RESEARCH

PAPER

ON

Role of Company Secretary as a statutory officer, as coordinator

and as an administrative officer.

FOR THE SUBJECT OF

COMPANY LAW -II

BY

HARSHIT SINGH

PRN 18010323057

DIV A BA LLB

SUBMITTED TO

Ms. ANITA SABLE

(FACULTY INCHARGE)

For

The Month

of

APRIL 2021

1
INDEX
Chapter 1
Sl. Title Page No.
No.
1.1 Introduction 3-4
1.2 Scope and Significance 5
1.3 Research Question and Research Objective 6
1.4 Research Methodology 7

Chapter 2
Sl. Title Page No.
No.
2.1 Meaning of company Secretary 8-9
2.2 Qualification of a company secretary 10
2.3 Rights of a company Secretary 11
2.4 Role of Company Secretary as a statutory officer, as coordinator 12-14
and as an administrative officer
2.5 Judicial Interpretation 15-16

Chapter 3
Sl. Title Page No.
No.
3.1 Conclusion and Recommendation 17
3.2 Literature Review 18
3.3 Reference 19-20

2
Chapter 1
1.1 INTRODUCTION

As per Section 2(24) of the Companies Act, 2013 a Company Secretary (hereinafter referred
as CS) means a Company Secretary as demarcated under Section 2(1)(c ) of the Company
Secretaries Act, 1980.As per or we can also say that a person who is chosen by a corporation
to carry out the jobs of CS.1 A CS also has an in-depth knowledge about the interpretation of
the law apart from being the master of the company. So, he can turn out to be the dominant of
all the Laws like Labour Laws, Tax system Laws, and other Laws that a Corporation needs to
fulfil with. It is very much clear that the Company Secretary is in-charge of all the works
related the compliance with the statutory and regulatory requirements. 2 Hence their roles
become threefold that is of statutory officer, coordinator and administrative officer.

As per the section 204 3 of the Companies Act 2013 it is a mandatory scene for the
companies that has a paid-up portion asset of more than 10 crore or added and the other as 5
crore or more, they must assign a round-the-clock CS. Also, to mention that in the recent time
the roles of the company secretary has been on thrive as there has been the writing of
multiple acts that has led to increment in the number of compliance and regulation to tenfold
and all these duties comes under the ambit of Company Secretary. 3 Talking about the role as
a coordinator here the company secretary ensures that that the plans given out by the top-
level management of the company is applied effectively and successfully. It can be also said
that his role as a coordinator is essentially a link between the top and the lower-level
management and also as a link between shareholder, society and the government. Adding to it
here as a coordinator the company secretary makes the Manging Director aware of the
different sorts of policies and regulations that has been passed by the board 4 and the changes
which the Government does. Under this ambit the role of the CS here is to basically look at
the working of the company is conforming the policies of the company or not since he is

1
Sumaira Jain, The Role Company Secretary in Corporate Governance, 2, IMPERIAL JOURNAL OF
INTERDISCIPLINARY RESEARCH, 4 (2016)
2
Palak Bhandaari, Different Roles of a Company Secretary, 5, BRYANT UNIVERSITY LAW JOURNAL, 10
(2018)
3
Dinesh N. Lal, The Secretary in India, IOWA STATE, (Feb 20, 2021 11: 47 AM)
https://www.extension.iastate.edu/
4
Ishwar Singh, Examination of Company Secretary’s, Impact of External Environment and Board
Characteristics, SEMATIC SCHOLARS (April 19, 2021 1:30 AM) https://pdfs.semanticscholar.org/

3
aware of the organisational structure thus, he understands the output in terms of work for a
company. 5

5
SHUBHASH CHANDRA, CORPORATE GOVERNANCE IN INDIA – AN EVALUATION 1 (3ed. Oxford
University press 2009)

4
 1.2 SCOPE AND SIGNIFICANCE

The research paper titled “Role of Company Secretary as a statutory officer, as coordinator
and as an administrative officer” has the scope that this paper will enlighten the reader on the
threefold role of the CS that is as an administrative officer, coordinator and as a statutory
officer, also in reference with relationship with a trade union, government and shareholders.
To mention it will give a detail idea about the meaning of company secretary and the
qualification of the same. Towards the end the scope of this paper is extended to the limit that
rights of the company secretary shall also be discussed by the researcher in addition to it the
researcher has provided with major case laws supporting each and every component of the
research paper. The significance of this research paper can also be seen subsequently going
over this paper, the readers will understand the multifaceted role and responsibilities of the
company secretary and then they shall also appreciate as in why the terminology “backbone”
is used for the company secretary and will help them discover the relationship of the
company secretary with other functionaries such as the trade union, government and with
shareholder along with giving the readers an important knowledge about the related case laws
and the basics of company secretary.

