Home India Securities and Exchange Board of India R.K. STEEL MANUFACTURING COMPANY LIMITED​- Addendum to DRHP...
Date: 2026-03-27 Category: Not Applicable State: Union Government Country: India

R.K. STEEL MANUFACTURING COMPANY LIMITED​- Addendum to DRHP

Issued by Securities and Exchange Board of India · Not Applicable

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THIS IS A PUBLIC ANNOUNCEMENT FOR INFORMATION PURPOSES ONLY. THIS IS NOT A PROSPECTUS ANNOUNCEMENT AND DOES NOT CONSTITUTE AN INVITATION OR OFFER TO ACQUIRE, PURCHASE OR SUBSCRIBE TO SECURITIES. NOT FOR RELEASE, PUBLICATION OR DISTRIBUTION, DIRECTLY OR INDIRECTLY OUTSIDE INDIA. INITIAL PUBLIC OFFERING OF EQUITY SHARES ON THE MAIN BOARD OF THE STOCK EXCHANGES IN COMPLIANCE WITH CHAPTER II OF THE SECURITIES AND EXCHANGE BOARD OF INDIA (ISSUE OF CAPITAL AND DISCLOSURE REQUIREMENTS) REGULATIONS, 2018, AS AMENDED (THE “SEBI ICDR REGULATIONS”) (Please scan the QR Code to view this Addendum cum corrigendum) PUBLIC ANNOUNCEMENT R.K. STEEL MANUFACTURING COMPANY LIMITED Our Company was originally incorporated as ‘R.K. Steel Manufacturing Company Private Limited’, a private limited company under the Companies Act, 1956, pursuant to a certificate of incorporation dated April 17, 2006, issued by the Registrar of Companies, Tamil Nadu. Upon the conversion of our company into a public limited company, pursuant to a resolution passed by our Board of Directors dated November 30, 2023 and resolution dated December 22, 2023 passed by the shareholders, the name of our company changed to R.K. Steel Manufacturing Company Limited and a fresh certificate of incorporation dated January 9, 2024 was issued by the Registrar of Companies, Central Processing Centre. Corporate Identity Number: U24106TN2006PLC059519 Registered Office: No.5, Ground Floor, Branson Garden Street, Kilpauk, Perambur Purasawalkam, Chennai – 600 010, Tamil Nadu, India Contact Person: S N Satiya Priya, Company Secretary and Compliance Officer; Telephone: +044 3500 5351 E-mail: compliance.officer@rksteel.co.in; Website: www.rksteel.co.in NOTICE TO INVESTORS: ADDENDUM CUM CORRIGENDUM TO THE DRAFT RED HERRING PROSPECTUS DATED SEPTEMBER 30, 2025 (“THE ADDENDUM CUM CORRIGENDUM”) INITIAL PUBLIC OFFERING OF UP TO 2,00,00,000 EQUITY SHARES OF FACE VALUE OF ₹10 EACH (“EQUITY SHARES”) OF R.K. STEEL MANUFACTURING COMPANY LIMITED (THE “COMPANY” OR THE “ISSUER”) FOR CASH AT A PRICE OF ₹ [●] PER EQUITY SHARE (INCLUDING A SHARE PREMIUM OF ₹ [●] PER EQUITY SHARE) (“ISSUE PRICE”) AGGREGATING UP TO ₹ [●] LAKHS (THE “ISSUE”). THE ISSUE SHALL CONSTITUTE [●]% OF THE POST-ISSUE PAID UP EQUITY SHARE CAPITAL. THE FACE VALUE OF THE EQUITY SHARES IS ₹10 EACH AND THE ISSUE PRICE IS [●] TIMES THE FACE VALUE OF THE EQUITY SHARES. THE PRICE BAND AND THE MINIMUM BID LOT WILL BE DECIDED BY OUR COMPANY IN CONSULTATION WITH THE BOOK RUNNING LEAD MANAGER AND WILL BE ADVERTISED IN ALL EDITIONS OF [●] (A WIDELY CIRCULATED ENGLISH NATIONAL DAILY NEWSPAPER), [●] EDITIONS OF [●] (A WIDELY CIRCULATED HINDI NATIONAL DAILY NEWSPAPER), AND [●] EDITIONS OF [●] (A WIDELY CIRCULATED TAMIL DAILY NEWSPAPER, TAMIL BEING THE REGIONAL LANGUAGE OF TAMIL NADU, WHERE OUR REGISTERED OFFICE IS LOCATED), AT LEAST 2 (TWO) WORKING DAYS PRIOR TO THE BID/ISSUE OPENING DATE, AND SHALL BE MADE AVAILABLE TO THE STOCK EXCHANGES FOR THE PURPOSE OF UPLOADING ON THEIR RESPECTIVE WEBSITES IN ACCORDANCE WITH THE SEBI ICDR REGULATIONS. This Addendum cum Corrigendum is in reference to the Draft Red Herring Prospectus filed with SEBI and the Stock Exchanges in relation to the Offer. Potential Bidders may note the following: 1. The chapter entitled “Outstanding Litigation and Material Developments” beginning on page 392 of the Draft Red Herring Prospectus has been updated to include the action taken by regulatory authority against the Company. 2. To reflect the action taken by regulatory authority against the Company, included through this Addendum cum Corrigendum, the chapters titled “Summary of the Issue Document”, “Risk Factor”, and "Our Business" beginning on pages 27, 37 and 203 respectively has been suitably updated to include updated information. 