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Control Sub

Area Process
No process

Board of Directors -
Entity Level Control ELC - 02 ELC
Oversight

Whistle Blower
Entity Level Control ELC - 03 ELC
Mechanism

Entity Level Control ELC - 04 ELC Code of conduct(CoC)

Entity Level Control ELC - 07 ELC Policies and Procedures

Authority Limits
Entity Level Control ELC - 11 ELC
(Authority Matrix)

New Hire-MRF & Offer


HR & Payroll HRP-01 HR & Payroll
Letter

HR & Payroll HRP-02 HR & Payroll Background verification


HR & Payroll HRP-03 HR & Payroll Employee Master

Payroll reconciliation,
HR & Payroll HRP-05 HR & Payroll Salary accounting and
payment

HR & Payroll HRP-06 HR & Payroll Statutory dues

Position/ Compensation
HR & Payroll HRP-07 HR & Payroll
Change

Vendor Contracting
Non Trade Procurement NTP - 02 Non Trade Procurement
(As applicable)

Non Trade Procurement NTP - 03 Non Trade Procurement Invoice Processing


Non Trade Procurement NTP - 04 Non Trade Procurement Vendor Payment

Vendor balance
Non Trade Procurement NTP - 05 Non Trade Procurement
confirmations

Non Trade Procurement NTP - 06 Non Trade Procurement Employee Advances

Vendor Master
Procure to Pay PTP - 01 Procure to Pay (Excluding Lifestyle, Silk
- IOTs and Inputs)

Payee Master in
Procure to Pay PTP - 03 Procure to Pay
Razorpay

Procure to Pay PTP - 07 Procure to Pay Price Index - Cocoon


Procure to Pay PTP - 10 Procure to Pay Invoice Processing

Payment (OCC to
Procure to Pay PTP - 11 Procure to Pay
Razorpay)

Procure to Pay PTP - 12 Procure to Pay Payment (Manual)

Purchases Return (Other


Procure to Pay PTP - 13 Procure to Pay
than lifestyle)

Reconciliation - OCC vs
Procure to Pay PTP - 15 Procure to Pay
Tally

Logistics (vendor
Procure to Pay PTP - 17 Procure to Pay selection and
contracting)
Logistics (Invoice
Procure to Pay PTP - 18 Procure to Pay
Processing)

Vendor Reconciliations
Procure to Pay PTP - 19 Procure to Pay and recoveries (Balance
Confirmation)

Customer Master
Revenue REV-01 Revenue
creation

SO Order Batch (Other


Revenue REV-03 Revenue
than lifestyle & Cocoon)

SO Order Batch
Revenue REV-04 Revenue
(Cocoon)

Price determination and


Revenue REV-05 Revenue
Listing (DTC - Lifestyle)

Discount Approval (DTC-


Revenue REV-06 Revenue
Lifestyle)

Collection (Other than


Revenue REV-08 Revenue
Lifestyle)
Collection
Revenue REV-09 Revenue
(DTC - Lifestyle )

Revenue REV-10 Revenue Revenue Recognition

Sales return (Credit


Revenue REV-11 Revenue
Note)

Reconciliation - OCC vs
Revenue REV-12 Revenue
Tally

Reconciliation for
Lifestyle - Unicommerce
Revenue REV-13 Revenue
vs Tally, Manual tracker
vs Tally

Customer Balance
Revenue REV-14 Revenue
confirmation

Provision for doubtful


Revenue REV-15 Revenue
debts

Taxation - Tax Deducted


Taxation (Direct & Indirect Taxation (Direct &
Tax - 01 at Source (TDS) -
Taxes) Indirect Taxes)
Calculation and Payment
Taxation - TDS Return -
Taxation (Direct & Indirect Taxation (Direct &
Tax - 02 Salary (24Q) / Non
Taxes) Indirect Taxes)
Salary (26Q)

Taxation (Direct & Indirect Taxation (Indirect Taxation - Goods and


Tax - 08
Taxes) Taxes) Service Tax Master

Taxation - Goods and


Taxation (Direct & Indirect Taxation (Indirect Service Tax (GST)
Tax - 09
Taxes) Taxes) Calculation, Payment
and Return filing

Taxation (Direct & Indirect Taxation (Indirect Taxation - GST ITC


Tax - 10
Taxes) Taxes) reversal
Taxation (Direct & Indirect Taxation (Indirect Taxation - GST on
Tax - 11
Taxes) Taxes) Export Items

Taxation (Direct & Indirect


Tax - 15 PF & PT returns Filing of PF & PT Returns
Taxes)

Bank account opening


Treasury TRE- 01 Treasury
and closure

Change in authorized
Treasury TRE- 02 Treasury
signatories

Bank account
Treasury TRE- 03 Treasury
reconciliation

Treasury TRE- 04 Treasury Payment Gateway


Board approvals for
Investments - Mutual
Treasury TRE- 05 Treasury
Funds (MF) / Fixed
Deposits (FD)

Investments - Mutual
Treasury TRE- 06 Treasury Funds (MF) / Fixed
Deposits (FD)

Closure of Mutual Fund /


Treasury TRE- 07 Treasury
Fixed Deposit

Treasury TRE- 10 Treasury Approval for Borrowings

Borrowings (Term Loan,


Treasury TRE - 11 Treasury WCDL, OD, SCF) and
Letter of Credit

Treasury TRE - 12 Treasury Loan covenants

Treasury TRE - 14 Treasury Reporting Covenants

Treasury TRE - 15 Treasury Repayment of loan


Treasury TRE - 16 Treasury Finance charges

Treasury
TRE - 20 Resha Mudra Onboarding
(Resha Mudra)

Treasury
TRE - 22 Resha Mudra Credit appraisal
(Resha Mudra)

Treasury
TRE - 26 Resha Mudra Collection
(Resha Mudra)
Treasury Delinquency
TRE - 27 Resha Mudra
(Resha Mudra) (Bad debts)

Treasury
TRE - 28 Resha Mudra Interest income
(Resha Mudra)

Charges Levied -
Treasury Penalty Charges(Delay
TRE - 30 Resha Mudra
(Resha Mudra) in payment or Interest
on Delay Payment-IOD)

Financial Statement Closure Financial Statement Chart of Accounts - GL


FSC 01
Process Closure Process Creation/modification

Financial Statement Closure Financial Statement Chart of Accounts -


FSC 02
Process Closure Process Review

Financial Statement Closure Financial Statement Checklist for closure of


FSC 03
Process Closure Process Books of Accounts

Financial Statement Fixed Assets - Addition,


Financial Statement Closure
FSC-18 Closure Process (Fixed FAR and GL
Process
Assets) reconciliation
Control owner

Secretarial/Legal Team

HR, Legal

HR Team

Business Finance

CEO/ CFO

HR - Recruitment Team

HR - Recruitment Team
HR - Operations Team

HR - Payroll Team &


Accounts Team

HR - Payroll Team &


Accounts Team

HR Payroll team

F&I Team - Madhuraj

AP Team / Business
Team/F&I Team
AP Team

F&I Team

AP Team

Merchandising Team
(Merchandiser)