5
 1.3 RESEARCH OBJECTIVE

 To comprehend the meaning of company secretary in relation to Companies Law

2013.
 To comprehend and gain knowledge about the qualification required of a company
secretary.
 To understand three major roles of company secretary as a statutory officer,
administrative officer and as coordinator with an in-depth analysis.
 To recognize the relationship with functionaries such as trade union, government and
shareholder.
 To understand the rights of company secretary in a corporate world
 To know with an in-depth analysis regarding the major case laws dealing with each
and every component of the research paper

1.4 RESEARCH QUESTIONS

 What is a company secretary and what are the qualification required to become a
Company Secretary?
 What is the appointment and the opportunities of a CS?
 What the major roles and duties of the CS in the corporate sector, with special
analysis on what are the threefold roles of a Company Secretary?
 What is the nature of service that a Company Secretary can offer and what is the right
available to them?
 What is the relation of a company secretary with the entities outside the corporate
world?

6
 1.5 RESEARCH METHODOLOGY

The use of Analytical Method as through scrutiny of pertinent works, the student made a in-
depth study of various information and allied it with the evidences on the ground before
making ending conclusions. Along with Doctrinal Research methodology as there has been a
use of doctrinal research by the researcher as the pre-existing legal proposition such as the
judgement of the courts and the other existing statutory provisions available has also been
analysed deeply. The research's key aim is to concentrate on pieces of knowledge and raise
specific questions about them. Qualitive Data Research, data has been taken from various
resources to understanding the concept of Company Secretary and its impact. The topic of
admissibility of evidence has also be dealt though not in detail. For this purpose, a perusal
approach was used by the researcher in getting a deep analysis of the case that the researcher
is mentioning in the final paper. A method of comparative analysis was used in terms of
analysing the common things in the case laws with respect to the forensic science and also
with the intention to a critical remark on that. Apart from this multidimensional approach was
applied to study the cases to find out the basics intrigue of the case laws that will ultimately
help in the critical analysis.

7
Chapter 2

2.1 MEANING OF A COMPANY SECRETARY

The CS has a very important part to show for the purpose of administration of a joint stock
company, the provisions that are given in the in the companies’ act are so puzzled that there
is a frequent reminder of their compliance is required. The scenario is such that it has become
practically not possible for the top administration of the company to keep an eye on this
regularly and ensure that there is a routine administration and compliance with the
“provisions of the act” and for managing these things the top management of the corporation
appoints the company secretary. A company secretary is basically a person who is called the
officer of the company whose appointment is done to perform various ministerial and
administrative duties, but at the same time it is not his onus to look after the matters if the
establishment.6 The major duty under his ambit is to look after the affairs that is happening in
the company and whether it is happening as the per “provisions” of the act or not and also as
per the “Articles of Association” of the establishment or not. The Companies Act of 1956 (as
amended by the Companies Act 1974) as per section 2(45) gives the definition of the same
which is “any individual, possessing the prescribed qualifications, appointed to perform the
duties which may be performed by a secretary under the Act and any other ministerial or
administrative duties” whereas the CS Act of 1980 tells that “a person who is a member of
the Institute of Company Secretary of India' [Section 2(1) (c)]” and the Companies
Amendment Act of 1988 tells that “a secretary means a company secretary within the
meaning of clause (C) of sub-section(1) of section 2 of the Company Secretaries Act, 1980,
and includes any other individual possessing the prescribed qualifications and appointed to
perform the duties which may be performed by a secretary under this Act and any other
ministerial or administrative duties”7 As per Section 2(24) of the Companies Act, 2013 A CS
means a CS as defined under Section 2(1)(c ) of the Company Secretaries Act, 1980 or who is
selected by the Corporation to accomplish the role of a CS. It means that The Companies Act,
2013 does not clearly define the word CS8.

