Jain Resource Recycling Limited has announced a postal ballot notice to seek shareholder approval for two significant corporate resolutions through remote e-voting. The company, engaged in recycling ferrous and non-ferrous metals, has set December 12, 2025, as the cut-off date for determining eligible shareholders.

Executive Director Appointment

The company seeks approval for appointing Mr. Sanchit Jain (DIN: 08751991) as Executive Director for a one-year term effective October 21, 2025. The Board of Directors and Nomination and Remuneration Committee had already approved this appointment in their respective meetings held on October 21, 2025.

Mr. Sanchit Jain, son of Managing Director Mr. Kamlesh Jain, currently heads the company's operations and brings extensive experience in the recycling industry with in-depth exposure to non-ferrous metal segments including Lead, Copper, and Aluminium. His remuneration package includes basic salary, allowances, perquisites, and other benefits as per company policy, with potential performance-based incentives determined by the Board.

Secretarial Auditor Appointment

The second resolution involves appointing M/s. VAK Associates, Practicing Company Secretaries (Firm Registration No. P2025TN322600), as the company's secretarial auditors. This appointment follows recent amendments to Regulation 24A of SEBI Listing Regulations requiring listed entities to conduct secretarial audits.

The firm provides professional services in Corporate Law, Capital Markets Securities Laws, Foreign Investment Exchange Control, NBFC, Intellectual Property Rights, Mergers & Acquisitions, and regulatory compliance matters.

Voting Schedule and Process

The postal ballot will be conducted exclusively through remote e-voting, with KFin Technologies Limited serving as the registrar and share transfer agent. M/s. BP Associates, Practicing Company Secretaries, have been appointed as scrutinizers to ensure fair and transparent voting.

Company Performance Context

The explanatory statement reveals the company's strong financial performance across recent years. The recycling company, which commenced commercial operations on February 25, 2022, has shown consistent growth in revenue and profitability.

The postal ballot notice has been sent electronically to shareholders whose email addresses are registered with the company or depositories. Physical copies will not be distributed in compliance with Ministry of Corporate Affairs circulars. The voting results will be communicated to stock exchanges and displayed on the company's website at https://jainmetalgroup.com upon completion of the scrutiny process.

Jain Resource Recycling Limited has disclosed that its promoter Kamlesh Jain has been penalized ₹25.00 lakh by the Securities and Exchange Board of India (SEBI) for alleged insider trading activities in shares of Refex Industries Limited. The company informed stock exchanges about the regulatory action taken against its promoter.

SEBI Adjudication Order Details

SEBI passed an adjudication order bearing reference number Order/JS/YK/2025-26/31830-31832 in the matter of insider trading activities in Refex Industries Limited scrip. The order was issued under Section 15-I of the SEBI Act, 1992, read with Rule 5 of the SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995.

Alleged Violations and Contraventions

SEBI alleged that Kamlesh Jain and the Jain Family Trust traded in Refex Industries Limited shares while possessing unpublished price-sensitive information. The regulatory body claimed that the entities made unlawful gains of ₹12.33 lakh through these trading activities.

The alleged contraventions include violations of:

• Section 12A(e) of SEBI Act read with Regulation 3(1) of SEBI PIT Regulations
• Section 12A(d) and (e) of SEBI Act read with Regulation 4(1) of SEBI PIT Regulations

Jain Resource Recycling emphasized that the alleged contravention does not relate to the company's shares in any way.

Promoter's Response and Legal Recourse

Kamlesh Jain and the Jain Family Trust have informed the company of their intention to contest the SEBI order and file an appeal. They believe they can strongly defend their position through the legal process and will avail appropriate recourse available under law against the adjudication order.

Impact Assessment on Company Operations

Jain Resource Recycling has clarified that the SEBI order will not impact the company's financial position, business operations, or other activities. The company stated that the matter pertains to the promoter and his family trust in their personal capacity, with no quantifiable monetary impact on the listed entity.

The company also noted that the subject matter related to the show cause notice issued by SEBI had been duly disclosed in its offer document for the Initial Public Offering, ensuring transparency with investors regarding potential regulatory matters involving the promoter.