Accounts Payable Team


(Ashoka, Pawan,
Dwarkeesh,Ananth)

Business Unit head


Merchandising Team

AP Team

AP Team

Merchandising Team & AP


Team

Business Team

Collection centre
Incharge
Director Facilities &
Infrastructure

Business Finance team &


AP team

Senior Merchandiser

Senior
Manager/Merchandiser
Manager/Zonal Manager
Sales

Senior Manager

Manager(Merchandising)

Store Manager

Accounts Team - Senior


Executive
Accounts Team - Senior
Executive

Assistant Director - FPNA

Senior Merchandiser &


Accounts Team - Senior
Executive

Business Team

Merchandising Team

Business Team/
Accounting Team

Director, Accounts

Tax Team
Tax Team

Tax Team

Tax Team

Tax Team & AP Team

Tax Team

Payroll Manager

Treasury Team - Senior


Manager Finance

Treasury Team - Senior


Manager Finance

Accounts Team- Assistant


Manager Accounts

Accounts Team- Assistant


Manager Accounts
Treasury Team- Senior
Manager Finance

Treasury Team- Senior


Manager Finance

Treasury Team- Senior


Manager Finance

Treasury Team- Senior


Manager Finance

Treasury Team- Senior


Manager Finance

Treasury Team- Senior


Manager Finance

Treasury Team- Senior


Manager Finance

Treasury Team- Senior


Manager Finance
Treasury Team- Senior
Manager Finance

Reshma Mudra team

Resha Mudra team- Zonal


Credit Manager

Resha Mudra team-


collection Manager
Resha Mudra team -
Senior Manager Finance

Resha Mudra team -


Senior Manager Finance

Resha Mudra team -


Senior Manager Finance

Accounts Team -
Assistant Manager

Accounts Team - CAO

Director Accounts

Accounts Team -
Assistant Manager
Control Activity Description

The Board provides oversight of management activities through periodic (quarterly)


meetings. The Board reviews and discusses the corporate goals and objectives and
monitors and evaluates the operational and financial performance of the Company.

The company has defined a Whistle-blower policy that contains the email id and
contact details (available on website) to which complaints can be sent by any
employee/ director/ third party. Whistle-blower policies are part of the induction kit
circulated to employees on joining. Vendors are educated on the whistle blower
mechanism at the time of on boarding.

The policy is approved by the Board of Directors and reviewed on an annual basis for
any changes.

A Code of Conduct (CoC) is in place to monitor the acceptable business practices,


conflicts of interest and expected standards of ethical behaviour. The new employees
are required to sign copies of CoC policies during the induction.

The CoC is accessible through the Company's website.

Yearly code of conduct refresher session are required to be conducted for all
employees.

The company maintains key policy/ procedure documents relating to various


functions that are approved by the respective functional heads.

These documents are reviewed on a periodical basis for necessary changes and all
the changes are approved by authorized persons. Key policy documents are available
on the shared portals and are accessible by relevant team members.
Assignment of responsibility (including who is authorized to initiate and/or change
transactions) and delegation of authority exists through an approval matrix. The
authorization matrix sets approval levels for purchases and contracts based on the
individuals' level within the organization. Any changes to the approval matrix is
reviewed and approved by CEO/CTO and CFO.
The respective department raises a manpower requisition and the same is approved
by respective Function Head and CEO/CTO.
Basis the approved requisition, Job ID is created in ZOHO.
Offer letters are linked to job id and automatically routed for approval (HR Head & BU
Head) prior to delivery to the candidate.

Background verification (BGV) for new employee is carried out by the contracted
vendor. It is initiated and tracked by the HR Recruitment team.

Candidates with Red BGV report are evaluated for continuity by CEO/CTO.
Candidates with Amber/Orange BGV report are evaluated for continuity by HR Head.
Offered candidates submit their documents and other details (such as PAN, Bank
details, UAN, etc.,) through a link provided by Onboarding team. After validation of
data, same is entered in ZOHO by Onboarding team after which Employee ID and
master data gets auto created.

For existing employees - Request for change in employee data is communicated by


the employee to HR team through emails along with relevant supporting.

Payroll team reviews the final pay register. Issues ,if any, are discussed and resolved
with Payroll vendor and confirms for final Paypro file generation.
Paypro file is shared with CAO for uploading file on the bank portal.
Accounts manager prepares and post JV for payroll

Statutory dues on account of TDS/PT/PF/ESI are calculated as part of the monthly


payroll output by payroll vendor. Statutory deductions are reviewed and approved by
Payroll Manager. Payroll vendor generates the draft challan for payment of respective
statutory dues and shares with the Payroll Team and Accounts team for payment.

Revision to compensation applicable due to promotion or appraisal is recommended


by BU Head and approved by Management (CEO/CTO).

Post approval, changes/revisions are communicated to payroll vendor as part of


monthly input file.
Contract for goods/services with the vendor is created as per need basis and vetted
by legal team. These are approved as below -:
- Up to INR 1 Lakh - By respective Business Head and F&I Head
- Above INR 1 Lakh -: By respective Business Head, F&I Head and CTO/CEO.

For F&I procurement: Receipt of goods/services are confirmed by respective user.


Vendor invoices are reviewed and approved by F&I Head.

Other department procurement : Receipt of goods/services are confirmed by


respective user. Vendor invoices are reviewed and approved by respective Business
Head and F&I Head.

Post approval, invoices are shared with the AP team for accounting and payment.
Accounting entries are posted AP Manager.
(Refer FSCP -10 for Asset Capitalization)
Respective user departments identify the list of invoices due for payments and share
with the F&I Team. F&I Team (designation. of Madhuraj.) reviews the payee details
with the vendor master and forwards the list to AP team (marking respective
Business Head, F&I head and CAO).
AP team further reviews the invoice list with the vendor's ledger and shares the
Payment Upload file with the Accounts Team (designation of. Ashoka) who then
uploads the file on Razor Pay for payment.
List of vendors identified for balance confirmation is prepared by Account Team and
approved by CAO.
Reconciliation is prepared by AP Team Executive and reviewed by CAO. Correction
entry, if any, is made by AP Team Executive and approved by CAO.

Employee raises request for advance to the Reporting Manager.


Reporting Manager approves and forwards the request to Business Head for final
approval.
This is shared with AP team for payment processing and accounting.
After completion of trip, employees raises reimbursement claim in ZOHO against
which advance amount is settled by AP team.

Vendor Master is created/modified in OCC by Merchandiser/Data Analyst basis the


KYC/change documents collected from respective vendors.
Respective Vendor Masters are activated for transaction in OCC post KYC verification.

Note-:
a. Farms- Raw Cotton,Chawki,Cocoon,Pupae - KYC verification is done manually
b. In other cases - KYC verification is done through OCC's interface with respective
Government (GSTN, MSME) and Consultant's Portals (Karzaa)

Razorpay Payee master is created/modified by AP Team basis the inputs and


documents received from the respective Merchandising Team/ Business team.

