AFFECTING THE FINANCIAL POSITION OF THE
COMPANY WHICH HAVE OCCURRED BETWEEN THE END OF THE FINANCIAL YEAR OF THE COMPANY TO WHICH
THE FINANCIAL STATEMENTS RELATE AND THE DATE OF THE REPORT:
There are no Material changes occurred subsequent to the close of the financial year of
the Company to which the balance sheet relates and the date of the report.
36. PARTICULARS OF EMPLOYEES:
The table containing the names and other particulars of employees in accordance with
the provisions of Section 197(12) of the Companies Act, 2013, read with Rule 5(1) of the
Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014, is provided
as "Annexure- D" to the Board’s report.
None of the employees of the Company drew remuneration of Rs.1,02,00,000/- or more per
annum and Rs.8,50,000/- or more per month during the year. No employee was in receipt of
remuneration during the year or part thereof which, in the aggregate, at a rate which is
in excess of the remuneration drawn by the managing director or whole-time director or
manager and holds by himself or along with his spouse and dependent children, not less
than two percent of the equity shares of the company. Hence, no information is required to
be furnished as required under Rule, 5(2) and 5(3) of The Companies (Appointment and
Remuneration of Managerial Personnel) Rules, 2014.
37. OBLIGATION OF COMPANY UNDER THE SEXUAL HARASSMENT OF WOMEN AT WORKPLACE
(PREVENTION, PROHIBITION AND REDRESSAL) ACT, 2013:
The Company has zero tolerance for Sexual Harassment at Workplace and has adopted a
policy against Sexual Harassment in line with the provisions of Sexual Harassment of Women
at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the rules framed there
under.
During the financial year 2023-24, the Company has not received any complaints on
sexual harassment and hence no complaints remain pending as of March 31, 2024.
38. TRANSFER OF AMOUNTS TO INVESTOR EDUCATION AND PROTECTION FUND:
The Company does not have any funds lying unpaid or unclaimed for a period of seven
years. Therefore, there were no funds which were required to be transferred to Investor
Education and Protection Fund (IEPF).
39. SECRETARIAL STANDARDS:
The Directors State that applicable Secretarial Standards - 1,2,3 and 4 issued by the
Institute of Company secretaries of India relating to ‘Meetings of the Board of
Directors’ and General Meetings’, ‘Payment of Dividend’ and
‘Report of the Board of Directors’ respectively, have been duly followed by the
Company.
40. LISTING WITH STOCK EXCHANGES:
The Company has taken note about payment of the Annual Listing Fees for the year
2023-2024to BSE where the Company’s Shares are listed.
41. WEBSITE OF YOUR COMPANY
Your Company maintains a website www.softrakventure,in. where detailed information of
the Company and specified details in terms of the Companies Act, 2013 and SEBI (Listing
Obligations & Disclosure Requirements) Regulations, 2015 has been provided.
42. PREVENTION OF INSIDER TRADING:
In January 2015, SEBI notified the SEBI (Prohibition of Insider Trading) Regulation,
2015 which came into effect from May, 2015. Pursuant thereto, the Company has formulated
and adopted a new code for Prevention of Insider Trading.
The New Code viz. "Code of Internal Procedures and Conduct for regulating,
Monitoring and reporting of Trading by Insiders" and "Code of Practices and
Procedures for fair Disclosure of Unpublished price Sensitive
Information" has been framed and adopted. The Code requires pre- clearance for
dealing in the Company’s shares and prohibits purchase or sale of Company shares by
the Directors and designated employees while in possession of unpublished price sensitive
information in relation to the Company and during the period when the Trading Window is
closed. The Company is Responsible for implementation of the Code.
43. ACKNOWLEDGEMENT:
Your directors thank the various Central and State Government Departments,
Organizations and Agencies for the continued help and co-operation extended by them. The
Directors also gratefully acknowledge all stakeholders of the Company viz. customers,
members, dealers, vendors, banks and other business partners for the excellent support
received from them during the year. The Directors place on record their sincere
appreciation to all employees of the Company for their unstinted commitment and continued
contribution to the Company.
Date: 05.09.2024 |
|
For & on behalf of the Board of Director |
Place: Ahmedabad |
|
Softrak Venture Investment Limited |
|
Sd/- |
Sd/- |
|
Bhoomiben Patel |
Raghvendra Kulkarni |
|
Director |
Managing Director |
|
(DIN: 08316893) |
(DIN: 06970323) |
|