Atul Ltd 2021-22

41 Corporate Overview 01 - 23 Statutory Reports 24 - 109 Financial Statements 110 - 263 During the period under review, the Company has complied with the provisions of the Act, rules, regulations, guidelines, standards, mentioned hereinabove and there is adequate compliance management system for the purpose of other sector specific laws as reported hereinabove. We have relied on the representations made by the Company and its officers for systems and mechanisms formed by the Company for compliances under other sector specific laws and regulations applicable to the Company. We further report that the Board of Directors of the Company is duly constituted with proper balance of the Executive Directors and the Non-executive Directors (Independent and Non-independent ). The changes in the composition of the Board that took place during the period under review were carried out in compliance with the provisions of the Act. Adequate notice was given to all the Directors to schedule the Board meetings, agenda and detailed notes on agenda were sent at least seven days in advance and a system exists for seeking and obtaining further information and clarifications on the agenda items before the meeting and for meaningful participation at the meeting. Majority decision is carried through while the views of the dissenting members are captured and recorded as part of the minutes, wherever required. We further report that there are adequate systems and processes in the Company commensurate with the size and operations of the Company to monitor and ensure compliance with the applicable laws, rules, regulations and guidelines. We further report that during the audit period, there were no specific events | actions having a major bearing on the affairs of the Company in pursuance of the above referred laws, rules, regulations, guidelines, standards, etc, except approval by the Board for the buy-back of equity shares of the Company for an amount not exceeding ` 70,00,00,000/- (Rupees seventy crores) at a price not exceeding ` 11,000/- per equity share, which represents 2.16% and 2.10% of the total paid-up equity share capital and free reserves (including securities premium account ) as per the audited Standalone and Consolidated Financial Statements. At the maximum buy-back size and the maximum buy-back price, the indicative maximum number of equity shares to be bought back under the proposed buy-back may be 63,636 equity shares, which represents 0.22% of the total number of equity shares of the Company. For SPANJ & ASSOCIATES Company Secretaries (Ashish C Doshi) Partner Membership number: F 3544 Certificate of practice number: 2356 Ahmedabad UDIN: F003544D000206824 April 26, 2022 Peer review certificate number: 702 | 2020 Note: This report is to be read with our letter of even date, which is annexed as Annexure I and forms an integral part of this report.

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