Your directors are pleased to present the 22^nd Directors' Report on the business and operations of
Steelman Telecom Limited (formerly Steelman Telecom Private Limited) ('the Company') together
with the Audited Financial Statements for the Financial Year ended March 31, 2025.

The Company's Financial Performance (Standalone and Consolidated) for the year ended March 31,
2025, is summarised below:

(Rs. in Lakhs)

Your Company is primarily engaged in Telecommunication Business and providing highly skilled
services to the telecom operators and OEMs. Apart from the services provided in the telecom sectors
your company has a significant footprint in the Engineering, Procurement, and Construction (EPC)
industry, providing services in Civil contracting, Electrical contracting, Mechanical contracting

During the Financial Year 2024-25, the Company recorded a Gross Revenue of Rs.17,535.96 lakhs, as
compared to Rs.18,939.33 lakhs in the previous year, reflecting a 7.41% decrease in revenue. Despite
the decline in revenue, Profit After Tax (PAT) improved, registering a 10.00% increase of Rs.805.75
lakhs, as compared to Rs.732.49 lakhs in the previous Financial Year. Correspondingly, Earnings Per
Share (EPS) for the year stood at Rs.8.33, up from Rs.7.57 in the previous year.

During the Financial Year 2024-2025, the Company reported a consolidated loss of Rs.886.58 lakhs,
reflecting a decrease of Rs.317.65 lakhs as compared to the consolidated loss of Rs.1,204.23 lakhs
reported in the previous Financial Year 2023-2024. This reduction is primarily attributed to the
performance of the subsidiary companies, since a significant portion of the loss of Rs.1,667.64 lakhs
has been incurred by the domestic subsidiary, M/s EC Wheels India Pvt Ltd, and a loss of Rs.24.69 lakhs
(1 INR = 0.654 ETB) has been incurred by the foreign subsidiary M/S Steelman Installation Services PLC
(incorporated in Ethiopia, Africa) during the Financial Year 2024-2025.

Accordingly consolidated Loss Per Share for the year stood at Rs. 1.47 as against the Earning Per Share
of Rs. 3.29 over previous Year.

Your Board is of the opinion that the overall situation would improve with the higher revenue and
profit generation by the subsidiaries in the next year.

Your Company having presence PAN India, headquartered in Kolkata having branch offices at
Bhubaneshwar, Gurgaon, Punjab, Uttar Pradesh and Bihar. Your Company has Project Sites in Telecom
Circles across India.

Your Company provide services for Network Survey and Planning, Installation and Commissioning,
Network Testing and Optimization, Network Solutions and Managed Services for network
maintenance. Strong technical background enables your Company to effectively carry out end-to-end
services thereby covering the entire network & technology service solutions. Understanding of critical
aspects of a technology and utilizing the same to improve coverage, capacity and quality of today's
networks leads to network quality improvement; thereby enhancing every subscriber's experience.
Technically skilled field workforce ensures effective planning and execution of the projects.
Understanding of new technologies and proven track record of good quality services is complimented
with efficient internal processes. Over the years your Company have been successfully implementing
various projects and have been recognized by its clients for quality and timely execution of the projects
undertaken. This expertise and capability have helped the company to achieve continuous growth and
success.

Your Company has strategically expanded its scope of operations beyond the telecom sector. In line
with our vision to diversify and explore new growth avenues, the company now engaged in
Engineering, Procurement, and Construction (EPC) business. This expansion includes the undertaking
of contracts and turnkey projects across various industries and sectors, both within India and
internationally. Our aim is to leverage our technical expertise and operational excellence to deliver
end-to-end EPC solutions for a broad range of clients. This strategic move aligns with our long-term
vision to become a diversified, multi-sector company with a strong presence in high-value
infrastructure and industrial projects.

CHANGE IN REGISTERED OFFICE

During the reporting period, the company has successfully completed a change in its registered office
address. The new registered office is located at MANI CASADONA, FLAT NO 15E1, FLOOR NO-15, PLOT
NO-IIF/04, STREET NO-372, ACTION AREA-IIF, NEW TOWN, KOLKATA-700156, effective from 27^th day
of September 2024. This change was made to better accommodate the growing operational needs
and to enhance business efficiency.

Your Company has complied with all necessary legal and regulatory requirements, including the filing
of the appropriate forms with the Registrar of Companies, to ensure a smooth transition. The updated
address is now the official location for all correspondence, legal notices, and other communications
related to the company.

This relocation marks an important step in the company's growth strategy and reflects its ongoing
commitment to improving operational capacity.

The main object of the Company is to carry on, installing, repairing, training, servicing, maintenance
of all types, varieties and kinds of telecommunication instruments, optical fibre instruments,
telephone internments, telecom network instruments including wires, telephonic communication
infrastructure including towers for wire and wireless communication and cable network, deep sea
cables, accessories, component thereof for telecommunications, signalling and control equipment's
used in roads, railways, ships, aircrafts, ports, airports, railways, network of telecommunication utility
providers, instruments, testing equipment's, accessories for repair, maintenance, calibration and
standardisation of all above items and all other equipment's being used in telecommunication industry
presently and to be develop in future. Your company also involved in a wide range of EPC projects
relating to Infrastructure, infrastructure projects, Industrial construction, Building construction etc.
The operations of the Company during the Financial Year were satisfactory. The detailed operation is
discussed in the Management Discussion Report for the Financial Year under review.

The Company's Equity Share Capital position as on March 31,2025 is as follows: -

A. AUTHORISED CAPITAL

The Authorised Equity Share Capital of the Company as on March 31, 2025, was Rs.110,000,000/-
consisting of 1,10,00,000 Equity shares of Rs. 10/- each during the Financial Year under review.

Changes in Authorised Share Capital during the year under review:

There was no change in Authorised Share Capital during the Financial Year 2024-2025.

B. PAID -UP CAPITAL

The Paid-up Share Capital of the Company as on March 31, 2025, was Rs. 9,67,62,000/-
consisting of 96,76,200 Equity Shares of Rs. 10/- each during the Financial Year under review.

i) Changes in Paid-up Share Capital during the year under review:

There was no change in Share Capital during the Financial Year 2024-2025 under review.

a) Convertible Warrant: During the Financial Year 2024-2025, your Company did not allot any
convertible warrants. However, the previously allotted 10,00,000 Fully Convertible
Warrants remain outstanding and are eligible for conversion on or before July 24, 2025."

b) Conversion of loan into equity - Your Company has not made conversion of loan into equity
during the year under review.

c) Issue of Bonus Shares - The Company has not issued any Bonus Shares during the year under
review.

d) Initial Public Offer - During the Financial Year under review Company does not entered into
further public officer of Equity Shares.

e) Employees Stock Option - The Company has not provided any Stock Option Scheme to the
employees during the year under review.

f) Buy Back of Securities - The Company has not bought back any of its securities during the year
under review.

g) Sweat Equity - The Company has not issued any Sweat Equity Shares during the year under
review.