6
Nitya Agrawal, Modern Overview Business, THE COMPANY, (April 20th 2021, 2:04 PM), https://thecompany
/ modern-business-overview/
7
AVTAR SINGH, COMPANY LAW, 78-81, (17ed. EBC 2016)
8
M Shanmugha Vadivel v Registrar of Companies CTA No 1286/2007

8
From the above discussion it is very much clear that, hence there is an emergence of three
points in regards to the topic which shall be put forth as:9

1. The appointment of an individual can only take place as a CS and no firm or a body
corporate can take this place.
2. The person whose appointment is done shall possess the qualification that is given by
the Central Government.
3. There are two duties that is (a) ministerial and (b)administrative in nature.10

It's important to note that a business secretary cannot behave on his own; instead, he must
work under the direction of the BOD. Except as directed by the board of directors, he has no
right to act, enter into contracts, or make decisions depictions in order to quandary the
business.

9
Dr. L Usha, Overview of Company Secretary in India, 12-15, ISJR 2013
10
AVTAR SINGH, COMPANY LAW, 78-81, (17ed. EBC 2016)

9
 2.2 QUALIFICATION OF A COMPANY SECRETARY

The definitions of Company Secretary Appointment and his Rights and Obligations are
defined in Sec. 2(24) of the Companies Act 2013, and a CS is defined in Sec. 2(1)(c) of the
Company Secretaries Act 1980. A individual who is a member of the Institute of Company
Secretaries of India is referred to as a CS in this clause. In the private sector, a CS can
represent his firm before any quasi-judicial body in relation to any civil controversy or other
legal proceedings, while in the public sector, a CS can represent his company before any
quasi-judicial body in relation to any legal issue and other legal litigation. To be qualified as
a company secretary, one must clear the:11

1. CS Executive level programme and Specialized level programme.

2. Must have training credentials which comprises student initiation programme, managerial
development programme, proficient development programmed and long-term practicum with
specified cs entity.
However, to apply for the above programmes, one must:12
(a) Be a graduate from any documented college or institution.
(b) Should not be less than 17 years of age.
Thus, a CS should be a member of the ISCI13.

A CS should have certain additional credentials in addition to the statutory qualifications

mentioned above. Me must have broad experience, including business and trade knowledge,
in order to provide useful guidance to directors. He must be well-versed in the various laws
that govern the industry.14 He should also be well-versed in economics, accounting, and
financial matters. He must have a pleasant attitude in order to get along with others and gain
the staff's full cooperation.

11
CV. Nagpal, Company Secretary- Qualifications, Rights and Duties, BCOM GUIDE (April 20th, 2021 8:42
AM), https://bcomguide.blogspot.com/2017/03/company-secretary-qualification-rights.html
12
Nitya Agrawal, Modern Overview Business, THE COMPANY, (April 20th 2021, 2:04 PM),
https://thecompany / modern-business-overview/
13
Institute of Company’s Secretaries of India
14
Dr Rajni Jagota, TAXMANN’S COMPANY LAW, 98-102, (4ed. TAXMANN (2020)

10
 2.3 RIGHTS OF THE COMPANY SECRETARY

RIGHTS
CS is a senior level officer. He relishes the rights as per the pact signed by him with the
Establishment. Some rights are as follows:15

1. Company Secretary, as a senior level official, has the authority to supervise, monitor, and
direct subordinate officers and employees.16
2. As a principal officer of a corporation, a CS may sign any outworker arrangement on
behalf of the corporation, subject to the board of directors' delegation of authority.
3. On behalf of the corporation, the Company Secretary may give instructions to the workers.
4. The Company Secretary is permitted to attend shareholder and board of directors’
meetings.
5. He will assert his legitimate dues as a preferential creditor of a firm during the winding up
process.17
6. On behalf of the organization, he may mark and validate the minutes of meetings (Board,
Annual general or extraordinary general meeting) and other records that do not require the
use of a common seal.
7. The CS is a Compliance Officer, and he has the authority to blow the signal if he believes
the company's officers or executives are acting in the establishment's best interests.