Category and Grade-wise index price for procurement of Cocoon is collected the BU
and the final price is approved by the BU Head. Post approval, the index price
(Recommended Rate) is updated in OCC by Data Analyst. A workflow approval is
defined in OCC for procurement of Cocoon at a price higher than the Recommended
Rate.
Respective Merchandisers review and record vendor invoices against the Purchase
Batch in OCC and shares with respective BU Head for approval.
Post approval, Merchandiser shares the invoice details with AP Team(Senior
Executive) for recording in Tally.

For Yarns and Cocoons -


Respective BU Manager selects the open invoices and initiates the payment request in
OCC. As per the workflow defined in OCC, the payment request is reviewed and
approved by the AP Team - Assistant Manager(Yarns)/Senior Executive(Cocoon).
OCC is interfaced with Razorpay wherein the payment is processed by the AP team
directly to the vendor's account through Razorpay.
Accounting entries are posted by AP team in Tally post payment is made.

Post approval from respective Business Unit Head, BU teams share a list of vendor
payments to be made with the Chief Accounts Officer(CAO).
In case of payment through Bank transfer, CAO initiates the required fund transfer to
Razorpay wallet from respective bank accounts which is approved by Board
Authorized Signatories.

Payment is processed by the designated AP team member (Senior Executive) to the


vendor's account through Razorpay.
Accounting entries are posted by AP team in Tally post payment is made.

Sourcing(For Weaves)/Merchandising Team(For Farms and Yarns) creates a Purchase


Batch return in OCC basis email approvals from respective BU head.
Purchase Batch Return is approved as per approval matrix in OCC and shared with
Senior Executive (AP Team) through mail.
Senior Executive (AP Team) reviews approval details with supporting documents and
raises Debit note in Tally.
On monthly basis, a reconciliation for purchases as per OCC and Tally is prepared by
Assistant Manager(AP Team). This is reviewed by Assistant Manager (Business
Finance).
Discrepancies if any, are investigated and resolved.

Weaves -
Logistic vendors are selected and approved by Associate Director (F&I).
Contracting with logistic vendors are created in a pre-vetted format by the legal
team. This is reviewed and approved by Associate Director (F&I).

Others -
Logistic vendors are selected and approved by respective BU Manager on a spot
basis.
Weaves -
Logistic request is raised in OCC against respective purchase order by respective
Merchandisers. Basis this, transportation services are facilitated by F&I Team with the
contracted vendors or on spot basis. Vendor invoices are reviewed and approved by
Associate Director (F&I) and shared with AP team for accounting in Tally.

Others-
Transportation services are facilitated by on-field supervisors on spot basis post
discussion with the respective BU Managers. Vendor invoices are reviewed and
approved by respective BU Managers basis and shared with AP team for accounting in
Tally.

Current design gap - Vendor Reconciliations and recoveries (Balance Confirmation).

Customer Master is created/modified in OCC by Merchandiser/Data Analyst basis the


KYC/change documents collected from respective customers.
Respective customer Masters are activated for transaction in OCC post KYC
verification.

Control Gap - Collection of KYC documents from customers are not mandatory at the
time of onboarding.

Sales team creates a Sales Order Batch in OCC linked to a Purchase order batch basis
email approvals from respective BU head.
An approval matrix is configured in OCC for the approval of margin (Sales order batch
(-) Purchase order batch).

Design Gap - On-field Sales Team (For Cocoons) creates a Sales Order Batch in OCC
basis email/verbal approvals from respective BU Manager.

Sales Price is reviewed and approved by the Assistant Director E-commerce.


Merchandising Team updates the approved prices for retail store in Zwing portal and
on marketplace.

Discount/promotions are proposed by Assistant Manager (Merchandiser & Operations)


is reviewed and approved by the Assistant Director E commerce.
Merchandising Team updates the approved discount on retail store in Zwing portal
and on marketplace.

Basis inputs from the Collection Team, Senior Executive (AR Team) confirms receipt
of amount in the bank statement and records the entry in Tally. Collection details are
also updated in OCC against the Sales order batch.

Design Gap - For weaves OCC is not updated with collection details. For Yarns and
Farms - Collection details is updated in OCC against Sales order batch details.
Basis inputs from the Assistant Manager (Operations), Senior Executive (AR Team)
confirms receipt of amount in the bank statement and records the entry in Tally.

'Collection made from Logistics partner for COD sales- Sales through Company's
website on COD basis are recorded as receivables from logistics vendor basis the
inputs from Assistant Manager (Operations). Collections are recorded in the manner
mentioned above.

Current Design Gap - Revenue Recognition monthly Basis

Sales Team creates a Sales Batch return in OCC basis email approvals from
respective BU head.
Sales Batch Return is approved as per approval matrix in OCC and shared with Senior
Executive (AP Team) through mail.
Senior Executive (AP Team) reviews approval details with supporting documents and
raises Credit note in Tally.

Control Gap -
1. There is no mechanism to track receipt of returned goods at the
warehouse/vendors.
2. Farms - Sales batch return is not created in OCC. Credit note is created in Tally
basis email approval from respective BU Heads.

On monthly basis, a reconciliation for sales as per OCC and Tally is prepared by
Assistant Manager - Accounts. This is reviewed by Assistant Manager (Business
Finance).
Discrepancies if any, are investigated and resolved.

Design Gap - Reconciliation for Lifestyle - Unicommerce vs Tally, Manual tracker vs


Tally.

Design Gap - Customer Balance confirmation and reconciliations.

Design Gap - Provision for doubtful debts

TDS liability is recorded at the time of expense booking by the AP Team. On monthly
basis, ledger extracts are shared with consultant for review and calculation of final
TDS/TCS liability. Any shortfall identified is communicated to AP Team for the
accounting adjustment. Tax team collates final calculation from consultant and
submits to CAO for payment processing.

The TDS liability to be paid is reconciled with the TDS liability as per the GL by CAO
for payment processing.
TDS returns are prepared and filed by the external consultant after review by Payroll
Manager (For 24Q) and Tax Manager/F&P Manager (For 26Q).

For every new SKU creation, Merchandise team creates HSN master consisting of
HSN code and tax rate after approval by tax team.
Post SKU creation Tax team performs Trial run to validate that tax rates are updated
correctly.

GST liability and return workings are prepared by Tax Consultant and reviewed by
Tax Manager/F&P Manager prior to monthly payment/filing. Any shortfall/error
identified is communicated to AP Team for the accounting adjustment.

Input tax and output tax is reconciled to Tax GL prior to filing and payment.

Current design Gap - GST ITC reversal.

Current design Gap - GST on Export Items.

Statutory dues on account of TDS/PT/PF/ESI are calculated as part of the monthly


payroll output by payroll vendor. Statutory deductions are reviewed and approved by
Payroll Manager. Payroll vendor generates the draft challan for payment of respective
statutory dues and shares with the Payroll Team and Accounts team for payment.