There are no such shares in suspense account.

To meet the working capital requirements for ongoing and future projects, your Company do not
declare any Dividend for the Financial Year ended 31^st March 2025.

The provisions of Section 125(2) of the Companies Act, 2013 do not apply as there was no dividend
declared and paid last year.

During the Financial year under review no amount was transferred to general Reserves.

There was no change in the nature of the Business of the Company during the FY 2024-2025.

The Company's properties including its Building, Plant & Machinery, Stocks and others continue to be
adequately insured against fire, flood, earthquake, explosive and other such risks, as considered to be
prudent and necessary.

In accordance with the provisions of Section 134(3)(a) of the Companies Act, 2013, Annual Return as
on 31^st March, 2025 in form MGT-7 will also be posted on the Company's website
www.steelmantelecom.com after the same is filed with the Ministry of Corporate Affairs.

By virtue of amendment to Section 92(3) of the Companies Act, 2013, the Company is not required to
provide extract of Annual Return (Form MGT-9) as part of the Board's report.

The declarations required under Section 149(7) of the Companies Act, 2013 from the Independent
Directors of the Company confirming that they meet the criteria of independence under Section
149(6) of the Companies Act, 2013, have been duly received by the Company along with a declaration
of compliance of sub-rule (1) and sub-rule (2) of Rule 6 of Companies (Appointment of Directors) Rules
2014. The independent directors have also complied with the Code for Independent Directors
prescribed in Schedule IV to the Act and Code of Conduct for Directors and senior management
personnel. In the opinion of the Board, there has been no change in the circumstances which may
affect their status as Independent Directors of the Company.

Your Company is required to take a certificate from a Company Secretary in practice that none of the
directors on the board of the company have been debarred or disqualified from being appointed or
continuing as directors of companies by the Board/Ministry of Corporate Affairs or any such statutory
authority as per item 10 (i) of Part C of Schedule V of the Securities Exchange Board of India.

The certificate on non-disqualification of directors (Pursuant to Regulation 34(3) and schedule V para-
C clause 10(i) of the SEBI (Listing Obligation and Disclosure Requirements) Regulations 2015 received
from Mr. Saurabh Basu (CP No: 14347, Meb No: 18686) forming the part of the Annual Report as
Annexure-A.

In keeping with the requirement of the SEBI, Mr. Saurabh Basu (C.P. No. 14347, M. No.: 18686)
Practicing Company Secretary, proprietor of M/S S. BASU & ASSOCIATES, Practicing Company
Secretary Firm, carry out a Secretarial Audit to reconcile the total admitted capital with National
Securities Depository Limited (NSDL) and Central Depository Services (India) Limited (CDSL) and the

total issued and listed capital. The audit confirms that the total issued / paid up capital is in
dematerialized form and the total number of dematerialized shares held with NSDL and CDSL.

In terms of Section 204 of the Act, read with Rule 9 of the Companies (Appointment and Remuneration
of Managerial Personnel) Rules, 2014 (as amended), your Board at its meeting held on 30.05.2024 re¬
appointed M/s S Basu & Associates, (FRN: S2017WB456500), Practicing Company Secretaries firm,
Kolkata as the Secretarial Auditors of your Company, to conduct the Secretarial Audit for the Financial
Year 2024-2025 and to submit Secretarial Audit Report thereon. The Secretarial Audit Report as
received from M/s S Basu & Associates in the prescribed Form No. MR - 3 is annexed to this Report
and marked as Annexure - B and does not contain any qualification, reservation, adverse remark or
disclaimer.

During the Financial Year under review, your Company operates independently, and does not have
any Holding Company, Associate Company or Joint Venture Company and does not cease to be a
subsidiary, joint venture or associate of any other Company. However, your Company has two
subsidiaries namely M/S EC Wheels India Private Limited which is not material and unlisted, pursuant
to SEBI (Listing Obligations and Disclosures Requirements) Regulations, 2015 incorporated as on date
26.02.2022 and a foreign subsidiary Company named M/S STEELMAN INSTALLATION SERVICES PLC
incorporated as on date 23.02.2023, in Ethiopia (Africa).

Your Company hold 50.66% Shares in EC wheels India Pvt Ltd and 99% in STEELMAN INSTALLATION
SERVICES PLC as on 31^st March 2025.

The details of Subsidiary Companies business activities are provided in the Management Discussion
Report forming part of the Annual Report of the Company. The Company has formulated a policy for
determining 'material' subsidiaries pursuant to the provisions of the Listing Regulations as amended
from time to time. The Policy is displayed on the website of the Company. chrome-
extension://efaidnbmnnnibpcajpcglclefindmkaj/https://steelmantelecom.com/pdf/Policy%20for%20
Determining%20Material%20Subsidiaries.pdf

The statement containing the salient feature of the subsidiary companies in Form AOC-1 is furnished
as Annexure C.

Details of top 10 employees and information required under the provisions of Sec.197(12) of the
Companies Act, 2013 read with Rule 5(1), 5(2) and 5(3) of Companies (Appointment and
Remuneration of Managerial Personnel) Rules,2014 ,as amended , which form part of the Directors'
Report , is given as Annexure- D , and will be made available to any shareholders on request as per
provision of section 136(1) of the said Act.

The Managing Director or Whole Time Director as per the terms of his /their appointment, does not
draw any commission or remuneration from subsidiary Company(ies). Hence, no disclosure(s) as
required u/s 197(14) of the Act has been made.

The remuneration paid to the Directors, Managing Directors, Whole time Directors and Managers
during the Financial Year under review is within the limit as prescribed under Sec 197(1) of the
Companies Act,2013.

The remuneration paid to the Directors, Key Managerial Personnel and senior management is as per
the Remuneration Policy of the Company which is available on the Company's website
www.steelmantelecom.com.

Details of loans, guarantees and investments covered under Section 186 of the Companies Act, 2013
are provided in the notes to the Financial Statement as attached with this Annual Report.

Your Company has not accepted any deposits within the meaning of Section 73 of the Companies Act,
2013 read with Companies (Acceptance of Deposits) Rules, 2014.