15
IBID
16
G. Sivakumar, The changing role of Company Secretary, DELOITTE, (April 19th 9:03PM),
https://www2.deloitte.com/ie/en/pages/legal/articles/changing-role-secretary.html
17
Sumaira Jain, The Role Company Secretary in Corporate Governance, 2, IMPERIAL JOURNAL OF
INTERDISCIPLINARY RESEARCH, 4 (2016)

11
2.4 ROLE OF A COMPANY SECRETARY AS A STATUORY OFFICER,
AS COORDINATOR AND AS AN ADMINISTRATIVE OFFICER

A CS is mostly a staff person who does essential duties including general management,
shareholder contact, corporate governance, and regulatory compliance/accounting reporting.
In a nutshell, the secretary serves as a link between the corporation, its partners, and
Companies House18, ensuring that all pertinent information is exchanged in a timely and
productive manner. Since the job of company secretary entails a wide range of
responsibilities, an organized person with prior management experience is always the best
choice.

It is very much evident that CS plays a highly vital role in the functioning of a company also
to mention that the space of his role solely hinge on on the magnitude and the nature of the
corporation with which he is working.19 Also, to state here that he is not just liable to the
company but also to its various components such as creditors employees etc. Three-fold role
can be seen namely as a statutory officer, as a coordinator and lately the role as an
administrative officer.

 STATUTORY OFFICER: Being the principal officer of the company he is mainly

answerable for acquiescence various provisions in relation to the main Act and also
for the requirement of the other Act He must sign many papers, including annual
returns, allotment returns, and declarations for the start of service.20 He is in charge of
verifying the authenticity of the profit and loss account and the balance sheet
Organizing meetings/ sessions between board of directors and shareholder, as well as
keeping minutes of those meetings. Here the CS is also accountable to obey with
several necessities that are related to Sales Tax Act, Capital Issues (Control) Act,
Industrial Dispute Act etc.
 COORDINATOR: He also acts as a link between BOD and other executives of the
company. The Board makes executive recommendations, but it is the secretary who
insists that they are carried out properly. 21He serves as a liaison between the Board of
18
CIC/AT/C/2008/00783
19
ibid
20
Ritu Bajaj v DSCS, CM 32226/2020
21
Palak Bhandaari, Different Roles of a Company Secretary, 5-8, BRYANT UNIVERSITY LAW JOURNAL,
(2018)

12
 Directors, the executive director, and the Chairman on the one side, and the
employees on the other. In an organization of many separate divisions such as
procurement, acquisition, staff, and so on, he serves as an intermediary with these
functionaries to ensure that policy actions are carried out properly, and if there are any
issues that need to be addressed further, the secretary will bring them before the
Board and relay the Board's decision to the concerned agency. The company secretary
also acts as a coordinator with trade unionists, auditors, shareholders of the company,
Government and the community at large.22 He is to ensure the compliance of the
provisions of companies Act and various other Acts. Ile should see that the company
functions in a manner as to achieve the declared objectives of the Government. It is
now widely accepted that the company has some responsibility towards the society as
well. The secretary can advise the Board regarding the matters where the company
can contribute to the welfare of the society.

RELATIONSHIP WITH TRADE UNION

As an agent of the business, the company secretary meets with labour unions. Since
dealing with labour unions is such a sensitive operation, the secretary must maintain
meticulous records of all negotiations and agreements. He is also in charge of the
company's agreements with labour unions. Before disciplining any employee accused
of misconduct, he must conduct a thorough investigation and make all relevant
information available. The secretary also maintains that Acts such as the Industrial
Disputes Act, Employees Provident Fund Act, Miscellaneous Provisions Act, and
others are followed.

RELATIONSHIP WITH SHAREHOLDERS

The secretary's job as coordinator includes maintaining a friendship with the
shareholders and serving as a liaison between the board and the shareholders. He is in
charge of all shareholder communications23. The corporation must ensure that all
documentation and reports requested by shareholders are sent to them in a timely
manner. He must also deal with them individually in order to clear up their concerns
and questions.

22
ND Associates, The Secretary in India, IOWA STATE, (April 20, 2021 11: 47 AM)
https://www.ndasso.iastate.edu/
23
Daljit Singh v Manohar Infrastructure CTA No. P/012/SR/2019

13
 REALTIONSHIP WITH GOVERNMENT
The company secretary is in charge of all government communications. In reality, this
is to ensure accurate and consistent reporting and communication. He would work
with the government to organize reforms to laws and regulations. He'll also work to
maintain a positive relationship with the authorities, ensuring that all rules and laws
are followed.