3. The chapter entitled “Outstanding Litigation and Material Developments” beginning on pages 392 of the Draft Red Herring Prospectus has been updated as there has been development in the legal proceedings involving our Company. Potential Bidders may note that in order to assist Bidders to obtain a complete understanding of the updated information, the updated relevant portions of the sections titled “Summary of the Issue Document”, “Risk Factor”, and "Our Business" and "Outstanding Litigation and Material Developments" have been included in this Addendum cum corrigendum. The above changes are to be read in conjunction with the Draft Red Herring Prospectus and accordingly their references in the Draft Red Herring Prospectus stand updated pursuant to this Addendum cum corrigendum. All updated information forming part of this Addendum cum Corrigendum will be suitably incorporated, as may be applicable, in the Red Herring Prospectus and the Prospectus, as and when filed with the Registrar of Companies, the Securities and Exchange Board of India and the Stock Exchanges. However, potential Bidders must note that this Addendum cum Corrigendum does not reflect all the changes that have occurred between the date of filing of the Draft Red Herring Prospectus and the date hereof, and accordingly does not include all the changes and/or updates that will be included in the Red Herring Prospectus and the Prospectus. potential Bidders should read the Red Herring Prospectus as and when filed with the RoC, the SEBI, and the Stock Exchanges before making an investment decision in the Offer. All capitalised terms used in this Addendum cum Corrigendum shall, unless the context otherwise requires, have the meaning ascribed to them in the Draft Red Herring Prospectus. The Equity Shares offered in the Offer have not been and will not be registered under the U.S. Securities Act or any state securities laws in the United States, and unless so registered, may not be offered or sold within the United States, except pursuant to an exemption from, or in a transaction not subject to, the registration requirements of the U.S. Securities Act and in accordance with any applicable U.S. state securities laws. Accordingly, the Equity Shares are being offered and sold outside the United States in ‘offshore transactions’ in reliance on Regulation S under the U.S. Securities Act and the applicable laws of the jurisdictions where such offers and sales are made. This Addendum cum Corrigendum which has been filed with SEBI and the Stock Exchanges shall be made available to the public for comments, if any, for a period of at least 21 days, from the date of such filing with SEBI and will be available on SEBI’s website at www.sebi.gov.in, the websites of the Stock Exchanges at www.bseindia.com and www.nseindia.com , the website of the Company at www.rksteel.co.in, and the websites of Book Running Lead Manager GYR Capital Advisors Private Limited at www.gyrcapitaladvisors.com Place: Chennai For and on behalf of R. K. Steel Manufacturing Company Limited Date: March 27, 2026 Sd/- Pramod Kumar Bhalotia Chairman and Managing Director BOOK RUNNING LEAD MANAGER REGISTRAR TO THE ISSUE GYR CAPITAL ADVISORS PRIVATE LIMITED MUFG INTIME INDIA PRIVATE LIMITED 428, Gala Empire, Near JB Tower, Drive in Road (formerly known as Link Intime India Private Limited) Thaltej, Ahmedabad – 380 054, Gujarat, India C-101, 1st Floor, 247 Park, Lal Bhadur Shastri Marg Telephone: +91 87775 64648 Vikhroli (West), Mumbai 400 083, Maharashtra, India Fax: N.A. Telephone: +91 81081 14949 E-mail: rksteel.ipo@gyrcapitaladvisors.in Email: rksteel.ipo@linkintime.co.inWebsite: www.gyrcapitaladvisors.com Website: www.linkintime.co.in Investor grievance: investors@gyrcapitaladvisors.com Investor Grievance Email: rksteel.ipo@linkintime.co.in Contact Person: Mohit Baid Contact Person: Shanti Gopalkrishnan SEBI Registration Number: INM000012810 SEBI Registration Number: INR000004058 BID/ISSUE PROGRAMME BID/OFFER OPENS ON [●]* BID/OFFER CLOSES ON [●]**^ *Our Company may in consultation with the BRLM, consider participation by Anchor Investors in accordance with the SEBI ICDR Regulations. The Anchor Investor Bidding Date shall be one Working Day prior to the Bid/Offer Opening Date. **Our Company may in consultation with the BRLMs consider closing the Bid/Offer Period for QIBs 1(one) Working Day prior to the Bid/ Offer Closing Date in accordance with the