DIRECTORS' REPORT

The Directors have the pleasure of presenting the Third (3^rd) Annual Report of your Company
together with the Audited Financial Statement for the year ended 31 March, 2026.

FINANCIAL SUMMARY AND HIGHLIGHTS

The Company's financial performance for the year ended on 31 March, 2026 is summarized
below:

The Company reports rise in the revenue from operations of ^ 8962.72 lacs as compared
to the previous year of ^ 5737.62 lacs. After providing for interest, depreciation and taxes,
the net profit for the year stood at ^ 966.75 lacs as compared to ^ 679.35 lacs in the
previous year. EPS for the year was ^ 9.03 per share as compared to ^ 8.48 per share in
the previous year. Detailed working on operation of the Company is provided in the
management discussion and analysis report as forms part of this.

MATERIAL EVENT - LISTING ON STOCK EXCHANGES

The Company marked a monumental milestone in the history of the Company with
the successful completion of its Initial Public Offering (IPO). The issue garnered
overwhelming market response, achieving an overall subscription of 7.67 times across
all investor categories.

To unlock the benefits of public listing, enhance corporate brand equity, and establish
a robust public market for its equity shares in India, the Company successfully listed its
shares on the stock exchange. The capital raise comprised a fresh issue of 29,46,000
equity shares of face value of ^ 10/- each, aggregating to ^ 2,975.46 Lacs.

The equity shares of the Company were officially listed and commenced trading on
the SME platform of the National Stock Exchange of India Limited (NSE Emerge) on
21 May, 2025.

THE STATE OF COMPANY'S AFFAIRS

The Company is a rapidly emerging Indian Contract Development and Manufacturing
Organization (CDMO), dedicated to manufacturing and marketing high-quality
pharmaceutical formulations. Powered by a vision to deliver healthcare solutions that
adhere to stringent international quality standards at competitive price points, the
Company has established a robust domestic market presence and continues to
strategically expand its global footprint.

Our comprehensive product portfolio spans a diverse range of therapeutic segments
and dosage forms, classified under the following core categories - Tablets, Capsules,
Oral Liquid, Oral Powder (Sachet, Dry Syrup) and External Preparations (Ointment, Cream,
Gel, Lotion, Medicated Shampoo, Mouthwash, Dusting Powder).

MANAGEMENT DISCUSSION AND ANALYSIS (MDA)

The Management Discussion and Analysis Report providing the detailed overview of
the Company's performance, industry trends, business and risks involved has been
provided separately and forms part of this report.

DIVIDEND

The Company has consistently pursued a path of expansion to drive long term growth. In
line with the need to conserve the Company's resources, the Board of Directors has not
recommended any dividend for the financial year ended 31 March, 2026.

TRANSFER TO GENERAL RESERVES

The Board of Directors has decided not to transfer any amount to the General Reserves for
the year under review.

SHARE CAPITAL
Authorised Share Capital:

y As on 31 March, 2026, the Authorised Share Capital of the Company is ^ 13,00,00,000/-
consisting 1,30,00,000 equity shares of ^ 10/- each.

Paid up Share Capital:

y As on 1 April, 2025, the Paid-Up Capital of the Company is ? 8,17,00,000/- consisting

81.70.000 equity shares of ? 10/- each fully paid-up.

y The Paid-Up Capital of the Company was increased from ^ 8,17,00,000/- to ^ 11,11,60,000/-
due to allotment of 29,46,000 equity shares of ^ 10/- each to public pursuant fresh
issue IPO dated 19 May, 2025.

y As on 31 March, 2026, the Paid-Up Capital of the Company is ^ 11,11,60,000/- consisting

1.11.16.000 equity shares of ^ 10/- each fully paid-up.

DETAILS OF SUBSIDIARY / JOINT VENTURES / ASSOCIATE COMPANIES

As on 31 March, 2026, the Company does not have any Subsidiaries, Joint Venture and
Associate Companies. Therefore, pursuant to the provisions of Section 129(3) of the
Companies Act, 2013, the statement containing salient features of the financial
statements of subsidiaries or associate companies or Joint ventures in Form AOC-1 is
not required.

PARTICULARS OF LOANS, GUARANTEES OR INVESTMENTS UNDER SECTION 186

During the year under review, the Company has not given any loan, not provided guarantee
or security and not made any investment under the provisions of section 186 of the
Companies Act, 2013.