 ADMINISTRATIVE OFFICER: As a general administrative officer, lie is in charge

of the company's effective management. He is responsible for overseeing, controlling,
and coordinating the operations of various departments such as revenue, staff, and
organization. He has to provide a solid and effective organizational framework. He
must also ensure the preservation and careful management of the company's
equipment and resources. 24He must be certain that they are not abused. The Company
secretary is in charge of making sure the documents are kept up to date. With the
rapid developments that are occurring, a secretary is likely to show an ever more
important part in the company's administration. He is to support the Board in placing
down the strategies and dealing with the Government and financial organizations.25

24
ND Associates, The Secretary in India, IOWA STATE, (April 20, 2021 11: 47 AM)
https://www.ndasso.iastate.edu/
25
Shruti Mehra, Examination of Company Secretary’s, Impact of External Environment and Board
Characteristics, SEMATIC SCHOLARS (April 19, 2021 1:30 AM) https://pdfs.semanticscholar.org/

14
 2.5 JUDICIAL INTERPRETATION

 Lewek Altair Shipping Pvt Ltd. V Registrar of Companies26

This case law was one of the major case in regards to the topic of the research
paper since here the Hon’ble Court defined the meaning of the term
“Company Secretary” in real sense here the Vishakhapatnam Bench of ITAT
said “A company secretary is in charge of all aspects of company
management, also known as company enforcement. This ensures they're in
charge of submitting confirmation notes and other vital paperwork to
Companies House, as well as a variety of other logistical tasks including
scheduling board meetings.”
 Shrimati Manju Khurrana v The state Farms Corporation Limited 27
Another major case laws related to the topic, this case laws has been used by
the research paper by the researcher since this case has explicitly mentioned
and talked in detail about the qualifications that are needed by the company
secretary in regards to the companies Act 2013, it has also mentioned about
the exams and the parameters that are required for this.
 SMS Pharmaceuticals v Neeta Bhalla28
The major reason for inclusion if such a case laws include that here Justice SB
Sinha clearly said and the researcher quote “. The secretary serves as a
statutory official, a planner, and an administrative officer. Aside from the
three primary responsibilities, the business secretary is also accountable to
lenders, depositors, creditors, debtors, and staff. Let's take a closer look at the
three core responsibilities of it.”. Hence this case law clearly distinguishes the
major roles of the CS as an coordinator, secretary and as and administrative
officer in a detailed manner and also explained the the other types of roles
present for a CS.
 BD Topiwala v Deccan Chronicles29

26
S.P.No.21/Viz/2017
27
CIC/AT/C/2008/00783
28
Appeal (crl.) 664 of 2002
29
CIC/LS/A/2012/002418

15
 This case law has been useful in explaining the other aspect of the role of the
CS here in the case the learned JM mentioned about the extension of the role
of the CS as coordinator where he explained further relations with trade
unions, government and shareholders in an explicit manner.
 DCM Financial Service v J.N Sareen30
This case laws explicitly focuses on the rights of the company secretary and
has been good in making understand the rights of the company secretary in a
detailed manner along with the duties of the CS and that too in a much-
detailed manner.

30
2002(3) TMI 871

16
Chapter 3

3.1 CONCLUSION AND RECOMMENDATIONS

A CS is critical to a company's growth and progress, as well as the connection between the
inside and outside worlds. As a result, certain improvements or alterations in the extent and
function of his responsibilities are needed in order to improve the company's governance and
achieve improved results in the future. To perform a wide range of duties that are critical to a
company's growth, a Company Secretary must be organized, diligent, highly trained,
experienced, and an authority in the concerned market for the company's upliftment, to
maximize the earnings of its owners, to support the shareholders, and to be a pioneer in the
industry. A CS is responsible for a variety of regulatory and corporate governance duties in
accordance with the Companies Act, including taxation laws, shareholder interests, legal
structure, legislative regulations, and industrial and economics laws. As a result, he serves as
a bond between the company's directors and shareholders. A company secretary's function
under the Companies Act is threefold: legislative officer, planner, and administrative officer
if so allowed.

RECOMMENDATIONS

1. The company secretaries' position must be clear and established, and they
must report to a single authority, the chairman.
2. 2. His scope of duties must include discretionary authority, and he must be
accountable for his decisions.
3. The importance of the business secretary's position should be emphasized
by the board members.
4. Mentoring and instruction of junior employees in the same position must
be successful and can be strengthened.
5. The most trained experts from ICSA must be assigned to the board
members' roles and to meet their needs.