SEBI ICDR Regulations. ^The UPI mandate end time and date shall be at 5:00 p.m. on Bid/Offer Closing Date. R. K. Steel Manufacturing Company Limited is proposing, subject to applicable statutory and regulatory requirements, receipt of requisite approvals, market conditions and other considerations, to undertake an initial public offering of its Equity Shares and has filed the DRHP with SEBI. The DRHP shall be available on the website of SEBI at www.sebi.gov.in, Stock Exchanges i.e., BSE at www.bseindia.com and NSE at www.nseindia.com, is available on the website of the Company at www.rksteel.co.in and the website of BRLM, i.e. GYR Capital Advisors Private Limited at www.gyrcapitaladvisors.com. Bidders should note that investment in equity shares involves a high degree of risk and for details relating to such risk, see the section titled “Risk Factors” beginning on page 37 of the DRHP. Potential Bidders should not rely on the DRHP filed with SEBI for making any investment decision. The Equity Shares have not been and will not be registered under the U.S. Securities Act of 1933, as amended (the "U.S. Securities Act"), and may not be offered or sold within the United States except pursuant to an exemption from, or in a transaction not subject to, the registration requirements of the U.S. Securities Act and applicable U.S. state securities laws. Accordingly, the Equity Shares are only being offered and sold outside the United States in offshore transactions in reliance on Regulation S and the applicable laws of the jurisdiction where those offers and sales occur.TABLE OF CONTENTS DEFINITIONS AND ABBREVIATIONS ...................................................................................... 4 SUMMARY OF THE ISSUE DOCUMENT .................................................................................. 5 SECTION II – RISK FACTORS .................................................................................................... 6 OUR BUSINESS ............................................................................................................................. 10 OUTSTANDING LITIGATION AND MATERIAL DEVELOPMENTS ................................ 11 DECLARATION ............................................................................................................................ 12DEFINITIONS AND ABBREVIATIONS Company Related Terms Term Description “Addendum Cum Corrigendum” This addendum cum corrigendum dated [●], 2026 to the Draft Red Herring Prospectus and filed with SEBI and the Stock Exchanges in relation to the Issue.SUMMARY OF THE ISSUE DOCUMENT The disclosures in the section “Summary of the Issue Document – Summary of outstanding litigation” on page 30 of the Draft Red Herring Prospectus shall be read with the following additional disclosures. Summary of outstanding litigation Nature of Cases Number of Amount Involved outstanding cases (₹ in lakhs)* Litigation involving our Company Criminal proceedings against our Company 1 Not ascertainable Criminal proceedings by our Company Nil Nil Material civil litigation against our Company Nil Nil Material civil litigation by our Company 3 65.95 Actions by statutory or regulatory Authorities Nil Nil Direct and indirect tax proceedings 17 4.81 Litigation involving our Directors (other than Promoters) Criminal proceedings against our Directors Nil Nil Criminal proceedings by our Directors Nil Nil Material civil litigation against our Director Nil Nil Material civil litigation by our Director Nil Nil Actions by statutory or regulatory authorities Nil Nil Direct and indirect tax proceedings Nil Nil Litigation involving our Promoters Criminal proceedings against our Promoters Nil Nil Criminal proceedings by our Promoters Nil Nil Material civil litigation against our Promoters 1 Not ascertainable Material civil litigation by our Promoters Nil Nil Actions by statutory or regulatory authorities Nil Nil Direct and indirect tax proceedings 7 0.87 Litigation involving our KMPs and SMPs Criminal proceedings against our KMPs and SMPs Nil Nil Criminal proceedings by our KMPs and SMPs Nil Nil Actions by statutory or regulatory authorities Nil Nil Direct and indirect tax proceedings Nil Nil *To the extent quantifiable.SECTION II – RISK FACTORS The below set Risk Factors as appearing