Following are the Directors of the Company as on 31^st March,2025:

A. Changes in Board of Directors during the Financial Year 2024-2025.

i) There was no change in the Directors of the Company during the Financial Year 2024-2025.

ii) Director Retire by Rotation- In accordance with the provisions of the Companies Act, 2013
and Articles of Association of the Company, Mr. Girish Bindal, Executive Director (DIN:
00484979) of the Company is liable to retire by rotation and being eligible to offers himself
for reappointment.

iii) The disclosures required regarding appointment / re-appointment Mr. Girish Bindal
pursuant to Regulation 36(3) of the SEBI Listing Regulations and Secretarial Standard on
General Meeting issued by The Institute of Company Secretaries of India are given in the
Notice of AGM, forming part of the Annual Report.

Following are the Details of KMP of the Company as on 31^st March,2025:

A. Changes in Key Managerial Personnel during the Financial Year 2024-2025.

There was no change in Key the Managerial Personnel in the Company during the Financial Year
under review.

In compliance with the requirements of Section 178 of the Act, the Listing Regulations and the
Guidance Note on Board Evaluation issued by SEBI in January 2017, a Performance Evaluation was
carried out internally for the Board, Committees of the Board, Individual Directors including the
Chairman of the Board for the Financial Year ended March 31, 2025. After completion of internal
evaluation process, the Board at its meeting held on 30^th May,2025 also reviewed the evaluation and
confirmed that during the year under review the Company has complied with all the criteria of
evaluation as envisaged in the SEBI Circular on Guidance Note on Board Evaluation such as
preparation, participation, conduct and effectiveness and expressed its satisfaction with evaluation
process and results thereof.

During the Financial Year 2024-2025, 6(Six) meetings of Board of Directors were held on 16^th May

2024, 30^th May 2024, 10^th July 2024, 27^th September 2024, 14^th November 2024 and 03^rd February

2025.

The Attendance of Directors at the Board Meetings is as follows:

To comply with the provisions of section 177 and 178 of the Companies Act, 2013("the Act') and Rule
6 of the Companies (Meeting of board and its powers) Rules, 2014 the following Committees have
been constituted by the Board of Director of the Company.

I) Audit Committee

II) Nomination & Remuneration Committee

III) Stakeholders Relationship Committee

IV) CSR Committee

I) AUDIT COMMITTEE:

The Board had, at its meeting held on Monday,18^th July,2022, constituted the Audit Committee in
compliance with the requirement under Section 177 of the Companies Act, 2013, read with rules made
thereunder and Regulation 18 of the Listing Regulations. The present terms of reference of the Audit
Committee includes the powers as laid out in Regulation 18(2)(c) and role as stipulated in Regulation
18(3)(A) of the Listing Regulations. The role, powers and terms of reference of this Committee also
covers the areas as contemplated under Section 177 of the Companies Act, 2013 and the Committee
also complies with the relevant provisions of the Companies Act, 2013.

A) Terms of reference:

The Scope and functions of the Audit Committee are in accordance with Section 177 of the
Companies Act 2013 and Regulations 18 (3) of SEBI Listing Regulation and its terms of reference
include the following:"

> Overseeing the Company's financial reporting process and the disclosure of its
financial information to ensure that the financial statement is correct, sufficient
and credible;

> Recommending to the Board the appointment, re-appointment and
replacement, remuneration and terms of appointment of statutory auditor of the
Company;

> Reviewing and monitoring the statutory auditor's independence and
performance, and effectiveness of audit process.

> Approving payments to statutory auditors for any other services rendered by the
statutory auditors of the Company.

> Reviewing, with the management, the annual financial statements and auditor's
report thereon before submission to the Board for approval, with particular
reference to:

(a) Matters required to be included in the Director's Responsibility Statement to be
included in the Board's report in terms of clause (c) of sub-Section 3 of Section
134 of the Companies Act, 2013, as amended;

(b) Changes, if any, in accounting policies and practices and reasons for the same;

(c) Major accounting entries involving estimates based on the exercise of judgment
by the management;

(d) Significant adjustments made in the financial statements arising out of audit
findings;

(e) Compliance with SEBI Listing Regulations and other legal requirements relating
to financial statements;

(f) Disclosure of any related party transactions; and

(g) Qualifications / modified opinion(s) in the draft audit report.

> Reviewing, with the management, the quarterly, half-yearly and annual financial
statements before submission to the board for approval;

> Reviewing, with the management, the statement of uses / application of funds
raised through an issue (public issue, rights issue, preferential issue, etc.), the
statement of funds utilized for purposes other than those stated in the offer
document / prospectus / notice and the report submitted by the monitoring
agency monitoring the utilization of proceeds of a public or rights issue, and
making appropriate recommendations to the Board to take up steps in this
matter;

> Approval or any subsequent modification of transactions of our Company with
related parties and omnibus approval for related party transactions proposed to
be entered into by our Company subject to such conditions as may be prescribed;

> Formulating a policy on related party transactions, which shall include materiality
of related party transactions;

> Scrutinizing of inter-corporate loans and investments;

> Valuing of undertakings or assets of the Company, wherever it is necessary;

> Evaluating of internal financial controls and risk management systems;

> Establishing a vigil mechanism for directors and employees to report their
genuine concerns or grievances;

> Reviewing, with the management, performance of statutory and internal
auditors, adequacy of the internal control systems;

> Reviewing the adequacy of internal audit function, if any, including the structure
of the internal audit department, staffing and seniority of the official heading the
department, reporting structure coverage and frequency of internal audit;

> Discussing with internal auditors of any significant findings and follow up there
on;

> Reviewing the findings of any internal investigations by the internal auditors into
matters where there is suspected fraud or irregularity or a failure of internal
control systems of a material nature and reporting the matter to the Board;

> Discussing with statutory auditors before the audit commences, about the nature
and scope of audit as well as post-audit discussion to ascertain any area of
concern;

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

> Reviewing the functioning of the whistle blower mechanism;

> Approving the appointment of the Chief Financial Officer (i.e., the whole-time
Finance Director or any other person heading the finance function or discharging
that function) after assessing the qualifications, experience and background, etc.
of the candidate; and

> Carrying out any other function as is mentioned in the terms of reference of the
Audit Committee and any other terms of reference as may be decided by the
Board and/ or specified/ provided under the Companies Act, 2013 or SEBI Listing
Regulations or by any other regulatory authority."

> Reviewing the utilization of loans and/ or advances from/investment by the
holding company in the subsidiary exceeding rupees 100 crore or 10% of the asset

size of the subsidiary, whichever is lower including existing loans / advances /
investments existing as on the date of coming into force of this provision.

