Saturday, 15 March 2014

Chapter VII -Co's Act 2013 : Management & Administration - Analysis

Management and Administration

Chapter VII of the Companies Act 2013 (Sec 88 – 122) & Draft Rules 
And
Companies Act 1956 (Sec 150-197A)


Care has been taken by the lawmakers to bring in the guidelines specified in the Secretarial Standards. This backgrounder is prepared with a view to bring in an insight into the new changes that have been brought to the existing Companies Act 1956.



Particulars
Applicability
Major changes on comparing Companies act 2013 with 1956
Register of Members
All Companies
-      Apart from maintenance of register of members and debenture holders, register and index of other security holders is also to be  maintained
-      All companies are required to maintain these registers irrespective of the number of members/ debenture holders (DH).(Earlier it was required only if the Member > 50 and DH > 50)


Power to close register of members or debenture holders or other security holders
All Companies
 Closure to be intimated atleast 7 days in advance and for listed companies , through advertisement in newspapers as detailed in the Rules in this regard
Annual Return
All Companies
The following Additional information and new disclosures are required to be provided

-          Changes in promoters, directors, KMP during last year.
-          Details of Class meetings, Members meetings, Board meetings and Committee meetings held during the year along with their attendance.
-          Remuneration details of directors and KMP
-          Appeals made by company, Penalties or punishments imposed on the Company or Directors or KMP
-          Details of Sharesheld by or on behalf of FII.
-          All companies having such paid up capital and turnover to get the annual return certified by a PCS
-          An extract of the Annual report to form part of the Board’s Report

Persons authorized to sign the Annual Return (AR):

Unlisted Company:The AR shall be signed by One director along with the CS and if there is no CS then by the PCS.

Listed Company with prescribed paid up capital and turn over:Shall also be certified by PCS in practice
One Person Company and Small Company:shall be signed by CS or where there is no CS, by Director of the Company.
Failure to certify in conformity with the requirements of the clause:PCS shall be punishable with fine : Rs 50,000 – Rs. 5,00,000
Preservation of Annual Return and Copies of their annexure:for a period of 8 years from the date of filing with the registrar.
Query:

Is it required to file all the particulars of the members including present and past every year or is it sufficient if we file only when there is changes in these particulars?
Return to be filed with registrar in case promoter’s stake changes
Listed Companies
Shall file a return with the ROC within 15 days from the date of change in the number of shares held by the promoters and top ten shareholders of the company.  (Newly inserted)

Place of keeping and inspection of registers, returns
All Companies
-      Registers shall normally be maintained at the Registered Office, however on passing a Special Resolution the registers maybe maintained at any other place outside the city, town or village in which the registered office is situated where more than 1/10th of the total members entered in the register of members reside.
-      The register shall be kept open throughout the day
-      In addition to the right given to the members and debenture holders, the security holders and beneficial owners can also,now inspect the register without paying any fee.
Annual General Meeting
All Companies
-       The first AGM is to be held within 9 months from the end of the first financial year (Earlier it was 18 months from the date of incorporation)
-       The AGM is to be held during business hours i.e.,Between 9:00 am to 6:00 pm and it cannot be held on a National Holiday. (Earlier it was public holiday)
-       No resolution can be passed in one annual General meeting to fix the time for its subsequent Annual General Meetings
Notice of Meeting
All Companies
Except: OPC
-       The notice can be sent through electronic means or physical means, and it shall be put on the website of the Company or on the website notified by the Central Government
-       The consent for the shorter notice shall be given in writing or by electronic mode by atleast 95% of the members entitled to vote at such General meeting. (Earlier AGM was excluded)
Statement to be Annexed to Notice
All Companies
Except: OPC
If the Special business that is being transacted relates to or affects any other company then
-          The shareholding information of directors or manager holding more than 2% of the paid up capital of that other company is to be disclosed. (Earlier it was 20%)
-          If any director or KMP derives any benefit due to the non-disclosure of any information in the statement then he shall be
·         Liable to compensate the company to the extent of benefit received by him
·         Punishable with fine upto Rs. 50,000 or 5 times the amount of benefit accrued. (Earlier there were no penal provisions)
Quorum for meetings
All Companies
Except: OPC
-       The quorum is fixed based on the number of members of the Company: (Members to be personally present to be counted for the quorum)

No of Members of the Company
No of Members to form the quorum
 Less than 1000
5
 1000 - 5000
15
More than 5000
30

-      In case of any adjourned meeting the company shall give not less than 3 days’ notice to the members either Individually or by Press Announcement. (Newly Inserted)
Proxies
All companies Except certain class or classes of Companies

Except: OPC
-       A person shall act as a proxy on behalf of members not exceeding 50 and holding in aggregate not more than 10% of total share capital of the Company carrying voting rights. (There was no restriction earlier)

-       The Central Govt. may prescribe a class or classes of companies whose members shall not be entitled to appoint proxies.
Restriction on voting rights
Both private and public companies (Earlier it was only to public companies).