in the section titled “Risk Factors” on page 37 of the Draft Red Herring Prospectus shall be replaced with updated Risk Factors as mentioned below: 4. We operate from a single manufacturing facility located at Perundurai, Tamil Nadu, India and any disruption at this facility could adversely affect our operations, business and financial condition. Our integrated manufacturing facility, located at Plot NN5, SIPCOT Industrial Growth Centre, Ingur Village, Perundurai 638 052, Tamil Nadu, is the sole production site for our operations. As on date, this facility houses nine (9) Tube Mills, four (4) Slitting Lines, two (2) Continuous Galvanizing Lines one (1) Tandem Cold Rolling Mill (“CRM”), one (1) Pickling Unit and one (1) Hot Dip Galvanizing Unit. We do not maintain any alternate or backup production facilities. Consequently, our operations and supply obligations are entirely dependent on uninterrupted functioning of this single site. Any disruption, whether temporary or prolonged, could materially and adversely impact our production schedules, business continuity, customer relationships, financial condition and results of operations. Disruptions may arise from a wide range of factors including natural disasters (such as earthquakes, floods, or cyclones), fires, power outages, equipment breakdowns, unavailability of raw materials, accidents, or other operational hazards. Additionally, risks such as labour unrest, strikes, adverse regulatory actions, or revocation of environmental or operational permits could also lead to suspension of activities at this site. Any halt in manufacturing operations may result in delays in fulfilling customer orders, cancellation of orders, inability to meet contractual delivery schedules, and consequent loss of revenue. Customers may turn to alternative suppliers, adversely impacting our market reputation and competitiveness. Furthermore, a disruption at our facility could lead to idle labor and fixed overheads without corresponding revenues, thereby exerting pressure on our margins and working capital. While we maintain insurance coverage for against risks such as fire and machinery breakdown, such insurance may not cover all possible losses or consequential damages. Recovery under these policies may also be subject to deductibles, policy limits, and time delays. The ability to restart operations after a major disruption would depend on multiple external and internal factors such as availability of skilled workforce, restoration of utilities, procurement of critical spare parts or machinery, and requisite regulatory approvals. Any delays in these aspects may prolong production downtime. The Company has, during the last three fiscal years, received a show cause notice from the Tamil Nadu Pollution Control Board in relation to the alleged discharge of untreated industrial trade effluent. Pursuant to such notice, the Company faced a temporary shutdown of its factory operations and disconnection of power supply. The Company has subsequently paid the requisite penalty and, as of the date of filing of the Draft Red Herring Prospectus, the factory operations have resumed and are continuing. For further details, please refer to “Outstanding Litigation and Material Developments” on page 392 of the Draft Red Herring Prospectus. However, we cannot assure you that similar incidents, regulatory actions, penalties, or disruptions will not occur in the future. Any recurrence of such events may adversely affect our business, financial condition, results of operations, and reputation. 13. We operate in a hazardous industry and are subject to business and operational risks arising from the manufacture, usage, and storage of hazardous substances, which could adversely affect our business, results of operations, financial condition, and reputation. Our operations involve processes that are inherently hazardous, including the manufacture, handling, processing, storage, and transportation of hazardous material such as Spent Acid, Sludge and high TDS Salts. In addition, our employees operate heavy machinery at our manufacturing facility, which exposes them to risks of accidents, equipment failure, fire, or explosions. These hazards could result in personal injury or loss of life, severe damage to property and equipment, environmental