17
 3.2 LITERATURE REVIEW

 G.K KAPOOR, SANJAY DHAMJI, Company Law, 87-91 (22ed. Taxmann 2019)

The 24th edition of this much looked for after work has been broadly reconsidered, refreshed,
broadened and made significantly more valuable to law understudies and Bar individuals.
The informed creator has given all the important case laws with relations to the topic with the
proper explanation which helped more with the understanding.

 SHUBHASH CHANDRA, Corporate governance in India – An Evaluation, 101-109

(3ed. Oxford University press 2009).

This literature was considered a much important guiding light for the completion of this
research paper and hence it acted as important source for writing about the use of Company
law in defining the company secretary and roles, powers etc. in India.

o Sumaira Jain, The Role of Company Secretary in Corporate Governance, 2-4,

JOURNAL OF RES. INTD., (2016)

This literature was considered a much vital guiding light for the accomplishment of this
research paper and hence it acted as an important cause for writing about the use of as it gives
and in-depth analysis of the roles of company secretary as coordinator, administrative officer
and statutory officer and has been properly explained.

o Palak Bhandaari, Different Roles of a Company Secretary, 5-11, BRYANT

UNIVERSITY LAW JOURNAL, 10 (2018)

This literature was considered as it gave an insight in details with regards to the world of
corporate laws and how does this become so useful in dealing with the basics of corporate
governance and also is describing in depth the relationship with various other functionaries
and also about the right of the secretaries.

18
 REFERENCES

BOOKS

o SHUBHASH CHANDRA, CORPORATE GOVERNANCE IN INDIA – AN EVALUATION

14-18 (3ed. Oxford University press 2009)
o AVTAR SINGH, COMPANY LAW, 78-81, (17ed. EBC 2016)
o Dr Rajni Jagota, TAXMANN’S COMPANY LAW, 98-102, (4ed. TAXMANN (2020)

CASES

o M Shanmugha Vadivel v Registrar of Companies CTA No 1286/2007

o Ritu Bajaj v DSCS, CM 32226/2020
o Daljit Singh v Manohar Infrastructure CTA No. P/012/SR/2019
o Lewek Altair Shipping Pvt Ltd. V Registrar of Companies S.P.No.21/Viz/2017
o Shrimati Manju Khurrana v The state Farms Corporation Limited 2002(3) TMI 871
o SMS Pharmaceuticals v Neeta Bhalla Appeal (crl.) 664 of 2002
o BD Topiwala v Deccan Chronicles CIC/LS/A/2012/002418
o DCM Financial Service v J.N Sareen 2002(3) TMI 871

JOURNALS

o Sumaira Jain, The Role Company Secretary in Corporate Governance, 2, IMPERIAL

JOURNAL OF INTERDISCIPLINARY RESEARCH, 4 (2016)
o Palak Bhandaari, Different Roles of a Company Secretary, 5-6, BRYANT
UNIVERSITY LAW JOURNAL, 10 (2018)
o Dr. L Usha, Overview of Company Secretary in India, 12-15, ISJR 2013
o Dr. P. Seevkumar, Changing Dimension of Company Secretary, 9-11. ASIAN LAW
JOURNAL 2018

INTERNET SOURCES

19
o Dinesh N. Lal, The Secretary in India, IOWA STATE, (Feb 20, 2021 11: 47 AM)
https://www.extension.iastate.edu/
o Ishwar Singh, Examination of Company Secretary’s, Impact of External Environment
and Board Characteristics, SEMATIC SCHOLARS (Feb. 19, 2021 1:30 AM)
https://pdfs.semanticscholar.org/
o CV. Nagpal, Company Secretary- Qualifications, Rights and Duties, BCOM GUIDE
(April 20th, 2021 8:42 AM), https://bcomguide/company-secretary-qualification-
rights/
o Nitya Agrawal, Modern Overview Business, THE COMPANY, (April 20th 2021, 2:04
PM), https://thecompany / modern-business-overview/
o G. Sivakumar, The changing role of Company Secretary, DELOITTE, (April 19th
9:03PM), https://www2.deloitte.com/ie/en/pages/legal/articles/changing-role-
secretary.html

20