Except: OPC
The company shall not prohibit members from exercising his voting rights on any grounds other than non-payment of calls or lien on shares applied.
Voting Through electronic means
Prescribed class or classes of companies

Except: OPC
-      Now members of the prescribed class or classes of companies can exercise vote thought electronic means. (through Secured system)
-      The Notice of the meeting should clearly specify that the company is providing facility for voting by electronic means along with the process and manner for voting by electronic means.
-      The E- voting shall be open for not less than 7 days and not more than 10 days

Appointment of Scrutinizer:

-       The Board shall appoint a scrutinizer to scrutinize the e-voting process.
-       The scrutinizer shall within 3 working days from date of conclusion of e-voting period unblock the votes in the presence of at least 2 witnesses and make a report of the votes casted in favour or against, if any forthwith to the Chairman.

Date of passing such resolution

Subject to the receipt of the sufficient votes the resolution shall be said to be passed on the date of the relevant general meeting of the members.

Demand for Poll
All Companies

Except: OPC
In addition to the Chairman the following members present in person or through proxy are also entitled to demand poll:

Particulars
Public Co / Pvt. Co Having Share Capital
Any other Company
Their Voting power
≥ 10% of the total voting power

≥ 10% of the total voting power

Sum of shares held
  ≥ Rs,5,00,000 or such higher amount as prescribed has been paid up.



Postal Ballot
All companies

Except: OPC
Applicable to all Companies. (Earlier it was applicable only to Listed Companies)

Circulation of Members Resolution
To all companies the exemption that was given to the Banking companies earlier no more exists.


Except: OPC
Number of members entitled to give a request to pass a resolution through circulation:

-          Companies having share capital : members entitled to vote holding shares of ≥ 10% of paid up share capital
-          Companies not having share capital : Members having voting power of  ≥ 10% of the total voting power of all the members

The CA 2013 permits requisition for circulation of statement at AGMs also.

Currently the word limit of 1000 words has been removed.
Ordinary and Special Resolution
All Companies
Votes cast electronically as well as votes cast by postal ballot shall be counted for determining whether or not ordinary/special resolution has been passed or not.
Resolutions requiring special notice
All Companies
Request for passing of such resolution shall be given to the company by such number of members holdings

-          Not less than 1% of the total voting power or holding shares on which aggregate sum not exceeding Rs, 5,00,000 as may be prescribed has been paid up.

There is no mention about time limit in providing the notice.  (Earlier it was 14 clear days before the day of the meeting)

Resolution and Agreements to be filed
All Companies
The following resolutions and agreements shall be filed with the registrar within 30 days from the date of passing the resolution or execution of the agreements as the case may be:
a.       Special Resolution
b.      Board Resolution: appointment, renewal of appointment, variation in terms of appointment of MD
c.       Resolution passed by the majority of any class of members
d.      Resolution passed to transact business under Sec 179 and 180
i.         Sec 179 - Powers of the Board
ii.       Sec 180 - restriction on powers of the Board).
e.      Resolution passed for voluntary winding up
f.        Any other resolution, agreement as may be prescribed.
Penalties:

-          The company : fine of Rs. 5 L - Rs. 25 L
-          Every officer in default:  Rs. 1 L - Rs. 5 L
Minutes of proceedings of General Meeting, Meeting of Board of Directors and other meeting and resolutions passed by postal ballot
All Companies
-      Minutes of the meeting of any class of shareholders and creditors to be maintained
-      Resolutions passed through postal ballot to be maintained
-      Person who is found to be tampering with the minutes of the  proceedings of the meeting shall be punishable
o   with imprisonment: upto 2 yrs and
o   with fine: Rs. 25,000/- – Rs. 1,00,000/-
Maintenance and inspection of documents in electronic form
All Companies
This section enables the companies to maintain, allow inspections or furnish copies of documents, records, minutes, registers etc. in electronic form.
Report on Annual General Meeting
Listed Companies
A report on each AGM is to be prepared including the confirmation to the effect that the meeting was convened, held and conducted as per provisions of the Act and the rules made there under.

A copy of the report to be filed with the ROC within 30 days from the date of conclusion of the AGM

If default in complying:Punishable with fine

Company: Rs. 1,00,000/- to Rs. 5,00,000/- 
Every officer who is in default: Rs 25,000/- to Rs. 1,00,000/-
Applicability of this chapter to one person company
OPC
-      The Provisions of Sec 98 and Section 100 to 111 are not applicable to OPC. (the table clearly specifies the exemptions granted to OPC under the applicability heading)

-      The resolutions passed shall be communicated to the company and entered in the minutes book.

-      The date of signing the minutes shall be taken to be the date of the general meeting/ board meeting.

Query: How will one person communicate to the Company?


Sanka Indrani, Company Secretary
Achuthan R, Company Secretary

Note: This article is prepared by the authors, as a back grounder for the meeting conducted by Chennai West Study Circle on 15th March 2014




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