contamination, suspension of operations, and the imposition of civil and criminal liabilities.Although we adopt safety and security measures and maintain insurance coverage that we believe to be adequate for certain risks, there can be no assurance that such measures will be sufficient to prevent accidents or mitigate their consequences. Any significant workplace accident, fire, explosion, or related incident could cause: (i) injury or loss of life to employees or third parties; (ii) damage to or destruction of plant, machinery, or inventory; (iii) disruption or suspension of operations; (iv) manufacturing or delivery delays impacting our ability to meet customer commitments; (v) imposition of regulatory penalties, civil liabilities, or criminal sanctions; and (vi) reputational damage that may impact customer and supplier relationships. The Company has, during the last three fiscal years, specifically in Fiscal 2025, received directions from the Tamil Nadu Pollution Control Board (“TNPCB”) under the Water (Prevention and Control of Pollution) Act, 1974, in relation to the alleged discharge of untreated industrial trade effluent at our Perundurai facility. Pursuant to such proceedings, the Company faced a temporary suspension of its factory operations and disconnection of power supply. The Company has subsequently paid the requisite environmental compensation of ₹27.00 lakhs and, following the suspension of the closure order by the TNPCB in June 2025, the factory operations have resumed and are continuing. Additionally, a First Information Report (“FIR”) has been registered in relation to this incident, which the Company is currently contesting. However, we cannot assure you that similar incidents, regulatory actions, penalties, or disruptions will not occur in the future. Any recurrence of such events may adversely affect our business, financial condition, results of operations, and reputation. For further details, please refer to the section titled “Outstanding Litigation and Material Developments” on page 392 of this Draft Red Herring Prospectus. However, Additionally, our hazardous waste authorization has expired. Althouth our Company has made an application on August 23, 2025, we are yet to receive a copy of the authorization. For details of such application and risk in relation to non-receipt of the said approval, see “Government and Other Statutory Approvals – Material approvals or renewals for which applications are currently pending before relevant authorities” and “Risk Factors – We require certain approvals and licenses in the ordinary course of business and are required to comply with certain rules and regulations to operate our business, any failure to obtain, retain and renew such approvals and licences or comply with such rules and regulations may adversely affect our operations” on pages 402 and 62. This could materially and adversely affect our business, reputation, financial condition, results of operations, cash flows, and prospects. 31. Any disruption or shortage of essential utilities such as power, fuel, or water could disrupt our manufacturing operations, increase our production costs, and adversely affect our results of operations and financial condition. Our manufacturing operations require a continuous supply of power, fuel, and water, which represent a key component of our production costs. We meet part of our power requirement through a captive 5.5 MW solar power plant and also source electricity from the state electricity board. In addition, we have adopted CBG”) as a replacement for conventional furnace oil in our production process, and our water requirements are met through SIPCOT’s supply. Set out below is the detail of our power, water, and fuel charges; Particulars Fiscal 2025 Fiscal 2024 Fiscal 2023 Amount (₹ % of Amount (₹ % of Amount (₹ % of in lakhs) total in lakhs) total in lakhs) total expense expense expense Power, Water 948.96 0.83% 847.38 0.85% 758.79 0.91% and Fuel Charges Our reliance on external sources of power and utilities exposes us to risks of rising costs and supply disruptions. If our power, water, or fuel costs continue to rise, or if our electricity supply arrangements are disrupted, our operations could be adversely impacted. For instance, any increase in the