All bank accounts are opened or closed basis Board Resolution. Documents are signed
by CEO or CTO.

`Any change in authorized signatories is based on valid Board resolution. Accounts


team submits Board resolution copy to respective banks for updation.
- Quarterly/Half yearly authorised bank signatory confirmation are obtained from all
banks and it is compared against the board resolution.
- Confirmation for continuation of signatories with the organization.

On a monthly basis, bank reconciliation is prepared by AP Team and reviewed by


CAO. Correction entry, if any, is made by AP Team Executive and approved by CAO.

On a monthly basis, reconciliation is prepared by AP Team and reviewed by CAO.


Follow up to resolve reconciling items is made by AP team.
A Board resolution is passed authorizing the company and specifying the authorized
signatories(CEO/CTO) to invest in Mutual Funds / Fixed Deposits.

Availability of funds for investments is approved by the CFO basis the monthly fund
forecast report prepared by Accounts Team.
- In case of Mutual Funds (MF), investments are made out of the options provided by
the approved consultants(BK securities). This is reviewed by CAO and approved by
CEO/CTO.
- In case of Fixed Deposits (FD), investments are reviewed by CAO and approved by
CEO/CTO.
- Journal entry is recorded by Accounts Team

- Redemption / closure of investments is reviewed by CFO and approved by the


CEO/CTO
-Details of all investments and Profit/ Loss from investment is accounted basis the
statement received from Fund managers / Bank. This is reviewed and approved by
Treasury Manager.
Journal entry is prepared by accounts team basis the above approvals.

-A Board resolution is passed authorizing the company on below points - :


- Defining the overall borrowing limit
- Institution specified for borrowing.
- Instrument of borrowing
- Specifying the authorized signatories for borrowing documentation.
- Organization Policy borrowing (Currently not available)
Requirement for borrowings is reviewed by the CFO and approved by authorised
signatories.
- Journal entry is recorded by Accounts Team basis above approval and loan
statement.
Treasury Team(Senior Manager) prepare Loan covenant Tracker which highlight
timelines for repayment of Loans.
Tracker will be circulated with all stakeholder on monthly basis.

Treasury Team(Senior Manager) share tracker for required documents(stock


statement, Drawing statement etc) and supporting's to be collected and shared as
per requirement of lender/Banks with stakeholder on monthly/quarterly basis.

`Treasury Team prepares monthly schedule and is shared with CAO for review.
Repayment is initiated by accounts team and reviewed by CAO and approved by
CEO/CTO on the bank portal.
Treasury Team calculate finance charges on each sanctioned loan amount on monthly
basis and cross verify with charges levied by lenders. Any discrepancies are reviewed
by Senior Manager(Treasury) and necessary action initiated with lenders to resolve
the issue.
- Journal entries is prepared by accounts team based on calculated finance charges
for each loan amount.

Sales Team initiates customer account creation on Loan Origination System (Tyrion).
Following points are checked by Onboarding Team against the conditions laid down in
Corporate Credit Policy, prior to onboarding a customer-:
1. Original Seen and verified (OSV) online through KARZA (tool) - Onboarding team
verifies the KYC documents against the original.
2. Unit Inspection Report - This is prepared by Sales Team after verifying Customer`s
business premise through field visit along with images collected as evidence.
3. Telephonic Verification (TVR) - All references and details mentioned in loan
application form are cross -verified through TVR by the Credit Team.
5. Credit Score (For individuals/Proprietorship) - Credit score is validated through
report provided by CIC (Experian) not older than 30 days. CIC should be 700 or
above out of 900. For Corporates Credit evaluation is performed basis financials
reports.
6. Bank Statement Analysis(BSA) - Customers active bank account statement for 1
year are reviewed by Credit Team through Precissa Application.
7. Customer Scoring - Customers rating is done through an in-house tool basis the
loan application and supporting documents. Threshold limit is 80 out of 100.

Any deviations (Refer Corporate Credit policy) from the pre-laid conditions are to be
approved by the authorized person(Zonal Credit Manager) as per Board approved
Corporate Credit Policy.

Credit appraisal of customer is performed by Credit Team as per process defined in


Corporate Credit Policy and approval is provided by Zonal Credit Manager .
Any deviation to the Corporate Credit policy is done by ReshaMudra Lead.

Collection Team updates the collections in the Tyrion system against the customer
loans after confirmation from Reshamudra Finance Team on the receipts in the bank
statement. ReshaMudra Finance Team records the collection entry in the respective
customer ledger in Tally.

Money collected should be allocated to overdue interest/interest outstanding,


principle outstanding and charges outstanding respectively(IPC method).
Post 90 days DPD (Days Past Due), 10% provision is calculated and shared by
ReshaMudra Finance Team(Senior Finance Manager) for MIS reporting and shared
with Business Finance Team(VP - Business Finance) for accounting in Tally.

Interest income is auto calculated by Tyrion and accrued on daily basis for loan
amount in line with loan agreement and Corporate Credit policy. Interest Income
accrual entry is booked in Tally by Accounts Team on monthly basis.

On completion of loan tenure final receipt of Interest and principal amount is booked
on Tyrion and accounted in Tally accordingly by Accounts Team.

Penalty charges is auto calculated on Tyrion as per rate mentioned in loan agreement
and accounted in Tally.

Accounts Team receives request from various departments for GL creation. Based on
the request, approvals are obtained from CAO/CFO/Director Accounts. The
approved GL is created in Tally by the Assistant manager accounts/Senior Executive
Accounts.

Control Design Gap

An Activity checklist is maintained by the CAO, specifying the month end activities
such as Purchase controls, sales control, accounting of prepaid expenses, expense
provision etc. to be carried out. The checklist is reviewed and approved by Director
Accounts.
The completeness of activities are reviewed by the CAO and a confirmation mail is
sent to Director Accounts.
The access to open/close accounting periods is restricted to authorized individuals
basis approval from CFO.

Accounts Team Member performs the following:


1. Reviews that transactions posted to Fixed Assets (asset additions) are
appropriately classified as fixed assets, have been assigned the appropriate asset
type according to capitalization policy and updated in manual Fixed Asset Register
(FAR).
2. Performs a review of reconciliation between GL balance and FAR prepared by F&I
Team personnel.
Fraud Risk Key

Board of Directors do not meet to


review financial results and assess
No Key
internal control as required by
statutory law.

Employees act unethically in


business matters.
Ethics and Compliance issues are
No Key
not communicated timely or to the
right level of management to
address.

Departures from Code of Conduct


(CoC) are not identified and acted
upon. Absence of a CoC and ethics
policies regarding acceptable
No Key
behaviour, business practices,
conflicts of interest and relationships
with customers, solicitors, and other
third parties

Divergent practices in the absence


No Key
of standard procedures

Expenditures or commitments are


Yes not in accordance with the Key
established authorization policy.