PARTICULARS OF CONTRACTS OR ARRANGEMENTS WITH RELATED PARTIES

All Related Party Transactions entered during the financial year 2025-26 were in
compliance to the provisions of law and were entered with the approval of Audit
Committee, Board and Shareholders, wherever applicable. All related party transactions
executed during the financial year were on arm's length basis, ordinary course of
business and in accordance with the provisions of the Act and the rules made
thereunder, the SEBI Listing Regulations and your Company's Policy on Related Party
Transactions. Further, there were no related party transactions which could be
considered material based on the definition of material transaction as mentioned
under Regulation 23 of the SEBI Listing Regulations. Accordingly, the disclosure in Form
AOC-2 pursuant to compliance of Section 134(3)(h) of the Companies Act, 2013 and Rule
8(2) of the Companies (Accounts) Rules, 2014 is not applicable to the Company for
2025-26 and hence does not form part of this report.

Your Company did not enter into any related party transactions during the year under
review, which could be prejudicial to the interest of minority shareholder.

The disclosures as required are provided in accounting standard in relation to
transactions with related parties which are forming the part of the notes to Financial
Statements. The policy on Related Party Transaction is available on the website of the
Company www.accretionpharma.com.

DEPOSITS

The Company has neither accepted nor renewed any deposits from the public within
the meaning of Section 73 of the Companies Act, 2013 read with the Companies
(Acceptance of Deposits) Rules, 2014 during the year under review.

MATERIAL CHANGES AND COMMITMENTS, IF ANY, AFFECTING THE FINANCIAL POSITION OF
THE COMPANY WHICH HAVE OCCURRED BETWEEN THE END OF THE FINANCIAL YEAR OF THE
COMPANY TO WHICH THE FINANCIAL STATEMENTS RELATE AND THE DATE OF THE REPORT

There is no change taken place which affect the financial position of the Company
between the end of the financial year of the Company to which the Financial Statements
relate and the date of the report during the year under review.

CHANGE IN THE NATURE OF BUSINESS, IF ANY

There is no change in the nature of the business of the Company.

CONSERVATION OF ENERGY, TECHNOLOGY ABSORPTION AND FOREIGN EXCHANGE
EARNINGS AND OUTGO

A statement containing information on Conservation of energy, Technology absorption
and foreign exchange earnings and outgo stipulated under Section 134(3)(m) of the
Companies Act, 2013 read with Rule 8 of the Companies (Accounts) Rules, 2014, is annexed
herewith as Annexure A to this Report.

DIRECTORS AND KEY MANAGERIAL PERSONNEL

Your Company has well constituted Board in accordance with the provisions of the
Companies Act, 2013 and Article of Association of the Company.

Appointment

y Mr. Chand Rameshbhai Kanabar: Based on the recommendation of the
Nomination and Remuneration Committee, the Board of Directors appointed
Mr. Chand Rameshbhai Kanabar as an Additional Director designated as Non
Executive Independent Director with effect from 19 April 2025, for a first term of
five (5) consecutive years and subsequently, the Shareholders approved his
appointment as a Non-Executive Independent Director at the 2^nd Annual General
Meeting of the Company held on 25 September 2025.

y Ms. Nishtha Harivanshi Pamnani: Based on the recommendation of the
Nomination and Remuneration Committee, the Board of Directors appointed
Ms. Nishtha Harivanshi Pamnani as an Additional Director designated as Non
Executive Independent Director with effect from 10 June, 2025, for a first term of
five (5) consecutive years and subsequently, the Shareholders approved her
appointment as a Non-Executive Independent Director at the 2^nd Annual General
Meeting of the Company held on 25 September 2025.

y Mr. Mayur Popatlal Sojitra: Based on the recommendation of the Nomination and
Remuneration Committee, the Board of Directors re-designated Mr. Mayur Popatlal
Sojitra (DIN: 09108404), Executive Director as the Non-Executive Non-Independent
of the Company and subsequently, the Shareholders approved his re-designation
as Non-Executive Non-Independent at the 2^nd Annual General Meeting of the
Company held on 25 September 2025.

y CS Roshni Shah: The Board of Directors has appointed CS Roshni Shah as Company
Secretary and Compliance Officer of the Company with effect from 01 September,
2025, in its Board Meeting held on 01 September, 2025.