per-unit cost of electricity by the state electricity board would increase our overall production costs. Inadequateor irregular supply of electricity or fuel could result in the interruption or suspension of production, leading to delays in meeting customer commitments and potential order cancellations. Frequent production shutdowns due to utility shortages would also increase costs associated with restarting production, result in lower capacity utilization, and lead to revenue loss. In particular, any significant increase in the cost of electricity could cause an unexpected rise in production costs, putting additional pressure on our already thin margins. The Company has experienced an instance of power disconnection during the last three fiscals and there can be no assurance that similar interruptions will not recur in the future due to unforeseen events, regulatory changes, grid instability, or supply-side constraints. Any prolonged or recurring disruption, shortage, or interruption in the availability of essential utilities may have a material adverse effect on our business operations, results of operations, cash flows, profitability, and overall financial condition. 19. Our Company, Promoters and Directors are parties to certain legal proceedings. Any adverse decision in such proceedings may have a material adverse effect on our business, results of operations and financial condition. Our Company, Promoters and Director are parties to certain legal proceedings. These legal proceedings are pending at different stages before various courts, tribunals and forums. The outcomes of these legal proceedings are uncertain and could lead to adverse orders against our Company, Promoters and Directors. Legal expenses, regulatory challenges, and potential sanctions arising from these proceedings may put a strain on our financial resources and impact our profitability. In the event of adverse rulings in these proceedings or levy of penalties / fines by courts, tribunals and forums, our Company may need to make payments or make provisions for future payments. Furthermore, adverse publicity and negative perceptions associated with criminal litigations can affect our reputation, leading to potential loss of customer trust and business opportunities. It may also impact our ability to secure contracts, licenses, or permits required for our operations. A summary of the pending criminal and tax proceedings and other material litigations involving our Company, Directors and Promoters has been provided below: Nature of Cases Number of Amount Involved outstanding cases (₹ in lakhs)* Litigation involving our Company Criminal proceedings against our Company 1 Not ascertainable Criminal proceedings by our Company Nil Nil Material civil litigation against our Nil Nil Company Material civil litigation by our Company 3 65.95 Actions by statutory or regulatory Nil Nil Authorities Direct and indirect tax proceedings 17 4.81 Litigation involving our Directors (other than Promoters) Criminal proceedings against our Directors Nil Nil Criminal proceedings by our Directors Nil Nil Material civil litigation against our Director Nil Nil Material civil litigation by our Director Nil Nil Actions by statutory or regulatory authorities Nil Nil Direct and indirect tax proceedings Nil Nil Litigation involving our Promoters Criminal proceedings against our Promoters Nil Nil Criminal proceedings by our Promoters Nil Nil Material civil litigation against our 1 Not ascertainable Promoters Material civil litigation by our Promoters Nil NilNature of Cases Number of Amount Involved outstanding cases (₹ in lakhs)* Actions by statutory or regulatory authorities Nil Nil Direct and indirect tax proceedings 7 0.87 Litigation involving our KMPs and SMPs Criminal proceedings against our KMPs and Nil Nil SMPs Criminal proceedings by our KMPs and Nil Nil SMPs Actions by statutory or regulatory authorities Nil Nil Direct and indirect tax proceedings Nil Nil *To the extent quantifiable. We cannot assure that any of the aforementioned litigations will be settled in our favour, or that no further liability will arise out of these proceedings. Even if we are successful in defending such cases, we will be subjected to legal and other costs relating to defending such litigation, and such costs