Unauthorized hiring and additions


Yes are made to Human Resources or Key
Payroll data.

Employees with undesirable


Yes Key
background are recruited.
Fictitious employees are added to
the employee master
Yes Key
Incomplete/inaccurate employee
records in employee master.

Inaccurate, incomplete and non


timely recording of payroll
transactions resulting in incorrect
books of account.
Yes Key
Incorrect salary payment to
employees

Incorrect, inaccurate statutory dues


deducted and paid. Non payment of
No Key
statutory dues before due dates
may lead to fines and penalties

Unauthorized and inaccurate


Yes additions, deletions or modifications Key
are made to Payroll data

Yes Unauthorized procurement Key

1. Purchases not supported by


evidence of receipt of services
Yes Key
2. Inaccurate and incomplete
recording of transactions
Incorrect payment may lead to
Yes Key
financial loss

Unreconciled / incorrect vendor


No Key
balance

Unauthorised advances paid to


Yes Key
employees

Unauthorized vendor onboarding


Yes and changes are made to vendor Key
bank account

Unauthorized vendor onboarding


Yes and changes are made to vendor Key
bank account

Yes Unauthorized procurement of goods. Key


Unapproved invoices may be
processed leading to unauthorized
payments.
Yes Key
Incorrect accounting entries getting
posted there by leading to incorrect
financials.

Incorrect payment may lead to


Yes Key
financial loss

Incorrect payment may lead to


Yes Key
financial loss

Unsellable goods are not returned to


No Key
vendors resulting in financial loss.

Incomplete purchases are recorded


No Key
in Tally

Unauthorized selection resulting in


Yes invalid transactions & higher costs Key
to the Company.
Unapproved invoices may be
processed leading to unauthorized
payments.
Yes Key
Incorrect accounting entries getting
posted there by leading to incorrect
financials.

Absence of vendors balance


No confirmation may lead to inaccurate Key
accounts payable ledger.

Duplicate and fictious customer


Yes Key
onboarding

Wrong quantities of goods are sold


Yes Key
and at incorrect price

Wrong quantities of goods are sold


Yes Key
and at incorrect price

Yes Listing of products at incorrect price Key

Decline in profitability due to


Yes Key
unauthorised discount.

Collections are accounted incorrectly


Yes Key
for the sales made.
Collections are accounted incorrectly
Yes Key
for the sales made.

Inaccurate revenue recognition


No resulting in incorrect presentation of Key
financial statements

Credit note are processed to the


Customer without the receipt of
Yes Key
returned goods and approval from
authorized personnel.

No Incomplete sales is recorded in Tally Key

No Incomplete sales is recorded in Tally Key

Absence of customer balance


No confirmation may lead to inaccurate Key
accounts receivable ledger.

Possibility of unauthorized write-off


Yes Key
of Bad debts without provision

-Interest / Penalties can be imposed


if inaccurate TDS is deposited
No -Incorrect, inaccurate TDS Key
accounting entries resulting in
incorrect TDS balances
Interest / Penalties can be imposed
No for non-filing/ late filing/ incorrect Key
filing of TDS

Sales being billed at incorrect tax


No Key
rates.

Non payment within the due date


might attract penalties.
Incorrect CGST/SGST/IGST
No disclosed in returns resulting in Key
interest/penalties being imposed.

ITC reversal negligence attract


No Key
penalty
Non receipt of GST refund causes
No Key
financial loss

PF & PT returns not filed within the


Yes Key
due dates/filed incorrectly

Bank account opening and closure


No are not authorized by Board Key
Resolution.

No Unauthorized bank transactions Key

Unreconciled transactions not


Yes monitored or identified for Key
resolution.
Unreconciled transactions not
Yes monitored or identified for Key
resolution.
No Unauthorized Investments Key

1. Unauthorized investments
No 2.Incorrect representation of Key
investment in financial statements

1.Redemption / closure of
investments are not authorized by
No appropriate personnel. Key
2.Incorrect representation of
investment in financial statements

Yes Unauthorized borrowings Key

Excess loans leading to inefficient


utilization of funds / shortage of
Yes Key
working capital leading to disruption
of business.

Delay in loan repayment attracts


No Key
penalty and effects credit rating

Missing Documents and letters


No Key
impact loan sanction

Delay in loan repayment attracts


Yes Key
penalty and effects credit rating
Incorrect finance charges may be
Yes Key
levied by lenders.

Misrepresentation of facts,
fake/manipulated document
No Key
submitted for credit evaluation.

Probability of default in case the


Yes customers' credit appraisal is not Key
performed.

Incorrect allocation of collections


resulting in misappropriation of
books.
Incorrect details mentioned in cash
Yes Key
& cheque summary regarding
receipt number, loan agreement
number, deposition date, bank
account number etc.
Inaccurate/ inadequate provisions
Yes Key
created

Incorrect recognition of interest


Yes Key
income

Incorrect recognition of charges


Yes Key
levied

No standard chart of accounts


Yes exists. Creation of unauthorized/ Key
fictitious accounts

No Risk of creation of duplicate GL Key

Delay in completion of monthly


activities

Inadequate segregation of duties


No resulting in incorrect accounting/ Key
reporting

Invalid journal entries are passed in


the wrong accounting period.

Asset acquisitions are not recorded


Yes Key
accurately
Type of Control Nature of Control
Frequency
(Automated or Manual) (Preventive or Detective)

Manual Preventive Quarterly

Manual Detective Event Based

Manual Preventive Annual

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based


Manual Preventive Event Based

Manual Preventive Monthly

Manual Preventive Monthly

Manual Preventive Half Yearly

Manual Preventive Event Based

Manual Preventive Event Based


Manual Preventive Event Based.

Manual Preventive Annually

Manual Preventive Event Based.

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based


Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Manual Detective Monthly

Manual Preventive Event Based


Manual Preventive Event Based

Manual Preventive Annual

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Semi Automated Preventive Monthly