Cessation

y Mr. Shyam Bhadresh Kapadia has resigned from the post of Non-Executive Independent
Director of the Company with effect from 19 April, 2025.

y Mr. Vijay Bharatbhai Anadkat has resigned from the post of Non-Executive Independent
Director of the Company with effect from 26 May, 2025.

y CS Bhavika Dhaval Makadia has resigned from the post of Company Secretary and
Compliance Officer of the Company with effect from 01 September, 2025.

Retiring By Rotation

Mr. Hardik Mukundbhai Prajapati, Director, will retires by rotation and being eligible,
offers himself for re-appointment as per the provisions of the Companies Act, 2013. A
resolution seeking Members approval for his re-appointment forms part of the
3^rd AGM Notice.

Apart from this, none of the Directors and Key Managerial Personnel have been appointed,
ceased or resigned during the period under review.

BOARD OF DIRECTORS

The Company has a balanced Board of Directors, comprising an optimal mix of
Executive and Non-Executive Directors, including Independent Directors and a
Woman Director, as mandated by applicable law. This composition plays a vital role
in Board processes, providing independent judgment on matters of strategy and
performance. The Board consists of eminent individuals from diverse fields, each
bringing valuable experience and expertise to the Company.

The composition of the Board, attendance at the Board Meetings during the year ended
on 31 March, 2026 are given below:

#Mr. Shyam Bhadresh Kapadia has resigned w.e.f. 19 April, 2025.

@Mr. Vijay Bharatbhai Anadkat has resigned w.e.f. 26 May, 2025.

AMr. Chand Rameshbhai Kanabar has appointed as Independent Director w.e.f. 19 April, 2025.

$Ms. Nishtha Harivanshi Pamnani has appointed as Independent Director w.e.f. 10 June, 2025.

Number of meetings of the Board of Directors

During the year under review, 8 (Eight) Board Meetings were held on 19 April, 2025,
06 May, 2025, 13 May, 2025, 19 May, 2025, 10 June, 2025, 01 September, 2025, 14 November,
2025 and 10 March, 2026. The provisions of Companies Act, 2013 were adhered to while
considering the time gap between two meetings.

BOARD PERFORMANCE EVALUATION

Pursuant to the provisions of the Companies Act, 2013 and Rules made there under, the
Board has carried the evaluation of performance of Individual Directors including
Independent Directors, Board as Whole and its Committees and performance of the
Chairman of the Board, on the basis of qualification, experience, knowledge &
competency, availability & attendance and fulfillment of functions assigned by the
Board / Law, initiative and team work, commitment, contribution and integrity,
independence, independent views and judgment, compliances with policies of the
company, code of conduct & ethics, availability & attendance, adequacy of
committee composition and expertise, evaluation of risk, grievance redressal for
investors, conflict of interest, stakeholder value and responsibility, corporate culture
and values and various other criteria as recommended by the Nomination and
Remuneration Committee of the Company. The Directors expressed their satisfaction
with the evaluation process and outcome.

Further, Separate meeting of Independent Directors was held on 10 March, 2026, without
the presence of Non- Independent Directors, inter-alia, to review performance of
Chairperson and Non-Independent Directors of the Company, to review performance
of the entire Board of Directors of the Company, to assess the quality, quantity and
timeliness of flow of information and to ensure adequate deliberations on related party
transaction.

DECLARATION BY INDEPENDENT DIRECTORS

All the Independent Directors of the Company have given their declarations to the
Company under Section 149(7) of the Companies Act, 2013 read with Regulation 25(8)
of SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 that they
meet the criteria of independence as provided under Section 149(6) of the Companies
Act, 2013 read with Regulation 16(l)(b) of SEBI (Listing Obligations and Disclosure
Requirements) Regulations 2015. They have further declared that they are not
debarred or disqualified from being appointed or continuing as directors of
companies by the SEBI /Ministry of Corporate Affairs or any such statutory authority.
The terms and conditions of the appointment of Independent Directors have been
disclosed on the website of the Companywww.accretionpharma.com.

In the opinion of the Board, all the Independent Directors are persons of integrity and
possess the requisite expertise, experience, and proficiency to effectively discharge
their duties and responsibilities.