could be substantial. The amounts claimed in these proceedings have been disclosed to the extent ascertainable. All of the above ongoing matters could result in financial losses, reputational damage, and disruptions to our Company’s business operations, in the event any adverse orders are passed against our Company/directors. While we have not incurred any material penalties / fines due to any adverse rulings during the last three Fiscals, such payments or provisions may increase our expenses and current or contingent liabilities and also, adversely affect our reputation, business, financial condition and results of operation in future.OUR BUSINESS In the section titled “Our Business” on page 203 of the Draft Red Herring Prospectus the following paragraphs shall stand replaced in the manner set out below. Our Manufacturing Facility has effluent treatment processes in compliance with applicable law. However, in past, we have been subject to legal action and penalty involving non-compliance with environmental laws and regulations. For details, see “Risk Factors – We operate from a single manufacturing facility located at Perundurai, Tamil Nadu, India and any disruption at this facility could adversely affect our operations, business and financial condition.” and “Risk Factors – We operate in a hazardous industry and are subject to business and operational risks arising from the manufacture, usage, and storage of hazardous substances, which could adversely affect our business, results of operations, financial condition, and reputation.” on pages 41 and 48, respectively.OUTSTANDING LITIGATION AND MATERIAL DEVELOPMENTS In the section “Outstanding Litigation and Material Developments” on page 392 of the Draft Red Herring Prospectus shall be updated to reflect the inclusion of the below set disclosures. I. Litigation involving our Company A. Litigation filed against our Company. 1. Criminal proceedings First Information Report – 144 of 2025 The First Information Report bearing number 144 of 2025 was registered at the Chithode Police Station on March 22, 2025, primarily based on a complaint alleging the deliberate contamination of a public water source, an offence punishable under Section 279 of the Bharatiya Nyaya Sanhita, 2023. The complaint was filed by Mr. S. Sivakumar after residents of Kolathupalayam village reported on March 19, 2025, that a local stream had turned yellow, was emitting a foul smell, and contained dead fish. A subsequent preliminary investigation uncovered crucial evidence, including CCTV footage from a nearby restaurant which allegedly captured a tanker lorry with registration number TN-52-Y-7104 discharging waste into the stream on the night of March 18, 2025. The driver of the lorry Nagaraj, was identified and stated that the vehicle belonged to Evergreen Chemical Company and that industrial effluent he discharged had been collected from the R.K. Steel Manufacturing Company Limited in Perundurai. Therefore, the FIR was filed on the basis of the physical evidence of pollution, the identification of the vehicle and driver, and the driver's statement naming R.K. Steel Manufacturing Company Limited as the source of the contaminating effluent. The matter is currently pending as on date.DECLARATION I hereby certify and declare that all relevant provisions of the Companies Act and the rules, guidelines or regulations issued by the Government of India and the rules, guidelines or regulations issued by SEBI, established under Section 3 of the SEBI Act, as the case may be, have been complied with and no statement made in this Addendum is contrary to the provisions of the Companies Act, the SCRA, the SCRR, the SEBI Act, each as amended or rules made or guidelines or regulations notified thereunder, as the case may be. I further certify that all statements, disclosures and undertakings made in this Addendum are true and correct. S/d Pramod Kumar Bhalotia Managing Director DIN: 01115735 Date: March 27, 2026 Place: Chennai, Tamil Nadu, IndiaDECLARATION I hereby certify and declare that all relevant provisions of the Companies Act and the rules, guidelines or regulations issued by the Government of India and the rules, guidelines or regulations issued by SEBI, established under Section 3 of the SEBI Act, as the case may be, have