Manual Preventive Monthly

Manual Preventive Yearly

Manual Preventive As needed

Manual Detective Monthly

Manual Detective Monthly

Manual Preventive Annual

Manual Preventive Yearly

Manual Preventive Monthly


Manual Preventive Quarterly

Manual Preventive As needed

Manual Preventive Monthly

Manual Preventive Monthly

Manual Preventive Event based

Manual Preventive Monthly

Manual Preventive Event Based

Manual Preventive Event Based

Manual Detective Monthly

Manual Detective Monthly


Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Monthly

Manual Preventive Monthly

Event Based
Manual Preventive (Should be
Monthly)
Manual Preventive Monthly

Manual Preventive Event Based

Manual Preventive Event Based

Manual Preventive Event Based


Manual Preventive Event Based

Automated. Preventive Event Based

Automated. Preventive Event Based

Manual Preventive Event Driven

Manual Detective Yearly

Manual Detective Monthly

Manual Detective Annually


TOD TOE

Pass Pass

Pass Pass

Pass Pass

Fail Fail

Fail Fail

Pass Pass

Pass Pass
Pass Pass

Pass Pass

Pass Pass

Pass Pass

Pass Fail

Pass Fail
Fail Fail

Fail Fail

Pass Fail

Fail Fail

Fail Fail

Fail Fail
Fail Fail

Fail Fail

Fail Fail

Pass Fail

Pass Fail

Fail Fail
Pass Fail

Fail Fail

Pass Fail

Pass Fail

Fail Fail

Fail Fail

Pass Fail

Fail Fail
Fail Fail

Fail Fail

Fail Fail

Pass Fail

Fail Fail

Fail Fail

Fail Fail

Fail Fail
Fail Fail

Fail Fail

Pass Fail

Fail Fail

Fail Fail

Pass Pass

Pass Fail

Pass Pass

Fail Fail

Fail Fail
Fail Fail

Fail Fail

Fail Fail

Pass Fail

Pass Fail

Pass Pass

Pass Pass

Pass Fail
Fail Fail

Pass Fail

Pass Fail

Pass Pass
Fail Fail

Pass Pass

Pass Pass

Fail Fail

Fail Fail

Fail Fail

Pass Pass
Remarks - Deloitte

Services - No evidence of circulation of notices for the Board meeting sent to one of the directors
(Nominee director).

Policy issues date - 17 Mar 2023.

Whistle-blower policy not communicated to third party/Vendor.

No CoC Sign offs taken from new joined employees. Code of Conduct is part of the Induction
Deck.

Business side policies and procedures not available. - Refer Internal audit observation.

HR policies and procedures available.

DOA matrix is not available.

CEO/CTO approval for MRF is manually selected and not a mandatory field.

TAT for action to be taken post receipt of BGV from vendor not defined in the BGV Policy.
Internal Audit Observation

Post disbursement salary reconciliation - Currently, there is no standard process followed for
reconciling the final bank upload file with bank statement after disbursement of salary.

1. No evidence of review of TDS Returns sent by external consultant to Reshamandi team.


2. Payroll data encryption - Final bank upload file and pay register are received in spreadsheet
format without encryption or password protection from the vendor.
3. Delegation of Authority (DOA) not documented - Absence of documented DOA stating the roles
and responsibilities for review and authorization of payroll data exchange and finalization.
4. Guidelines for data transfer to Payroll Vendor - Absence of documented guidelines defining the
protocols for data exchange with payroll vendor. Vendor uses a generic as well as personal email
ID whereas Payroll team members use their respective email IDs for data exchange.

Business head recommendation not documented - 20 instances.

1. No legal review evidence - 5 instances.

2. Contracts not signed by RM/Vendor - 3 instances.

1. Criteria for review and approval of invoice (DOA matrix) is not available/documented.

2. Evidence of invoice reviewed and approved by respective Business Head/F&I Head not
available. Only Approval for payments taken.

3. Evidence of payment reviewed and approved by respective Business Head/F&I Head while
payment not available for 10 cases.

4. Receipt of goods/services confirmed by respective user not available. Payment request is


considered as user confirmation.
1. AP team is not authorized by the board for payment.
Delegation of authority for payments through Razorpay not documented.

2. No evidence of involvement from F&I team in 17 cases, the invoices are approved by BU heads
and shared with AP team for payments.

There is no formal process for defining the selection of vendors for obtaining balance confirmation,
and there is also no process for reviewing the reconciliation of balances obtained and adjustment
entries posted in Tally, if any.

1. Company does not have any ageing report for advances.

2. Not able to evidence the approval from BU heads/Reporting manger for 8 cases.

3. No flow in Zoho for approval and settlement of advances. Advances are approved over mail and
no tracker maintained for employee advances.

1. For IOT and Inputs vendor master are maintained in Excel sheet.

2. No guidelines for vendor onboarding process.

3. No modification email evidence available.

4. Bank documents collected from vendors not available - 25 instances.

5. vendor was onboarded after KYC verification resulted in negative - 2 instances.

6. KYC documents collected from vendors not available - 12 instances.

7. KYC verification on OCC - evidence not available - 17 instances.

1. Maker checker control is missing on Razorpay.

2. Razorpay does not restrict Creation of duplicate payee details.

3. In 6 instances no mail communication for sharing of bank details was available.

Index price (Daily recommended price) is not reviewed before updating in OCC.
Index price screenshot from OCC not provided.
Weaves and Yarns - Purchase is booked in Tally based on the invoice details updated taken in
OCC.
Cotton, Cocoon and Chawki - Approvals are informally taken on WhatsApp.
Lifestyle - Purchase is booked in Tally based on the physical invoice copy.

Farms - Invoice number not updated in OCC, the details are entered in OCC. - 8 instances.

Cocoon - Coupon amount is not entered in invoice or OCC, but updated in tally - 1 instance.

AP team is not authorized by the board for payment.


Delegation of authority for payments through Razorpay not documented

Cocoon - Evidence of payment request being reviewed and approved by the AP Team - Assistant
Manager(Yarns)/Senior Executive(Cocoon) in OCC not available. Approval taken through
WhatsApp for cocoon.

Yarns - Approval flow in OCC implemented and was begun operation in the month of Mar-23. Prior
to Feb'23 approvals were taken through mail communication.
No approval taken for payment - 6 instances.

(Refer weaves P2P report for more details)

AP team is not authorized by the board for payment.


Delegation of authority for payments through Razorpay not documented

Not able to evidence the approval by BU head - 2 instances.

(Refer weaves P2P report for more details)

1. Control Gap - Farms - Purchase batch return is not created in OCC. Debit note is created basis
email approval from respective BU Heads.
2. Complete flow not live on OCC.

Not able to evidence approval from BU head - 4 instances.

Review of Reconciliation not available for Farms.


Month on month reconciliation not provided for farms.

Others - BU Manager approval not documented , However, Approvals are decided on ground/spot
basis the lowest quote received for the respective trip from available vehicles.
No guidelines for rate negotiation or formal contract with the vendor.

Weaves - Agreements not signed - 5 instances.


Legal review mail not available - 2 instances.
Others - No evidence for approval for logistic in Cocoon.

Yarns - No mail communication available - 1 instance.


Logistics request not raised in OCC.

There is no formal process for defining the selection of vendors for obtaining balance confirmation,
and there is also no process for reviewing the reconciliation of balances obtained and adjustment
entries posted in Tally, if any.

1. No modification email evidence available.


2. No guidelines for customer onboarding process.
3. KYC documents collected from the customers not available - 19 instances
4. Kyc verification evidence not available - 17 instances.
5. Control Gap - Collection of KYC documents from customers are not mandatory at the time of
onboarding.

Farms - No approval matrix flow in OCC/Approvals not provided.

Yarns - Supporting mail for margin approval matrix attached. Sales orders approved as per
approval matrix. Implementation in the month of September-22.

Design Gap - On-field Sales Team(For Cocoons) creates a Sales Order Batch in OCC basis
email/verbal approvals from respective BU Manager.
No approval matrix flow in OCC.