COMMITTEE
A. Audit Committee

The Audit Committee serves as a vital link between the Management, Statutory
Auditors, Internal Auditors, and the Board of Directors, overseeing the financial reporting
process of the Company. Its primary role is to monitor the integrity of financial reporting,
review the Company's internal financial control systems and governance practices,
and evaluate the effectiveness of statutory and internal audit functions.

The Audit Committee has been constituted by the Board of the Directors in compliance
with the provisions of Section 177 of the Companies Act, 2013 read with the rules made
thereunder and Regulation 18 of the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015 (SEBI Listing Regulations) read with Part C of Schedule II
of the SEBI Listing Regulations and the powers, role and terms of reference of the
Committee are in accordance with the aforesaid requirements of the Act and SEBI
Listing Regulations. Apart from the above, the Committee also carries out such functions
/responsibilities entrusted on it by the Board of Directors from time to time. The Company
Secretary of the Company acts as a Secretary to the Committee. The Chairman of the
Committee is an Independent Director having knowledge in Finance.

During the year under review, the Audit Committee held Five (5) meetings on 19 April,
2025, 10 June, 2025, 01 September, 2025, 14 November, 2025 and 10 March, 2026. Time
elapsed between two meetings never exceeded 120 days.

The composition of the Audit Committee and the details of the meetings attended
by its members during the financial year ended 31 March, 2026 are as under:

#Mr. Shyam Bhadresh Kapadia ceased to be a Member of the Committee upon his resignation from the Board w.e.f. 19 April 2025.
@Mr. Vijay Bharatbhai Anadkat was appointed as the Chairperson of the Committee w.e.f. 19 April 2025 and ceased to be the
Chairperson and a Member of the Committee upon his resignation from the Board w.e.f. 26 May 2025.

"Mr. Chand Rameshbhai Kanabar was appointed as a Member of the Committee w.e.f. 19 April 2025 and as the Chairperson
of the Committee w.e.f. 10 June 2025.

During the year, the Board has accepted all the recommendations made by the Audit
Committee

B. Nomination and Remuneration Committee

The Nomination and Remuneration Committee (NRC) has been constituted by the
Board of the Directors in compliance with the provisions of Section 178 of the Companies
Act, 2013 read with the rules made thereunder and Regulation 19 of the SEBI Listing
Regulations read with Part D of Schedule II of the SEBI Listing Regulations and the powers,
role and terms of reference of the Committee are in accordance with the aforesaid
requirements of the Act and SEBI Listing Regulations.

Apart from the above, the Committee also carries out such functions/responsibilities
entrusted on it by the Board of Directors from time to time. The Company Secretary of the
Company acts as a Secretary to the Committee.

During the year under review, the Nomination & Remuneration Committee held Three (3)
meeting on 19 April, 2025, 10 June, 2025 and 01 September, 2025.

The composition of the Nomination & Remuneration Committee and the details of the
meetings attended by its members during the financial year ended 31 March, 2026 are
as under:

#Mr. Shyam Bhadresh Kapadia ceased to be a Member of the Committee upon his resignation from the Board w.e.f. 19 April 2025.
@Mr. Vijay Bharatbhai Anadkat was appointed as the Chairperson of the Committee w.e.f. 19 April 2025 and ceased to be the
Chairperson and a Member of the Committee upon his resignation from the Board w.e.f. 26 May 2025.

"Mr. Chand Rameshbhai Kanabar was appointed as a Member of the Committee w.e.f. 19 April 2025 and as the Chairperson
of the Committee w.e.f. 10 June 2025.

$Ms. Nishtha Harivanshi Pamnani was appointed as a Member of the Committee w.e.f. 10 June, 2025.

C. Stakeholders' Relationship Committee

The Stakeholders' Relationship Committee (SRC) has been constituted by the Board of the
Directors in compliance with the provisions of Section 178 of the Companies Act, 2013 read
with the rules made thereunder and Regulation 20 of the SEBI Listing Regulations read with
Part D of Schedule II of the SEBI Listing Regulations and the powers, role and terms of
reference of the Committee are in accordance with the aforesaid requirements of the Act
and SEBI Listing Regulations. Apart from the above, the Committee also carries out such
functions/responsibilities entrusted on it by the Board of Directors from time to time. The
Company Secretary of the Company acts as a Secretary to the Committee.