been complied with and no statement made in this Addendum is contrary to the provisions of the Companies Act, the SCRA, the SCRR, the SEBI Act, each as amended or rules made or guidelines or regulations notified thereunder, as the case may be. I further certify that all statements, disclosures and undertakings made in this Addendum are true and correct. S/d Abhishek Bhlotia Whole-time Director DIN: 07624387 Date: March 27, 2026 Place: Chennai, Tamil Nadu, IndiaDECLARATION I hereby certify and declare that all relevant provisions of the Companies Act and the rules, guidelines or regulations issued by the Government of India and the rules, guidelines or regulations issued by SEBI, established under Section 3 of the SEBI Act, as the case may be, have been complied with and no statement made in this Addendum is contrary to the provisions of the Companies Act, the SCRA, the SCRR, the SEBI Act, each as amended or rules made or guidelines or regulations notified thereunder, as the case may be. I further certify that all statements, disclosures and undertakings made in this Addendum are true and correct. S/d Beena Bhalotia Non-Executive Director DIN: 02678849 Date: March 27, 2026 Place: Chennai, Tamil Nadu, IndiaDECLARATION I hereby certify and declare that all relevant provisions of the Companies Act and the rules, guidelines or regulations issued by the Government of India and the rules, guidelines or regulations issued by SEBI, established under Section 3 of the SEBI Act, as the case may be, have been complied with and no statement made in this Addendum is contrary to the provisions of the Companies Act, the SCRA, the SCRR, the SEBI Act, each as amended or rules made or guidelines or regulations notified thereunder, as the case may be. I further certify that all statements, disclosures and undertakings made in this Addendum are true and correct. S/d Saimathy Soupramanien Independent Director DIN: 07657046 Date: March 27, 2026 Place: Chennai, Tamil Nadu, IndiaDECLARATION I hereby certify and declare that all relevant provisions of the Companies Act and the rules, guidelines or regulations issued by the Government of India and the rules, guidelines or regulations issued by SEBI, established under Section 3 of the SEBI Act, as the case may be, have been complied with and no statement made in this Addendum is contrary to the provisions of the Companies Act, the SCRA, the SCRR, the SEBI Act, each as amended or rules made or guidelines or regulations notified thereunder, as the case may be. I further certify that all statements, disclosures and undertakings made in this Addendum are true and correct. S/d C Rajendran Independent Director DIN: 10345090 Date: March 27, 2026 Place: Chennai, Tamil Nadu, IndiaDECLARATION I hereby certify and declare that all relevant provisions of the Companies Act and the rules, guidelines or regulations issued by the Government of India and the rules, guidelines or regulations issued by SEBI, established under Section 3 of the SEBI Act, as the case may be, have been complied with and no statement made in this Addendum is contrary to the provisions of the Companies Act, the SCRA, the SCRR, the SEBI Act, each as amended or rules made or guidelines or regulations notified thereunder, as the case may be. I further certify that all statements, disclosures and undertakings made in this Addendum are true and correct. S/d S. Krishnamachari Independent Director DIN: 10698035 Date: March 27, 2026 Place: Chennai, Tamil Nadu, IndiaDECLARATION I hereby certify and declare that all relevant provisions of the Companies Act and the rules, guidelines or regulations issued by the Government of India and the rules, guidelines or regulations issued by SEBI, established under Section 3 of the SEBI Act, as the case may be, have been complied with and no statement made in this Addendum is contrary to the provisions of the Companies Act, the SCRA, the SCRR, the SEBI Act, each as amended or rules made or guidelines or regulations notified thereunder, as the case may be. I further certify that all statements, disclosures and undertakings made in this Addendum are true and correct. S/d Sanjay Bhalotia Chief Financial Officer Date: March 27, 2026 Place: Chennai, Tamil Nadu, India

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