> Consider and comment on rationale, cost-benefits and impact of schemes
involving merger, demerger, amalgamation etc., on the listed entity and its
shareholders.

B) Composition of Audit Committee during the Financial Year under review:

C) Changes in the composition of Audit Committee during the Financial Year 2024-2025.

There was no change in the composition of the Audit Committee in the Company during the
Financial Year under review.

D) Meetings of the Audit Committee during the Financial Year under review:

During the Financial Year 2024-2025 the Audit Committee held 5 (Five) meetings on 16th May
2024, 30th May 2024, 27th September 2024, 14th November 2024 and 13th March, 2025.

Chairman of the Committee was present at the last Annual General meeting of the Company held on
20.08.2024.

II) NOMINATION AND REMUNERATION COMMITTEE

Your Company has constituted a Nomination and Remuneration Committee in accordance Section 178
of Companies Act, 2013. The constitution of the Nomination and Remuneration Committee was approved
by a Meeting of the Board of Directors held on July 18, 2022, in terms of requirement under the provisions
of Section 178 the Companies Act, 2013, read with rules made thereunder and in conformity with
Regulation 19 of the Listing Regulations.

A) Terms of reference:

The Scope and functions of the Nomination and Remuneration Committee is in accordance with Section
178 of the Companies Act 2013 and Regulations 19 (4) of SEBI Listing Regulation and its terms of reference
include the following:

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

> Formulating of criteria for evaluation of performance of independent Directors and the Board;

> Devising a policy on Board diversity;

> Identifying persons who are qualified to become directors of our Company and who may be
appointed in senior management in accordance with the criteria laid down and recommend to
the Board their appointment and removal. Our Company shall disclose the remuneration policy
and the evaluation criteria in its Annual Report of our Company;

> Determining whether to extend or continue the term of appointment of the independent
director, on the basis of the report of performance evaluation of independent directors;

> Analyzing, monitoring and reviewing various human resource and compensation matters;

> Determining our Company's policy on specific remuneration packages for executive directors
including pension rights and any compensation payment, and determining remuneration
packages of such directors;

> Determining compensation levels payable to the

> that there is no violation, by and employee id any applicable laws in India or Overseas,
including:

(a) the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
and,

(b) the Securities and Exchange Board of India (Prohibition of Fraudulent and Unfair Trade
Practices Relating to the Securities Market) Regulations, 2003, by the trust, our Company and
its employees, as applicable."

> Performing such other activities as may be delegated by the Board of Directors and/or
specified/ provided under the Companies Act, 2013 or SEBI Listing Regulations or by any other
regulatory authority.

> The policy on directors' appointment and remuneration including criteria for
determining qualifications, positive attributes, independence of a director and other
matters is available on the company's website.

B) Composition of NRC Committee during the Financial Year under review:

C) Changes in the composition of NRC Committee during the Financial Year 2024-2025.

There was no change in the composition of the NRC Committee in the Company during the Financial
Year under review.

D) Meetings of NRC Committee during the Financial Year under review:

During the Financial Year 2024-2025 the NRC Committee held 1 (One) meeting on 16^th May 2024.

Chairman of the Committee was present at the last Annual General meeting of the Company held on

20.08.2024.

IN) STAKEHOLDERS RELATIONSHIP COMMITTEE

Your Company has constituted a shareholder / investors grievance committee "Stakeholders'
Relationship Committee" to redress complaints of the shareholders. The Stakeholders' Relationship
Committee was constituted vide resolution passed at the meeting of the Board of Directors held on July
18, 2022.

A) Terms of reference:

The Scope and functions of the Stakeholders Relationship Committee is in accordance with Section
178 of the Companies Act 2013 and Regulations 20 (4) of SEBI Listing Regulation and its terms of
reference include the following:

The Committee shall consider and resolve grievances of security holders, including but not limited to:

> Efficient transfer of shares including review of cases for refusal of transfer / transmission of shares and
debentures;

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

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

> Allotment and listing of shares in future;

> Reference to statutory and regulatory authorities regarding investor grievances;

> Review of measures taken for effective exercise of voting rights by shareholders

> Review of adherence to the service standards adopted by the Company in respect of various services
being rendered by the Registrar & Share Transfer Agent.

> Review of the various measures and initiatives taken by the Company for reducing the quantum of
unclaimed dividends and ensuring timely receipt of dividend warrants/annual reports/statutory notices
by the shareholders of the company

> Ensure proper and timely attendance and redressal of investor queries and grievances; and

> To do all such acts, things or deeds as may be necessary or incidental to the exercise of the above
powers.

B) Composition of the Stakeholders Relationship Committee during the Financial Year under review:

C) Changes in the composition of Stakeholders Relationship Committee during the Financial
Year 2024-2025.

There is no change in the composition of the Stakeholders Relationship Committee in the Company
during the Financial Year under review.

D) Meetings of Stakeholders Relationship Committee during the Financial Year under review:

During the Financial Year 2024-2025 the SRC Committee held 1 (One) meeting on 16^th May 2024.

Chairman of the Committee was present at the last Annual General meeting of the Company held on
20.08.2024.

IV) CORPORATE SOCIAL RESPONSIBILITY COMMITTEE

Your Company has constituted a CSR committee "Corporate Social Responsibility Committee" upon
applicability of the provision of Section 135 of the Companies Act, 2013 and Rule 5 of the
Companies (Corporate Social Responsibility) Rules, 2014, from the Financial Year 2023-2024.The
CSR committee was constituted vide resolution passed at the meeting of the Board of Directors
held on 30^th day of August 2023. Your Company has formulated a CSR Policy which aims to ensure
that your Company continues to operate its business in an economically, socially and
environmentally sustainable manner.

Further, the policy also lays down the role of the CSR Committee, responsibilities of the Board,

CSR Programmes/Projects, Implementation process, criteria for identifying executing partners,
monitoring and evaluation mechanisms, etc., The complete policy document can be accessed on
the website of the Company at

extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.steelmantelecom.com/pdf/CSR%20

policy.pdf

A. Guiding principles for conducting CSR activities.

Guiding principles of Selection process:

a. Proposals to select under different heads of activities shall be in accordance with Schedule VII of
the Companies Act 2013 and amendments to it from time to time, and to ensure that it fulfils the
eligible criteria defined in the company's CSR Policy.

b. Visit by CSR department's Officials at the site, preparation of report and its submission to the CSR
Committee with all related documents for approval.

c. The activities which benefit the underprivileged and the downtrodden will be given preference.

d. The activities identified by the Company are to be carried out by entities with a proven track
record, to be eligible for funding by the Company.

e. Generally, a CSR activity which is proposed to be completed during afinancial year shall be preferred.
However, if an "ongoing project" is selected, funding shall be done in each year during the duration of the
project out of the funds earmarked for each Financial Year.

f. "Ongoing Project" means a multi-year project undertaken by the company in fulfilment of its CSR
obligation having timelines not exceeding three years excluding the financial year in which it was
commenced. However, they may include projects that were initially not approved as a multi-year project
but whose duration has been extended beyond one year by the Board, based on reasonable
justification.

g. Select projects which are monitorable with the fund disbursed and activities performed in accordance
with predetermined milestones.

h. Maximum priority shall be given to projects where benefits to participants are clear and
measurable.