During the year under review, the Stakeholders' Relationship Committee held One (1) meeting
on 10 March, 2026.

The composition of the Stakeholders' Relationship Committee and the details of the
meetings attended by its members during the financial year ended 31 March, 2026 are
as under:

#Mr. Shyam Bhadresh Kapadia ceased to be a Member of the Committee upon his resignation from the Board w.e.f. 19 April 2025.

@Mr. Vijay Bharatbhai Anadkat was appointed as the Chairperson of the Committee w.e.f. 19 April 2025 and ceased to be the
Chairperson and a Member of the Committee upon his resignation from the Board w.e.f. 26 May 2025.

AMr. Chand Rameshbhai Kanabar was appointed as a Member of the Committee w.e.f. 19 April 2025 and as the Chairperson
of the Committee w.e.f. 10 June 2025.

D. Corporate Social Responsibility Committee

The Corporate Social Responsibility (CSR) Committee has been constituted by the Board
of the Directors in compliance with the requirements of Section 135 of the Companies Act,
2013 and rules made there under. The CSR Policy is available on the website of the
Companywww.accretionpharma.com. The powers, role and terms of reference of the
Corporate Social Responsibility Committee covers the areas as mentioned under Section
135 of the Companies Act, 2013 and Companies (Corporate Social Responsibility Policy)
Rules, 2014. Apart from the above, the Committee also carries out such functions/
responsibilities entrusted on it by the Board of Directors from time to time.

During the year under review, the Corporate Social Responsibility held One (1) meeting on
01 September, 2025.

The composition of the Corporate Social Responsibility Committee as on 31 March, 2026
is as under:

@Mr. Vijay Bharatbhai Anadkat ceased to be a Member of the Committee upon his resignation from the Board w.e.f.
26 May 2025.

AMr. Chand Rameshbhai Kanabar was appointed as a Member of the Committee w.e.f. 10 June 2025.

NOMINATION AND REMUNERATION POLICY

The Board has, on the recommendation of the Nomination and Remuneration Committee
framed a policy for selection and appointment of Directors, Senior Management and their
remuneration. Details of Remuneration under Section 197(12) of the Companies Act, 2013
and details required under Rule 5(1) of the Companies (Appointment and Remuneration of
Managerial Personnel) Rules, 2014 are also stated in Annexure B which forms part of this
Annual Report. Nomination and Remuneration policy can be assessed at
www.accretionpharma.com.

The Remuneration policy covers the remuneration for the Directors (Chairman, Managing
Director, Independent Directors and other Non-executive Directors) and other employees
(under senior management cadre and management cadre).

PARTICULARS OF EMPLOYEES

The information pertaining to employee drawing remuneration as per Section 197(12) of the
Companies Act, 2013 read with per Rule 5(2) & 5(3) of the Companies (Appointment and
Remuneration of Managerial Personnel) Rules, 2014, pertaining to the names and other
particulars of employees is available for inspection at the registered office of the Company
during business hours on working days of the Company up to the date of ensuing AGM.
Having regard to the provisions of Section 134 and Section 136 of the Companies Act, 2013,
the Reports and Accounts are being sent to the Members excluding such information. Any
Shareholder interested in obtaining a copy of the same may write to the Company
Secretary and Compliance Officer either at the Registered Office address or by email to
compliance@accretionpharma.com.

HUMAN RESOURCES

The Company firmly believes that its human capital is the cornerstone of its sustained growth,
operational excellence, and long-term value creation. Recognizing that a skilled, engaged,
and motivated workforce is fundamental to achieving its strategic objectives, the Company
continues to strengthen its people practices by fostering a culture of integrity, collaboration,
innovation, and continuous learning. The Company remains committed to providing an
inclusive, performance-driven, and enabling work environment that encourages professional
growth, employee well-being, and organisational excellence.

The Company continues to invest in building organisational capability through structured
learning and development initiatives, leadership development programmes, talent
management practices, and employee engagement interventions. These initiatives are aimed
at enhancing employee competencies, strengthening leadership capabilities, and fostering a
future-ready workforce aligned with the Company's evolving business priorities.