No mail evidence prior to December and post December as no new SKU was added.

No discount approval mails provided for offers/Sale that took place prior to December,22.

1. Design Gap - For weaves OCC is not updated with collection details. For Yarns and Farms -
Collection details is updated in OCC against Sales order batch details.

2. Mail communication for collection details and confirmation on receipt of the same in Bank by AR
team not available.
Farms - OCC is not updated with the collection details - 9 instances.
Weaves - OCC is not updated with the collection details - 7 instances.

(Refer Weaves and Farms revenue report with reference to AR Ageing for more details)
Mail communication of collection details and confirmation in bank by AR team - Not available
Collection data prior to October not available.

Revenue was recognized in Tally on the date of invoice creation in OCC and it is not mandatory to
capture POD details in OCC.

1. There is no mechanism to track receipt of returned goods at the warehouse/vendors.

2. No workflow defined in OCC for credit notes. Credit notes are created in Tally.

3. Mail communication for approval of sales order batch/Credit note not available - 4 instances
(lifestyle).

Population data was taken from Tally.

Review of Reconciliation not available for Farms.


Month on month reconciliation not provided for farms for the months of Dec-22 and Jun-22 .
Difference found in reconciliation of farms.

Design Gap - Reconciliation not performed

There is no formal process for defining the selection of customers for obtaining balance
confirmation, and there is also no process for reviewing the reconciliation of balances obtained and
adjustment entries posted in Tally, if any.

Design Gap - Not control currently

1. Tax team does not collate the date to be shared with the consultants.
2. No mechanism of review and approval followed.
3. No reconciliation of tax liability as per workings to Tax GL available for the month of July.
4. Differences noted in the reconciliation for the Oct-22 and Feb-23 and rectification entry
evidenced.
1. Q2 - No review of the return before filing by Payroll/Tax manager for 24Q and 26Q.
26Q for Q2 returns filled post due date (30th October,2022) on 30th Novemeber,2022.

2. Q4-Payroll manager does not review the 24Q Returns before filing.

No evidence documented for approval of Tax team for the HSN code being added to HSN master.

No approval mechanism of GST liability and return workings for the months of Jul-22 and Oct-22.
Amendments made are available in the working file, but mail communication not available to the
external consultant for the amendments in Jul-22 and Oct-22.Review evidence for reconciliation of
input and output tax to GL not available.

Design Gap - Reported In internal Audit

Design Gap - no control

1. No evidence of review of TDS Returns sent by external consultant to Reshamandi team.


2. Payroll data encryption - Final bank upload file and pay register are received in spreadsheet
format without encryption or password protection from the vendor.
3. Delegation of Authority (DOA) not documented - Absence of documented DOA stating the roles
and responsibilities for review and authorization of payroll data exchange and finalization.
4. Guidelines for data transfer to Payroll Vendor - Absence of documented guidelines defining the
protocols for data exchange with payroll vendor. Vendor uses a generic as well as personal email
ID whereas Payroll team members use their respective email IDs for data exchange.

1. BR passed for opening of bank account not available - 3 instances.


2. Opening document or equivalent not available - 8 out of 8 instances.
3. Dormant accounts - 2 instances.

Half yearly/Quarterly review of Board signatures not done as there are only 2 Signatories i.e. CEO
& CTO.

As discussed with Jagadeesh, currently there is no process of documenting the review of Bank
reconciliation statement the same was confirmed with the Business finance team.

As discussed with Jagadeesh, currently there is no process of documenting the review of Bank
reconciliation statement and the same was confirmed with the Business finance team.
1. For investment in fixed deposits, no BR provided.
2. For investment in Mutual funds BR copy provided authorising CEO and CTO.

Approval for investment of funds into Fixed Deposit (non lien) not available.

1. Review and Approval mail for redemption - Not available


2. Profit and loss review evidence not available.

1. Board resolution not available - 4 instances.


2. Improvement - It is recommended that the company should have a borrowing policy.

1. Board resolutions authorising signatories for Loans not provided - 4 instances.


2. Improvement - It is recommended to have fund forecast in place.

Process of tracking loan covenants was started in the month of Oct-22.

1. Tracker provided from Oct'22 - evidence of circulation of mail to the stakeholder not provided.
2. Details were shared which were not updated in the tracker - 2 instances.
3. The detail was shared with a delay of 1 month - 1 instance.

1. Fund forecast not prepared.


2. Repayment Mail is sent to CAO for payment on a monthly basis.
3. We have checked the repayments as per schedule on sample basis.

As confirmed with Nikhil, Grow money has not been repaid for the month of Mar'23 as per
schedule.
Monthly review not performed - finance charges calculation reconciled with charges levied by
lenders are reviewed by senior manager (Treasury).

1. Unit Inspection reports not provided - 18 Instances


2. Deviation approval not provided - 1 instance
3. Customers not onboarded on Loan management system - 17 instances.

CAM not available - 1 instance.


Repayment history not available - 1 instance.

Data not updated in Tyrion and are maintained and calculated manually on a tracker for 7 cases.

Data for certain customers are not updated on Tyrion and are calculated and maintained manually
on a tracker. Individuals details are updated in Tyrion.

Collection details are communicated over WhatsApp by collections team and same is verified with
the bank statement.
Improvements - Consolidated collection details can be sent to the accounts team by day-end over
the mail.

IPC to CIP

Old remarks - Highlight as improvement point


As discussed with Sabya, There is no entry in tally for DPD.

MIS working with DPD circulated to Management provided

RBI norms to be followed for Provisioning of assets. Asset classification to be done in a standard
manner, sub standard and doubtful assets.

Old Remarks - Highlight as improvement point

Data not updated in Tyrion and are maintained and calculated manually on a tracker for 9 cases.

Data for certain customers are not updated on Tyrion and are calculated and maintained manually
on a tracker. Individuals details are updated in Tyrion.

Interest to be accrued on daily basis. Batch run to be done and accounting entry to be done at cut
off .

Data not updated in Tyrion for 5 cases.


Data for certain customers are not updated on Tyrion and are calculated and maintained manually
on a tracker. Individuals details are updated in Tyrion.

GL codes are created in tally without Approval. Control design gap

No periodic review in place

1.No monthly book closure checklist maintained by the accounts team.

Evidence of FAR vs GL reconciliation not provided (Improvement)


Remakes by POC - RM

1. Induction Deck is presented to new joiners in which there is a section for


Whistle-blower policy is available on employee portal.
2. Vendors are educated on the whistle blower mechanism at the time of on
boarding - Not available

Code of Conduct is part of the Induction Deck, but no sign offs are not taken from
newly joined employees.

Not available

Offer letter signed by HR head and it is the only approval, BU head approval not
required. Salary is communicated with BU head for the purpose of gathering inputs
regarding the salary offered, and is BU head inputs not compulsory.
Payroll workings will not be shared due to confidentiality reasons, the same was
shown on RM system.