B. Guiding Principles of Implementation and Monitoring process

a. CSR projects/proposals as approved by the Board shall be carried out either directly by the Company
or through entities who are registered with the Registrar of Companies and have been allotted a
Unique Registration Number permitting them to carry out CSR activities, in conformity with the
prescribed Rules.

b. Every CSR project shall have a time frame and periodic milestones shall be finalized before selection.

c. All connected and related formalities shall be followed as per relevant Rules and the Act in processing

and implementing CSR project.

d. Monitoring of CSR activities shall include visit and inspection by officials of Company's CSR team,
periodic reports on progress on implementation of a project, etc. However, the methodology of
monitoring shall be determined by the CSR Committee on the recommendation of Company's CSR
team, depending upon the nature of the CSR activity and the manner and scope of implementation.

e. Funds allocated for the CSR project shall be disbursed depending on the nature of the project.
Where the amount to be allocated is in tranches, such disbursement shalt be made on the basis of
the schedule, progress of the project and utilization of the amount already disbursed. For this
purpose, the CSR team shall carry out inspection and shall prepare and submit monitoring report for
approval and release of subsequent payment.

f. Wherever any CSR activity is implemented through an approved Agency, besides inspection by CSR
team on the progress made, suitable certificates from such agency shalt be obtained on utilization of
the funds provided by the Company and reports on the progress/status of implementation and/or
completion of the project, as the case may be,be obtained.

g. Status Report on the progress of CSR project undertaken shalt be reported to CSR Committee by the
CSR team at every meeting of the CSR Committee.

h. As and when considered appropriate, services/ assistance of Group/ Associate Companies located
near the project site for CSR related activities may be availed of. In such cases, the CSR team shall
also ensure that it receives a report on the progress of implementation of each of the project and
actual use of funds periodically for release of payment, if any.

i. In case of an ongoing project, the Board shall monitor the implementation of the project with
reference to the approved timelines and year-wise allocation and shaft be entitled to make
modifications, if any, for smooth implementation of the project within the overall permissible time
period.

C. Composition of the Corporate Social Responsibility Committee during the Financial Year
under review:

D. Meetings of Corporate Social Responsibility Committee during the Financial Year under review:

During the Financial Year 2024-2025 the CSR Committee held 2 (Two) meetings on 20^th January 2025
and 26^th March 2025.

In terms of the amendments made to the Listing Regulations, the Board of Directors confirm that
during the year, it has accepted all recommendations received from all its committees.

In terms of requirement of Schedule IV of the Companies Act, 2013, a separate meeting of the
Independent Directors of the Company was held on Wednesday, 5^th March,2025 to review the
performance of Non- Independent Directors (including the Chairman) and the entire Board. The
Independent Directors also reviewed the quality, content and timelines of the flow of information
between the Management, Board and its Committees considered necessary for effective and
reasonable performance while discharging their duties.

On appointment, the concerned Directors was issued a Letter of appointment setting out in detail,
the terms of appointment, duties, responsibilities and expected time commitments. Each appointed
Independent Directors was taken through an induction and familiarization program including the
presentation and interactive session with the Committee Members and other Functional Heads on the
Company's finance and other important aspects. The details of familiarization program conducted
during the Financial Year 2024-2025 for Independent Directors are available on the official website of
the Company at the link provided; https://steelmantelecom.com/regulation25.php

Your Company has in place a Whistle Blower Policy, as a part of Vigil Mechanism to provide
appropriate avenues to the Directors, employees and other Stakeholders of the Company to bring to
the attention of the Management any issue which is perceived to be in violation of or in conflict with
the Code of conduct, values, principles and beliefs of the Company. The established Vigil Mechanism
helps to report concerns about any unethical conduct, financial malpractices or any unhealthy practice
prevalent in the Company. The said Vigil Mechanism provides for adequate safeguards against
victimization of persons who use such mechanism and also provides for direct excess to the Chairman
of the Audit Committee. The details of this Policy are also available on the Company's website;
https://www.steelmantelecom.com/code-policy.php

The Board has, on recommendation of the Nomination and Remuneration Committee framed a policy
for selection and appointment of Directors, Senior Management and their remuneration including
criteria for determining qualifications, positive attributes, independence of Directors and other
matters as per section 178 and Clause 49(IV)(B) of Listing Agreement. The Policy is available on the
website of the Company viz. http://www.steelmantelecom.com./code-policy.php

As per the provisions of SEBI (Listing Obligations and Disclosures Requirements) Regulations, 2015,
(LODR Regulations) the regulations 17-27 of the LODR Regulations pertaining to requirements of
Corporate Governance provisions shall not apply in respect of the following class of Companies:

a) Listed entity having paid up equity share capital not exceeding '10 Crore and Net Worth not
exceeding '25 Crore, as on the last day of the previous Financial Year;

b) Listed entity which has listed its specified securities on the SME Exchange.

Since, our Company falls within the ambit of aforesaid exemption (b); hence compliance with the
provision of Corporate Governance shall not apply to the Company and it does not form part of the
Annual Report for the Financial Year 2024-2025.

The disclosures regarding the above are filed with the BSE on quarterly basis and are also available in
our website http://www.steelmantelecom.com/corporate-governance.php

As per Provision to regulation Rule 4(1) of the companies (Indian Accounting Standards) Rules, 2015
notified vide Notification No. G.S.R 111' (E) on 16th February, 2015, Companies whose shares are
listed on SME exchange as referred to in Chapter XB of SEBI (Issue of Capital and Disclosure
Requirements) Regulations,2009, are exempted from the compulsory requirements of adoption of
IND-AS w.e.f. 1st April, 2017.

As your Company is listed on SME Platform of BSE Limited, is covered under the exempted category
and is not required to comply with IND-AS for preparation of financial statements beginning with
period on or after 1^st April, 2017.