As on 31 March 2026, the Company had a total workforce of 132 employees, as compared to 121
employees as on 31 March 2025. The Company remains committed to attracting, developing,
and retaining high-calibre talent while strengthening organisational capabilities to support
sustainable growth and the successful execution of its long-term strategic objectives.

VIGIL MECHANISM / WHISTLE BLOWER POLICY

Pursuant to the provisions of section 177(10) of the Companies Act, 2013 and Regulation 22 of
SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, a Vigil Mechanism or
'Whistle Blower Policy' for directors, employees and other stakeholders to report genuine
concerns, unethical behaviour, fraud or violation of company's code of conduct, has been
established.

Over the years, the Company has built a strong reputation for conducting business with
honesty and integrity, maintaining a zero-tolerance approach toward unethical behavior or
wrongdoing. The policy safeguards whistleblowers' rights to report concerns or grievances
and provides direct access to the chairman of the audit committee.

During the year under review, no instance has been reported under this policy. The said policy
is available on the website of the Companywww.accretionpharma.com.

STATUTORY AUDITORS

M/s V S S B & Associates, Chartered Accountants (Firm Registration No. 121356W), were re¬
appointed as the Statutory Auditors of the Company by the Board of Directors, which was
subsequently approved by the Shareholders at the 2^nd Annual General Meeting held on
25 September 2025. They have been appointed for a second term of five (5) consecutive
years to hold office from the conclusion of the 2^nd Annual General Meeting until the
conclusion of the 7^th Annual General Meeting of the Company to be held in the year 2030.

M/s V S S B & Associates, Chartered Accountants have carried out the Statutory Audit of the
Company for financial year 2025-26 and the Report of the Statutory Auditor forms part of the
Annual Report. The Statutory Auditors have not raised any qualification, observations or
adverse remarks in their report. There were no frauds reported by the Statutory Auditors
under the provisions of Section 143 of the Companies Act, 2013.

REPORTING OF FRAUD BY AUDITORS

There have been no instances of fraud reported by the Auditors u/s 143 (12) of the
Companies Act, 2013 and rules framed there under either to the Company or to the Central
Government.

COST AUDITORS AND RECORDS

In terms of the provisions of Section 148 of the Companies Act, 2013 read with the Companies
(Cost Records and Audit) Rules, 2014, as amended from time to time, the Company is not
required to maintain the Cost Records and Cost Accounts. Hence, the appointment of Cost
Auditors is not applicable to the Company.

SECRETARIAL AUDITORS

The Board pursuant to Section 204 of the Companies Act, 2013 read with Rule 9 of the
Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 had
appointed Mr. Nimish Chunibhai Sakhiya, Proprietor, M/s. Sakhiya & Co., Practicing Company
Secretary to conduct Secretarial Audit for the financial year 2025-26.

The Secretarial Audit Report in Form MR-3 for the financial year ended 31 March, 2026 which
is annexed herewith as Annexure C, which forms part of this report. There were no
qualifications, reservation, adverse remark or disclaimer in the report.

RISK MANAGEMENT

The Company has established a comprehensive risk management framework designed to
identify potential risks across all aspects of its business and implement remedial measures
to minimize any adverse impact. Recognizing that risk evaluation and mitigation are
continuous processes, the Company remains fully committed to proactively identifying and
addressing risks at every level of the organization.

The Risk Management Policy has been formulated and adopted by the Board of Directors in
accordance with the provisions of the Companies Act, 2013 and the SEBI Listing Regulations.
The Management periodically reviews the risk management framework and policies to
ensure their effectiveness. The Board has identified and assessed the key risks outlined in the
policy and has implemented appropriate mitigation strategies. As of now, there are no risks
which, in the opinion of the Board, may threaten the existence of the Company.

ENVIRONMENT, HEALTH AND SAFETY

The Company remains fully committed to upholding the highest standards of Environment,
Health, and Safety across all its operations. We firmly believe that a safe and healthy
workplace is fundamental to the long-term success and sustainability of our business.

The Company pledges to identify and manage environmental and social risks associated
with its operations, comply with all applicable environmental laws and regulations, and set
and pursue targets aimed at avoiding, reducing, or mitigating negative impacts. Additionally,
the Company is committed to promoting sustainable development through the responsible
use and conservation of natural resources.

