Welcome to KHL Properties Limited

Code of Conduct

Brief description of the Company's working during the year/State of Company's affair

The company is carrying on the business of income from house property and commission.
Declaration by an Independent Director(s) and re- appointment, if any

A declaration by an Independent Director(s) as prescribed in section 149(7) that they meet the criteria of independence
as provided in sub-section (6) of Section 149 of the Companies Act, 2013 received.
Composition of various committees of board of directors;
Audit Committee

The Audit Committee comprises of the following directors of the company:
1. Mr Umesh Singh, Directors
2. Mr S N Daga, Independent Director
3. Ms Rashmi Bhotika, Independent Director

The Board has accepted all recommendation of the Audit Committee.

Nomination and Remuneration Committee

The Nomination and Remuneration Committee comprises of the following directors of the company:
1. Mr Umesh Singh, Director
2. Mr Dronesh Singhania, Director
3. Mr S N Daga Independent Director
4. Ms Rashmi Bhotika, Independent Director

The policy formulated by nomination and remuneration committee has been accepted by the Board.
Code of conduct of board of directors and senior management personnel;

The Directors' Responsibility Statement referred to in clause (c) of sub-section (3) of Section 134 of theCompanies
Act, 2013, state that-

(a) in the preparation of the annual accounts, the applicable accounting standards has been followed;

(b) the directors selected accounting policies and applied them consistently and made judgments and estimates that are
reasonable and prudent so as to give a true and fair view of the state of affairs of the company at the end of the financial
year and of the profit and loss of the company for that period;

(c) the directors 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 prepared the annual accounts on a going concern basis; and

(e) the directors 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 devised proper systems to ensure compliance with the provisions of all applicable laws and that such systems were
adequate and operating effectively.
Details of establishment of vigil mechanism for directors and employees

The audit committee of the company oversees the vigil mechanism. The vigil mechanism provides all directors and employees to
access audit committee to report their concerns. No complaint is received during the year.
Criteria of making payments to non-executive directors , if the same has not been disclosed in annual report;
Managerial Remuneration:

Disclosure as required in rule 5 of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014

i) The ratio of the remuneration of the directors to the median remuneration of employees is nil. The directors of the company except
WTD are not paid any remuneration except meeting fees.

ii) Details of payment as required in rule 5(2) of the Companies (Appointment and remuneration of Managerial Personnel) Rules, 2014 is nil.

iii) The number of permanent employees on the payroll of the company is 3.

iv) The average increase of remuneration of employees is normal.

v) Whole Time Directors is employed during the year.

vi) The variation in the market capitalization is nil. As there is no change in market quotation of shares of the company during the year, as no
trade in shares took place.

vii) The remuneration has been paid as per remuneration policy of the company.

viii) No employee of the company employed throughout / part of the financial year was paid monthly salary more than Rs.5 lac per month or
Rs.60 lac in aggregate.
Particulars of contracts or arrangements with related parties:

The company has not entered into any contract or arrangement with a related party with respect to items specified in section 188(1) of the
Companies Act, 2013.
Details of Subsidiary/Joint Ventures/Associate Companies

The company does not have any subsidiary / joint venture or associate company.
The email address for grievance redressal and other relevant details;
SHARE TRANSFER AGENTS
Maheshwari Datamatics Private Limited
Corporate Office: 23 R N Mukherjee Road, 5th Floor, Kolkata-700001.
Regd. Office: 6 Mangoe Lane, 2nd Floor, Kolkata-700001.
Email: mdpldc@yahoo.com
Contact information of the designated officials of the listed entity who are responsible for assisting and handling investor
grievances;
Sri Umesh Singh, Director
KHL Properties Limited
8 Bentinck Street, Ground Floor, Kolkata-700001
Ph: 9830290648
Email: sales@usbcosteels.com

Financial information including:

i) Details of notice of quarterly Board meeting and the meeting on which financial results approved:

Qtr	Notice Date	Meeting Date	Meeting Result
1st Qtr	02.08.17	11.08.17	Approved
2nd Qtr	31.10.17	09.11.17	Approved
3rd Qtr	27.01.18	05.02.18	Approved
4th Qtr	27.04.18	05.05.18	Approved

ii) Complete copy of the annual report including balance sheet, profit and loss account, directors report, corporate governance report etc,
approved in the Board meeting dated 30.06.17 for the FY 16-17.

Shareholding pattern;

Quarterly Shareholding pattern received from the Share Transfer Agent, Maheswari Datamatics Pvt Ltd is filed with Calcutta Stock Exchange
in terms of regulation R31.
Details of agreements entered into with the media companies and/or their associates, etc;
NIL.
Analyst or institutional investor meeting and presentations made by the company during the year;
NIL
Change in name of the company;
No change
Items in sub-regulation (1) of regulation 47
In every quarter, the publication in news paper of the notice of Board meeting for approving quarterly financial results and after the meeting of
the Board, the approved quarterly financial results are published. The publication is done in English in Echo of India and in Bengali in Arthik Lipi
of Kolkata news paper.