The Managing Director (MD) and Chief Financial Officer (CFO) have issued necessary certificate
pursuant to the provisions of SEBI (Listing Obligations and Disclosure Requirements) Regulation, 2015
certifying that the Financial Statements do not contain any materially untrue statement and these
statements represent a true and fair view of the Company's affairs. The said certificate is annexed and
forms part of the Annual Report.

All Related Party Transactions that were entered into during the Financial Year were on an arm's
length basis, in the ordinary course of business and in compliance with the applicable provisions of
the Companies Act, 2013. All the details regarding related parties are disclosed in the Financial
Statement.

During the Financial Year under review your Company has entered into related party transactions and
the details as per provisions of section 134(3) (h) of the Companies Act, 2013 read with provisions of
rule 8 of the Companies (Accounts) Rules, 2014, are disclosed in Form No.AOC-2 as an Annexure-E.

However, the details of the transactions with Related Party are provided in the Company's financial
statements in accordance with the Accounting Standards.

All the Related Party Transactions entered during the Financial Year under review were presented
before the Audit Committee and the omnibus approval were taken for the transactions repetitive in
nature.

There was no material changes and commitment in the financial position of the Company occurred
between the ends of the financial year to which these financial statements relate and the date of
report.

The information pertaining to conservation of energy, technology absorption, foreign exchange
earnings and outgo as required under Section 134 (3)(m) of the Companies Act, 2013 read with Rule
8(3) of the Companies (Accounts) Rules, 2014 is furnished as follows:

(A) CONSERVATION OF ENERGY:

(i) Steps taken or impact on conservation of energy: Nil

(ii) The steps taken by the company for utilization of alternate sources of energy: Nil

(iii) The Capital Investment on energy conservation equipment: Nil

(B) TECHNOLOGY ABSORPTION:

(i) The efforts made towards technology absorption: Nil

(ii) |The benefits derived like product improvement, cost reduction, product development or import
substitution: Nil

(iii) In case of imported technology (imported during the last three years reckoned from the beginning
of the financial year): NOT APPLICABLE

(iv) The expenditure incurred on Research and Development: Nil

(C) FOREIGN EXCHANGE EARNING & OUTGO
Foreign Exchange Earning: NIL

Foreign Exchange Outgo: NIL

Risk Management is the systematic process of understanding, measuring, controlling and
communicating organization's risk exposures while achieving its objectives. Risk Management is an
important business aspect in the current economic environment and its objective is to identify,
monitor and take mitigation measures on a timely basis in respect of the events that may pose risks
for the business. The Company's risk-management strategy is to identify, assess and mitigate any
significant risks. The company has established processes and guidelines, along with a strong overview
and monitoring framework at the Board and Senior Management levels. The Board of Directors
regularly review risks and threats and takes suitable steps to safeguard its interest and that there is
no element of risk identified that may threaten the existence of the Company. The focus shifts from
one area to another area depending upon the prevailing situation. A detailed report on significant
risks and mitigation is forming part of Management's Discussion and Analysis.

Your company believe that the employees are key contributors to the success of the business. Your
company Focus on attracting and retaining the best possible talent. This attribute helps employees
garner a sense of brotherhood with the management which ultimately produces exemplary results for
the entire organization. Company's manpower is a prudent mix of the experienced and youth which
gives the dual advantage of stability and growth. Entire work processes and skilled, semi-skilled and
unskilled resources together with management team have enabled to implement your company's
growth plans.

Your Company believes that the human resources are a very important part of its strengths and hence
ensures that all facilities like EPFO, ESIC, Leave, Entitlement and other facilities, uniforms, safety
equipment is provided to all staff as applicable. Housing facility is available for outstation employees.

During the year under review, there were no significant material orders passed by the Regulators /
Courts and no litigation was outstanding as on March 31, 2025, which would impact the going concern
status and future operations of your Company. The details of litigation on tax matters are disclosed in
the Auditors' Report and Financial Statements which form part of this Annual Report.

Your Company's zeal to undertake CSR activities in line with the well-laid out CSR policy and
requirements of the Companies Act, 2013, The Board of Directors of your company have approved
CSR initiatives to the value of Rs. 15,40,000/- (Rupees Fifteen Lakhs Forty Thousand Only) as per the
CSR provision created by the Company in the Balance Sheet during the Financial Year 2023-2024,
which is Rs. 1,16,095/- higher than the CSR Obligation of Rs. 14,23,905/- (Fourteen Lakhs Twenty-
Three Thousand Nine Hundred Five Only). The entire amount of Rs. 15,40,000/- was disbursed and
duly utilized for eligible CSR activities under Rule 4(4) of the Companies (CSR Policy) Rules, 2014,
through a government-authorised implementing agency - ANGEL CHARITABLE TRUST. As per the
provisions of the Companies (CSR Policy) Rules, the excess CSR expenditure incurred by the Company
may be set off against the CSR obligation in the succeeding financial years, as permitted under the
law.

The Annual Report on CSR activities, containing details of CSR committee, CSR expenditure, details of
excess amount spent etc; is appended as Annexure-F to this Report.

The Company has, in all material respects, an adequate Internal Financial Controls System over
Financial Reporting and such Internal Financial Controls over Financial Reporting were operating
effectively as at 31^st March, 2025, based on the internal control over financial reporting criteria
established by the Company considering the essential components of internal control stated in the
Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute
of Chartered Accountants Of India.

The Company seeks to promote the highest levels of ethical standards in the normal business
transactions guided by the value system. The SEBI (Listing Obligations and Disclosure Requirements)
Regulations, 2015 mandates formulation of certain policies for listed companies. The Policies are
reviewed periodically by the Board and are updated based on the need and compliance as per the
applicable laws and rules and as amended from time to time. The policies are available on the website
of the Company at http://www.steelmantelecom.com/code-policy.php

• Code of Independent Director with Terms & Conditions of Appointment

• Familiarisation Programme for Independent Directors

• Code of Practice for Disclosure of UPSI

• Policy on Determination of Materiality of Events

• Nomination and Remuneration Committee Policy

• Policy for Preservation of Documents

• Amended RPT Policy

• Vigil Mechanism Policy

• Code of Fair Disclosure

• Anti-Sexual Harassment Policy

• CSR Policy

• Archival Policy

• Debtors Provisioning Policy

• Risk Management policy

• Conflict of Interest Policy

• Anti-Corruption Policy

• Policy for determining Material subsidiaries

• Code of Conduct for All Employees

• Role and Responsibilities of Audit Committee

• Code of Conduct for Directors

• Criteria for making payment to Non-Executive Director

• Role and Responsibilities Stakeholder Relationship and Investor Grievance Committee

• Code of Business Ethics Policy

The Company has adopted a Code of Conduct for Prevention of Insider Trading with a view to regulate
trading in securities by the Directors and designated employees of the Company. The Code requires
pre-clearance for dealing in the Company's shares and prohibits the purchase or sale of Company
shares by the Directors and the 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 Board is responsible for implementation of the Code. All Directors and the designated
employees have confirmed compliances with the Code.