INTERNAL CONTROL SYSTEMS AND THEIR ADEQUACY

The Company has established a robust internal control system commensurate with the scale
and complexity of its operations. The Company believes in a strong internal control framework,
which is necessary for business efficiency, management effectiveness and safeguarding
assets. The Company has a well-defined internal control system in place, which is designed to
provide reasonable assurance related to operation and financial control.

The Company has a well-defined organizational structure, authority levels, internal rules and
guidelines for conducting business transactions. The Company intends to undertake additional
measures as necessary in line with its intent to adhere to procedures, guidelines and regulations
as applicable in a transparent manner. The Management of the Company is responsible for
ensuring that Internal Financial Control has been laid down in the Company and that controls
are adequate and operating efficiently.

PROHIBITION OF INSIDER TRADING

In terms of the provisions of the Securities and Exchange Board of India (Prohibition of Insider
Trading) Regulations, 2015, as amended (“SEBI PIT Regulations”), the Company has adopted the
revised “Code of Conduct to Regulate, Monitor and Report Trading by Insiders” (“the Code”).
The Code is applicable to promoters, all directors, designated persons and connected persons
and their immediate relatives, who are expected to have access to unpublished price sensitive
information relating to the Company. The Company has also formulated a 'Code of Practices
and Procedures for Fair Disclosure of Unpublished Price Sensitive Information (UPSI)' in
compliance with the PIT Regulations. The aforesaid codes are available on the website of the
Company and can be accessed at www.accretionpharma.com.

SECRETARIAL STANDARDS

The Company has followed the applicable secretarial standards issued by the Institute of
Company Secretaries of India (ICSI) during the year under review.

CORPORATE SOCIAL RESPONSIBILITY

The Company is committed to creating sustainable and measurable social impact through its
Corporate Social Responsibility (“CSR”) initiatives. The Company's CSR approach goes beyond
statutory compliance and focuses on improving healthcare accessibility, affordability, and
availability of quality healthcare. The Company aims to bridge the healthcare gap, promote
preventive health, to improve healthcare infrastructure through strategic partnerships or
contribution in various projects and to create sustainable and measurable social impact
through healthcare interventions.

In terms of provisions of Section 135 of the Act read with the Companies (Corporate Social
Responsibility Policy) Rules, 2014 ['the CSR Rules'], the Company has formulated a Corporate
Social Responsibility Policy ('CSR Policy') outlining the framework and activities to be
undertaken by the Company. The CSR Policy is available on the website of the Company
and can be accessed at www.accretionpharma.com.

During the year, the Company was required to spend CSR expenditure of ^11.76 Lacs as per
the provisions of the Act. The Company has spent a total amount of?12.11 Lacs towards CSR
activities during the year. The Annual Report on CSR activities in terms of the requirements
of CSR Rules is annexed herewith as Annexure D, which forms part of this report.

DISCLOSURE UNDER THE SEXUAL HARASSMENT OF WOMEN AT WORK PLACE (PREVENTION,
PROHIBITION AND REDRESSAL) ACT, 2013

The Company believes in providing a safe and harassment free workplace for each and every
individual working for it through various interventions and practices. It is the continuous
endeavour of the management to create and provide an environment to all its employees that
is free from discrimination and harassment including sexual harassment. It has adopted a
policy against sexual harassment in line with the provisions of Sexual Harassment of Women at
Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the rules framed thereunder. All
employees (Permanent, Contractual, Temporary and Trainees) are covered under this Policy.

Your directors state that during the year under review, there were no complaints relating to
sexual harassment nor any cases filed pursuant to the said Act.

DISCLOSURE UNDER THE MATERNITY BENEFIT ACT, 1961

During the year under review, the Company has complied with the provisions of the Maternity
Benefit Act, 1961, as amended from time to time.

EXTRACT OF THE ANNUAL RETURN

The Annual Return of the Company as on 31 March, 2026 is available on the website of the
Company i.e. www.accretionpharma.com pursuant to the provisions of Section 92 read with
Section 134 of the Companies Act, 2013 and rules made there under.

CORPORATE GOVERNANCE

As the Company is listed on the NSE SME EMERGE platform, it is exempt from certain
Corporate Governance regulations under the SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015.