Payroll workings will not be shared due to confidentiality reasons, the same was
shown on RM system.

The email evidence of revised compensation shared to Payroll vendor was shown in
RM System and not shared due to confidentiality reasons.

1. Receipt of goods/services confirmed by respective user not available - Payment


request is considered as user confirmation.

2. Cotton logistics vendors - Invoice is shared through WhatsApp for the purpose of
booking the expense in Tally during emergency situations.
No approval email available - Approvals are taken verbally.

Zoho flow for approving is not applicable.

1. Bank details (passbook/Account details) docs are not available as it were


manually entered in the farmer profiles - 13 instances.

2. KYC not completed, while the purchase invoices have GSTIN mentioned in it- 3
instances.

1. Razorpay Payee master is created/modified by AP Team basis the payments


request mail communication only by the Business team. No documents are
received/reviewed by AP team at the time of master creation.
We are unable to download the Payee master from the razorpay.

2. No Mail Communication for payments made to Chawki and cocoon , Approvals


are done through WhatsApp.

These are taken from sericulture website on which we rely and no mail approval are
required.
Lifestyle - Not integrated with OCC. The tool is solely for inventory management.
Its linked to purchase flow.

Farms & Lifestyle- DN flow not available in OCC.


No debit flow in OCC - Yarns
Provision for debit note Appearance in Occ not available - Weaves
NO OCC Records.

Cotton-No margin and approval process


Weaves - Above 8% there no margin approval
Yarns - Flow not available prior to Sep 22. Supporting mail for margin approval
matrix attached
Farms (Pupae, Cocoon, Chawki and Inputs) No margin and approval flow at the
time of these invoices and No approval required since sale orders will be default
accepted by the system.
Farms (Pupae, Cocoon, Chawki and Inputs) No margin and approval flow at the
time of these invoices and No approval required since sale orders will be default
accepted by the system.
No mail evidence prior to December and post December no new SKU was added.
Zwing - Tool used to only book for the sales. Currently, its discontinued and
tracking is done manually.
People associated with the process prior to dec are no more in the organisation.
No mail evidence prior to December and post December no new SKU was added.
Zwing - Tool used to only book for the sales. Currently, its discontinued and
tracking is done manually.
People associated with the process prior to dec are no more in the organisation.

Mail confirmation for receipts not available. Flow for capturing receipts on OCC not
available.
Collections data prior to October not available.

Mail communication not available

Provision for debit note Appearance in OCC not available - Farms


No debit note flow in OCC - Yarns
Prior to 12-July-2023, HSN code creation request was directly routed to the Tech
team by the business team post verification of HSN code on GST portal, No
documents for the same were maintained and verbal confirmation was obtained
from the Tax team.
From 12-July-2023, The process has been automated on OCC, and review of the
HSN code by Tax team will be Maintained.

Payroll workings will not be shared due to confidentiality reasons, the same was
shown on RM system.

1. Aseer - to provide the board approval / Letter to the bank for opening of Bank
account
2 & 3 - Jagadeesh - NA (No mail communication) only hard copies shared

1. Aseer - To give details related to one Axis Account (Services)


2 - Jagadeesh - Communication to the bank / fund house for modification in
authorized signatories in bank account.
3. Jagadeesh - Check if there are any other signatories except Mayank & Saurabh.
Nikhil - As per Nikhil this is Non-Key. Further to discuss with Ajay

1. Investment limit - NA
2. Instrument for investments - NA
3. Authorized signatories for investment procedural documents - NA
4. Investment policy of organization - Aseer to provide the investment policy
Mentioned in 27th meeting held on 24-02-2022 - Not Available- Confirmed over
email.
All the fixed deposits are against the borrowings taken.

Board resolution for investment in mutual funds is enclosed.

1. Na
2. Board members are the authorized signatory for investments i.e. CEO & CTO and
also they are the bank signatories and no investment shall be authorized.

1. Mail communication not available as it happens through phone call.


3. We have investments in liquid mutual fund which has low risk. We don't have the
review process in place.

Nikhil - Borrowings are not based on fund forecast, they are on need basis.

Fund forecast not available but repayment tracker available and shared with CAO.
Mail communication provided
Annual reconciliation workings provided. No reconciliation done on a monthly basis.
Review mail not available.

For offline cases we are maintaining an offline tracker of all cases including those
onboarded on Tyrion and the RM ID will be crosschecked with the Mudra Database
prior to processing. However as Tyrion is fully live we will be processing all future
cases on Tyrion only.
For offline cases we are maintaining an offline tracker of all cases including those
onboarded on Tyrion and the RM ID will be crosschecked with the Mudra Database
prior to processing. However as Tyrion is fully live we will be processing all future
cases on Tyrion only.

For offline cases we are maintaining an offline tracker of all cases including those
onboarded on Tyrion and the RM ID will be crosschecked with the Mudra Database
prior to processing. However as Tyrion is fully live we will be processing all future
cases on Tyrion only.
Improvements

The company should document the evidence of acknowledged notice for


the board meeting conducted being sent to the board members.

The company should develop a process of educating the third


party/vendors on whistle blowing policy.

The company should follow a practice of obtaining sign off on Company's


CoC at the time of onboarding.

System should be configured in a manner to make the matrix for


approval as a non editable field.

TAT for action to be taken post receipt of BGV from vendor should be
defined in the BGV Policy.
Maker checker process for employee master creation and modification in
ZOHO to be evaluated and implemented.

Post disbursement reconciliation should be performed on a


monthly basis by accounts team and approved by Director –
Finance & Accounts.

1. It is recommended that the company should perform a sample test


basis the investment proofs uploaded by the employees to ensure
correct deduction of TDS.
2. Company should define guidelines for payroll data exchange,
protection and management.

Appraisal recommendation by respective business unit heads should be


documented.
1. It is recommended that the company should perform a sample test
basis the investment proofs uploaded by the employees to ensure
correct deduction of TDS.
2. Company should define guidelines for payroll data exchange,
protection and management.

Dormant accounts to be reviewed on a periodic basis and further actions


to be evaluated.

Board signatures should be reviewed on a half yearly/Quarterly basis.


It is recommended that the company should define the below:
1. Investment limit
2. Instrument for investments
3. Investment policy of organization.

1. It is recommended to have fund forecast in place.


2. It is recommended investments are made basis the evaluation of
rates offered by multiple banking partners in case of fixed deposit and
approved consultants in case of mutual funds.

It is recommended that the company should have a borrowing policy.

It is recommended to have fund forecast in place.

Loan covenant tracker should be shared to the stakeholders on a


monthly basis.

Company to update Loan covenant tracker on a regular basis.


The company should update the offline customers on Tyrion(loan
management system) and should process all the future loan on Tyrion.
The company should update the offline customers on Tyrion(loan
management system) and should process all the future loan on Tyrion.

The company should update the offline customers on Tyrion(loan


management system) and should process all the future loan on Tyrion.

Evidence of FAR vs GL reconciliation not provided (Improvement)


Management Response - RM

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