The website of your Company www.steelmantelecom.com, has been designed to present the
Company's businesses up-front on the home page. The site carries a comprehensive database of
information including the Financial Results of your Company, Shareholding pattern, Director's and
Corporate Profile, Corporate Policies and business activities of your Company. All the mandatory
information and disclosures are as per the requirements of the Companies Act, 2013 and Companies
Rules 2014.Company has complied with Clauses(b) to (i) of Regulation 46 (2) relating to dissemination
of information on the website of the Company.

The Management Discussion and Analysis Report under review, as stipulated under SEBI (Listing
Obligations & Disclosure Requirements) Regulations, 2015 is forming part of the Directors' Report.

As required under clause (c) of sub-section (3) of section 134 of the Act, directors, to the best of their
knowledge and belief, 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.

In terms of Section 139 of the Act read with the Companies (Audit and Auditors) Rules, 2014, M/S JAY
GUPTA & ASSOCIATES,CHARTERED ACCOUNTANTS(formerly known as Gupta Agarwal and
Associates), Kolkata (ICAI Firm Registration Number -329001E ) was appointed as the Auditors of your
Company for the term of five(5) Years, beginning from the conclusion of the 19^th Annual General
Meeting of the Company held during the FY-2022-2023 till the conclusion of the Annual General
Meeting of the Company to be held in the Financial Year 2027 -2028 i.e. for the period of five(5) years
from 01.04.2022 to 31.03.2027 on such terms and remuneration as may be mutually agreed upon
between the said Auditors and Board of Directors of the Company.

Auditors have confirmed that they are not disqualified to be appointed as statutory auditors in terms
of the provisions of the proviso to Section 139(1), Section 141(2) and Section 141(3) of the Act and the
provisions of the Companies (Audit and Auditors) Rules, 2014.

The reports given by the Statutory Auditors M/s Jay Gupta and Associates on the Standalone and
Consolidated Financial Statements of your Company for the Financial Year ended March 31, 2025,
form part of this Annual Report and there is no qualification, reservation, adverse remark or disclaimer
given by the Auditors in their Reports. The Auditors of your Company have not reported any fraud in
terms of the second proviso to Section 143(12) of the Act.

There were no qualifications reservations or adverse remarks made by the Auditors in their report.
Further, the observations of the Statutory Auditors, when read together with the relevant notes to
accounts and other accounting policies are self-explanatory and do not call for any further comment.

M/S S. MURARKA & COMPANY., Chartered Accountants (Firm Reg. No. 322627E) at Kolkata, is acting
as Internal Auditors of the Company and has conducted periodic audit of all operations of the
Company. The Audit Committee of the Board of Directors has reviewed the findings of Internal
Auditors regularly.

All the Shares of the Company are held in dematerialised form and all the Company's Shares are
currently traded in dematerialized form, as per the SEBI directives and by virtue of an agreements with
the following Depositories i.e., National Securities Depository Limited (NSDL) and Central Depository
Services (India) Limited (CDSL).

As on 31^st March,2025, total 9676200 Equity Shares are held in dematerialized form and represent
100% of the Company's total paid up capital, out of which 1436400 Equity Shares are in Demat mode
with NSDL and 8239800 equity Shares remains in Demat mode with CDSL.

The Company has in place an Anti-Sexual Harassment Policy in line with the requirements of the Sexual
Harassment of Women at the Workplace (Prevention, Prohibition & Redressal) Act, 2013 to ensure
harassment free workplace for employees. Sexual harassment cases are dealt as per the Company's
Policy on 'Prevention of Sexual Harassment'. Internal Complaints Committee (ICC) has been set up to
redress complaints received regarding sexual harassment. All employees (permanent, contractual,
temporary, trainees) are covered under this policy.

During the Financial Year under review, the Company held meeting of woman employees on
Monday,20^th January 2025 at the registered office of the Company and has not received any
complaints of sexual harassment from any of the woman employee of the Company.

The maintenance of cost records under Section 148(1) of the Companies Act, 2013, and Audit of Cost
Records are not applicable to the Company.

Industrial relations in your Company, during the year under review continued to be cordial and
harmonious.

No case of fraud has been reported by the Auditors under sub-section (12) of Section 143 of the
Companies Act, 2013 read with Rule 13 of the Companies (Audit and Auditors) Rules, 2014.

There are no proceedings pending under the Insolvency and Bankruptcy Code, 2016 during the
Year under review.

The Company is conscious of the importance of environmentally clean and sale operations. The
Company's policy requires the conduct of all operations in such manner so as to ensure safety of
all concerned, compliance of statutory and industrial requirements for environment protection and
conservation of natural resources to the extent possible.

Business Responsibility Report as per Regulation 34(2)(f) of SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015, describing the initiatives taken by them from an environmental,
social and governance perspective is not applicable to the Company, for the Financial Year 2024¬
2025 as per the SEBI Notification dated 22 December, 2015 and Frequently Asked Questions issued
by SEBI on SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 dated 29"
January, 2016.

Your directors state that the Company has complied with the necessary provisions of the revised
Secretarial Standard 1 and Secretarial Standard 2 to the extent applicable to the Company.

The Company has a code of conduct for all its Board members and senior management personnel
which is available on the website of the Company.

http://www.steelmantelecom.com/pdf/Code%20of%20Conduct%20for%20Directors.pdfAll Board
members and Senior Management Personnel (as per Regulation 26(3) of the Listing Regulations)
have affirmed compliance with the applicable Code of Conduct.

No revision of Financial Statements or Board Report was made in respect of any of the three
preceding financial years.