Nevertheless, the Company remains committed to practicing sound Corporate
Governance by taking timely and appropriate actions to enhance and meet stakeholder
expectations. It continues to comply with all mandatory provisions and actively strives
to adhere to the non-mandatory guidelines of Corporate Governance.

Report on Corporate Governance Practices and the Auditors Certificate regarding compliance
of conditions of Corporate Governance and certification by CEO & CFO is not applicable to your
Company as per regulation 15(2)(b) of SEBI (Listing Obligation and Disclosure Requirements)
Regulations, 2015.

DETAILS OF SIGNIFICANT AND MATERIAL ORDERS PASSED BY THE REGULATORS OR COURTS
OR TRIBUNALS IMPACTING THE GOING CONCERN STATUS AND COMPANY'S OPERATIONS IN
FUTURE

During the financial year, the Company received a Show Cause Notice from the Securities and
Exchange Board of India (SEBI) vide letter no. SEBI/HO/EAD/EAD1/P/OW/2025/00027452/1 dated
28 October, 2025 under Rule 4(1) of the SEBI (Procedure for Holding Inquiry and Imposing
Penalties) Rules, 1995, read with Section 15-I of the Securities and Exchange Board of India Act,
1992. The Company submitted its response to the said Show Cause Notice and subsequently
attended a personal hearing pursuant to the notice issued by SEBI vide letter no. SEBI/HO/EAD/
EAD-1/ak/rk/ow/2025/000030276/1 dated 03 December, 2025. Thereafter, SEBI passed an
Adjudication Order bearing no. Order/AK/RK/2025-26/31951-31952 dated 07 January, 2026,
imposing a monetary penalty of 51,00,000 under Section 15HB of the SEBI Act. The Company has
duly complied with the said Order by paying the prescribed penalty.

The management believes that the aforesaid matter has been appropriately addressed and
resolved through compliance with the Adjudication Order. The said Order does not have any
material adverse impact on the Company's financial position, operational performance, or its
ability to continue as a going concern.

Accordingly, except for the matter stated above, there were no significant and material orders
passed by any regulator, court, or tribunal during the year which could have an adverse impact
on the going concern status of the Company or its future operations.

DIRECTORS' RESPONSIBILITY STATEMENT

In accordance with the provisions of section 134(3)(c) of the Act, 2013, with respect to Director's
Responsibility Statement, it is hereby stated :

a. that in the preparation of the annual accounts for the year ended 31 March, 2026, the
applicable accounting standards had been followed along with proper explanation
relating to material departures, if any;

b. that such accounting policies as mentioned in Notes to the Financial Statements had been
selected and applied consistently and judgment and estimates have been made that are
reasonable and prudent so as to give a true and fair view of the state of affairs of the
Company as at 31 March, 2026 and of the profit of the Company for the year ended on that
date;

c. that proper and sufficient care had been taken for the maintenance of adequate accounting
records in accordance with the provisions of the Companies Act, 2013 for safeguarding the
assets of the Company and for preventing and detecting fraud and other irregularities;

d. that the annual accounts for the year ended 31 March, 2026 had been prepared on a going
concern basis;

e. The Company is following up the proper Internal financial controls and such internal financial
controls are adequate and are operating effectively; and

f. that systems to ensure compliance with the provisions of all applicable laws were in place
and were adequate and operating effectively.

GENERAL DISCLOSURES

Your Directors state that no disclosure or reporting is required in respect of the following items,
as there were no transactions/events of this nature during the year under review:

a. Issue of equity shares with differential rights as to dividend, voting or otherwise.

b. Provision of money by company for purchase of its own shares by employees or by trustees
for the benefit of employees.

c. Issue of employee stock options scheme.

d. Issue of Shares (including Sweat Equity Shares) to employees of your Company under any
scheme.

e. There was no application made or proceeding pending under the Insolvency and Bankruptcy
Code, 2016 (31 of 2016) during the year.

f. There has been no instance of valuation done for settlement or for taking loan from the
Banks or Financial Institutions.

g. The Company did not face any incidents or breaches or loss of data breach in cyber
security.

ACKNOWLEDGMENTS

The Directors wish to express their sincere appreciation to all business associates for their
valuable support and contributions during the year. The Directors also extend their gratitude to
the Company's employees, customers, suppliers, alliance partners, bankers, and all other
stakeholders for their continued support and the confidence they have placed in the
management.