During the year, the Company has fully complied with the mandatory requirements as stipulated
in Listing Agreement and Listing Regulations. The status on the compliance with the discretionary
requirements as specified in Listing Regulations and Part E of Schedule II of Listing Regulations is as
under:

i) Shareholders Rights: The Company has adopted the practice of sending out half-yearly
declaration of financial performance to shareholders. Half Yerly results as approved by the
Board are disseminated to Stock Exchanges and updated on the website of the Company.

ii) Audit Qualifications: There is no audit qualification. Every endeavour is made to make the
financial statements without qualification. The Company's Standalone and Consolidated
Financial Statements for the financial year ended on 31^st March 2025 are with unmodified
audit opinion.

iii) Reporting of Internal Auditors: Reports of Internal Auditors are placed before the Audit
Committee for its review.

iv) The Board: The requirement relating to maintenance of office and reimbursement of
expenses of Non-Executive Chairperson is not applicable to the Company, since the
Chairperson of the Company is an Executive Director.

Results

The Half Yearly Results and the Annual Audited Financial Results of the Company are sent to the
stock exchanges immediately after they are approved by the Board. Also, they are uploaded on the

Company's website www.steelmantelecom.com.The results are published in accordance with the
guidelines of the Stock Exchange.

Website

The Company's website www.steelmantelecom.com contains a separate dedicated section
'Investor Relations' wherein shareholders' information including financial results is available. The
Company's Annual Report is also available in a user- friendly and downloadable form.

Annual Report

The Annual Report containing, inter alia, Audited Financial Statements (standalone and
consolidated), Boards' Report, Auditors' Report and other important information is circulated to
Members and others entitled thereto. The Management's Discussion and Analysis (MD&A) Report
forms part of the Annual Report and is displayed on the Company's website
https://steelmantelecom.com/annual-report.php.

There are no significant events during the Financial Year under review.

In compliance with various MCA Circulars and SEBI Circulars, notice of the AGM along with the
Annual Report 2024-2025 is being sent only through electronic mode to those members whose
email addresses are registered with the Company/RTA/Depositories. Members may note that the
Notice and Annual Report 2024-2025 will also be available on the Company's website at
https://www.steelmantelecom.com/annual-report.php, websites of the Stock Exchange, i.e., BSE
Limited at www.bseindia.com and on the available on the website of NSDL (agency for providing
the Remote e-Voting facility) i.e. www.evoting.nsdl.com

a) The Equity Shares of the Company are listed at the following Stock Exchange: -

BSE Limited (BSE) in SME platform.

Address: Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai-400001.

BSE Scrip Code: 543622
ISIN No: INE0MSK01016

b) Stock Market Price Data (F.Y-2024-2025):

c) Shareholding Pattern as on 31^st March, 2025:

d) Distribution of Shareholding as on 31^st March 2025:

e. Status of Investor Complaints Status of Investor Complaints as on 31^st March, 2025 as reported
under Regulation 13(3) of the Listing Regulations is as under:

f. SEBI Complaints Redress System (SCORES):

The investor complaints are processed in a centralized web based complaints redress system. The
salient features of this system are centralized database of all complaints, online upload of Action
Taken Reports by the concerned companies and online viewing by investors of actions taken on the
complaint and its current status. Your Company has been registered on SCORES and makes every
effort to resolve all investor complaints received through SCORES or otherwise within the statutory
time limit from the receipt of the complaint. The Company has not received any complaint on the
SCORES during Financial Year 2024-2025.

g) Registrar and Share Transfer Agents:

BIGSHARE SERVICES PRIVATE LIMITED

1st Floor, Bharat Tin Works Building, Opp. Vasant Oasis,

Makwana Road, Marol, Andheri East,

Mumbai- 400059, Maharashtra, India
Tel No.: 91 22 6263 8200
Fax No.: 91 22 6263 8299
E-mail: ipo@bigshareonline.com

h) Listing Fees to the Stock Exchange

The Company has paid listing fees up to March 31, 2025, to SME Platform of BSE Limited, where
the Company's shares are listed.

i) Address for Correspondence

j) Financial Calendar

Financial reporting for the 1^st Half Year End 30^th September,2024 - November 14, 2024, and Audited
Results for the year ending March 31, 2025- May 30, 2025.

Your Company remains committed towards its endeavour to minimize its carbon foot prints and
continues to embrace a sustainability initiative with the aim of going green and minimising the

repercussion on the environment. Your Company had already adopted the green initiative by
dispatching the Annual Report, Notices, other communications, etc., through e-mail to its
Shareholders, whose e-mail address are registered with relevant Depository Participants / RTA /
Company. Shareholders are requested to support this initiative by registering / updating their e¬
mail address for receiving Annual Report, Notices, other communications, etc. through e-mail. In
view of the COVID-19 pandemic, the Ministry of Corporate Affairs ('MCA') and the Securities and
Exchange Board of India had issued relaxations from sending printed copy of Annual Report, Notice
of the Annual General Meeting ('AGM'), etc. to the Shareholders for the AGM to be held in the year
2024. With objective of supporting the Green Initiative and in view of the above-mentioned
relaxations, your Company is dispatching the Annual Report & Notice of the AGM along with other
documents required to be annexed thereto to the Shareholders through e-mail at their registered
e-mail address. Such documents are also available on the website of the Company at
www.steelmantelecom.com.in Further, those Shareholders who have not yet registered their e¬
mail address are requested to follow the procedure as mentioned in the Note to the Notice calling
AGM to receive the Annual Report & the Notice of the AGM and other documents relating thereto
through electronic mode and to enable their participation in the AGM.

During the financial year under review,

i. there was no instance of one-time settlement with any Bank or Financial Institution.

ii. The Company has not issued any Equity Shares under ESOP during the year under review.

. Outstanding GDRs/ADRs/Warrants or any Convertible Instruments: The Company has not
issued GDRs/ADRs as on 31^st March, 2025,

Statement in the Annual Report, particularly those which relate to Management Discussion and
Analysis, describing the Company's objectives, projections, estimates and expectations, may
constitute "forward looking statements "within the meaning of applicable laws and regulations.
Although the expectations are based on reasonable assumptions, the actual results might differ.
Details as prescribed under section 134 of the Act and Rules made thereunder, applicable to the
Company, have been specifically given in this Report, wherever applicable.

Your directors place on records their sincere thanks to bankers, business associates, consultants,
and various Government Authorities for their continued support extended to your Company's
activities during the year under review.

Your directors also acknowledge gratefully the shareholders for their support and confidence
reposed on your Company.

Your directors recognize the commitment and contribution of the employees at all levels and look
forward to their increased involvement and dedicated services towards the Company in the
coming years.

BY OREDER OF THE BOARD OF DIRECTOR

FOR STEELMAN TELECOM LIMITED

Formerly known as

(Steelman Telecom Private Limited)

Sd/-

GIRISH BINDAL
(DIN:00484979)

CHAIRMAN

Date:10.07.2025