STATUTORY AUDITOR’S APPOINTMENT – A SHIFT IN PLATE REQUIRED?



In dispensation of justice, law does not operate in a vacuum, it draws substance, sustenance from social and operational jurisdiction.”

-       Justice N. V Ramana, Supreme Court of India

INTRODUCTION:
Time had been the witness and on the other hand reason as well for the metamorphosis of legislation in the Indian soil but nevertheless the core intent of law had been undisturbed irrespective of the changes. The intention of any law is crystal clear and its locus lies in the interest of its people. The Delhi Bench of State Consumer Disputes Redressal Commission in the case of “Ashok Gupta vs. Indian Airlines Limited (2008)” while interpreting the rule of beneficial legislation postulated that “A law is interpreted and constructed in the manner that which should serve the interests of those for whom it is meant and promote its object. If there are two or more constructions possible, construction which is beneficial and protects the interests and favour those for whom a law was made is to be followed.”
Likewise, the landscape of the corporate sector had underwent substantial changes when Companies act, 1956 was repealed and Companies act, 2013 was enacted and made effective. The latter is recognised as consolidating statute. The rationale behind introduction of a consolidating statute is to present the whole body of statutory law on a subject in a complete form, repealing the former statute. An interpretation can be chalked out from the case of “Southern Petrochemical Industries Ltd. vs. Electricity Inspector and Ors. (2007)” for understanding the nature of Companies act, 2013. The Supreme Court of India in the said case contemplated that “A consolidating act/statute re-enacts in an orderly form the various provisions embodying a particular law.”
STATUTORY AUDITOR – THE STANDPOINT:
A company’s good position is an indicator of the effort at all the levels of hierarchy of a company. Such performance is attributable to the degree of caution exercised by the board of directors of the company and the designated officials to whom power is delegated thereupon. Now when the term all levels of hierarchy is used, it denotes the personnel who work internally and also externally. Statutory auditor is an important stakeholder to the company who is an external personnel appointed to audit and certify the financial status of the company. Section 141 of the Companies Act, 2013 embodies that only a qualified chartered accountant can be appointed as an auditor. The Gujarat High Court in the case of “Council of Institute of Chartered Accountants  vs. Shri Mukesh R. Shah FCA and Ors. (2003)” opined that “Companies Act specifically prescribes that a person shall not be qualified for appointment as auditor of a company unless he is a Chartered Accountant within the meaning of the Act. There are various other provisions which prescribe the powers and duties of the Auditors as well as the responsibilities. These provisions are indicative of the extent a Chartered Accountant is looked upon by the society, with special reference to the corporate world, as being competent to discharge various statutory duties and responsibilities as a qualified professional.
The statutory auditor is a watchdog of a kind, who by certifying the financial status ensures that the relevant records required to be maintained are in place and also compliance under law are adhered to. The role of the statutory auditor is extremely critical. The Delhi High Court in the case of “National Dairy Development Board vs. Union of India (2010)” held that “Statutory auditor is primarily concerned with the financial position/affairs of the company or the corporation, maintenance of accounts and records and whether statutory compliances have been made.” Every business functions in a prevailing dynamic cluster wherein decisions concerning growth and returns have to chalked out with utmost care and diligence.
So how does a company get to be termed as ‘credible’ to be invested in? Being a potential investor, an individual would look for an authenticated information or record to understand the entity and the financial position. This is where the certification by the statutory auditor plays a big role. The biggest misconception about the audit report is that it is mandatory since the law creates an obligation for a company to appoint an auditor and get a report. But that is not the intention of the legislation. The audit report is an authenticated “public document” which creates reposes the confidence upon an investor or a regulator to look at the company as a potential one. Auditing being a statutory function brings authentication and a source which every stakeholder can rely upon. The Hyderabad bench of Custom, Excise & Service Tax Tribunal in the case of “Price Waterhouse vs. Hyderabad-Ii (2018)” opined that “Auditing is a statutory function in terms of Companies Act and the report of the Auditor clearly shall mention that 'they have audited the attached balance sheet and the P&L account of the Company in connection with audit and this is not merely a certification activity." Therefore the audit activity undertaken by the statutory auditors set a tone for the company among the stakeholders. The Supreme Court of India in the case of “Centre for Public Interest Litigation vs. Union of India and Ors. (2018)” held that “Financial statements audited by qualified auditors are acted upon and failures of the auditors have resulted into scandals in the past. The auditing profession requires proper oversight.”
HAS THE INDEPENDENCE BEEN FORGONE?
Ineffective decisions and decisions concerning personal pursuits are perhaps the frontier actions of corporate boards that has led several companies into scams. The Uttaranchal High court in the case of “Jagteshwar Prasad Bansal and Ors. vs. State of Uttarakhand and Anr (2017)” categorically remarked that “The corporate personality has been obtained by certain individuals as a cloak or a mask to prevent tax liability or to divert the public funds or to defraud public at large or for some illegal purposes etc.” When any corporate financial scam is pulled out, at first immediately the role of auditors and the board of directors are put under scrutiny. So the question has always been on the charts, are the statutory auditors who certify the credibility of a company independent? The judiciary has also acknowledged the fact that auditors being the cornerstone of a company’s market standing must be independent. The Supreme Court of India in the case of “M/s Sahara India (Firm), Lucknow vs. Commissioner of Income Tax (2008)” postulated that “An auditor is a professional person. He has to function independently. He is not an employee of a company. In case of mis-conduct, he may become liable to be proceeded against by a statutory authority under the Chartered Accountants Act, 1949.The Andhra High Court in the case of “Vadlamudi Rama Rao vs. Asian Coffee Ltd., Sec'Bad (2000)” reiterated that “A statutory auditor has an independent role to play if he has to effectively perform his part. The imputations of bias cannot lightly be made against a professional Chartered Accountant who is expected to discharge the duties according to the obligations cast on him by the Statute and the well-established principles of professional conduct and etiquette.” Closely held companies often enjoy this position where directors are shareholders and such directors cum shareholders use such autonomy to appoint statutory auditors who are known to them personally. By appointing in such a way, the financial documents are often inflated and investor’s wealth is eroded over the period of time. A very interesting view is derived from the case of “G. Haranadh vs. Shri Laxmi Durga Paper Products (India) Limited (2004)” where the Company law board opined that “The shareholders' inherent rights to appoint their auditor cannot constitute an act of mismanagement.” Unless any act is done contrary to the interest of the company and the investors, the law grants protection to the members in a company especially in a closely held set-up.
So the foremost characteristic attribute that an auditor must possess is ‘independency’ in examining a company and giving the report. Being independent shouldn’t be projected in the subject heading and in textual content of the auditor report but also during the entire process of audit and reporting exercise. Lindley L.J. in the case of “Land Allotment Co. (1893)” observed that “Directors have been described as trustees because of the peculiar nature of their office. The directors are the individuals elected to manage the affairs of the company for the benefit of the shareholders.” Most of the corporate structure failures can be attributed to the mismanagement of the personnel functionaries by the board of directors. Sole focus on personal pursuits have been placed over the real business objective of wealth maximization. There is no justification or reasoning for appointment and functioning of an auditor if such individual or firm is influenced by the company. The Calcutta High court in the case of “New Central Jute Mills Co. Ltd. vs. Deputy Secretary, Ministry of Corporate Affairs (1965)” contemplated that “If it appears that auditors are under some sort of obligation to the company, the accounts of which they audit, there may arise a doubt that the auditors might have discharged their functions much too indulgently. If such a doubt arises, it cannot be ignored as a doubt which no reasonable man should entertain.
If an Auditor were to rely upon statements of the management even in respect of matters which were capable of direct verification, his appointment by the shareholders to examine the accounts of the company would be perfectly useless and would serve no purpose at all. The real value of a company is projected to the public and regulators only when the authentication of the company as a whole is undertaken by an independent personnel. It is unfortunate to understand and know today that most corporate resort to appointment of auditors who are related to them in a way so as to ensure that the entity as a whole is evaluated as per the discretion of the management. Many companies adopt the practice of entrusting the activity of book keeping and accounting services to the auditor which is prohibited under Section 144 of the Companies Act, 2013. The Bangalore District Court in the case of “Mr. M. Pratap Reddy vs. Raghavendra Naik T (2018)” held that “The rendering of services in accounting and book keeping services means the participation of statutory Auditor in preparing the financial statements. This involves the direct participation of auditors in the participation of finance management of a company.” This is where an auditor loses his/her independency. It is imperative to understand that shareholders of the company who are the true owners rely upon the audit report submitted by the statutory auditors to understand whether a company has their investments channelized in proper manner. Audit certification and reporting forms a basis for investment decisions. Improper diligence by the auditors have resulted in the scam biggest corporate scams such as Lehman Brothers Scandal (2008), the Satyam Scam (2009), Leasing & Financial Services (IL&FS) Saga just to name a few. These occurrences had served as a catalyst to exploit the corporate decision making. This is the reason for the legislation to evolve over times to reduce malafide practices. The Audit report given the statutory auditors plays a crucial role which the stakeholders of a company including statutory regulators take into factor while evaluating the credibility of a company. The Delhi High Court in the case of “Additional Commissioner of Income Tax vs. Jay Engineering Works Ltd. (1978)” remarked that “It is quite competent for the income-tax authorities not only to accept the auditors' report, but also to draw the proper inference from the same.”
ANALYSIS OF STATUTE:
Section 139 of the Companies Act, 2013 casts onus on both the board of directors and the shareholders to appoint auditors of the company. The statute stipulates that the board of directors of a company other than a government company shall appoint the first auditor within 30 days of the company being registered i.e. within 30 days of obtaining the certificate of incorporation. Failure to do the same, shifts the responsibility to the shareholders who shall appoint the auditor within 90 days from the registration of the company at an extra-ordinary general meeting and such auditor appointed by the board or the shareholders as the case maybe shall office till the conclusion of the first annual general meeting. Thereafter at the first annual general meeting the shareholders shall appoint the statutory auditor who shall act as the auditor of the company from the conclusion of the said meeting till the conclusion of the sixth annual general meeting. Further the shareholders may appoint the same auditors for another period of 5 years or appoint another individual or firm to act as auditor. The law in clear sense empowers the shareholders to exercise their rights to govern the appointment of auditors. The Telangana High Court in the case of “P.M. V. Subba Rao vs. The State of Telangana & Anr. (2019)” reiterated that “Shareholders appoint statutory auditor of the company at General Meetings, who have duty to audit the Annual Accounts prepared by Board of Directors and after duly auditing, Board of Directors circulate prepare the Annual Accounts and Returns as per law and the same is uploaded into the public domain of ROC/MCA portal.” The Companies Act, 2013 also mandates that any body corporate other than a limited liability partnership registered under the Limited Liability Partnership Act, 2008 shall not be eligible to act as an auditor.
The auditors are also seen as officers of the company and on equal footing with every personnel of the company. In “Kingston Cotton Mill Co. (1896)” Vaughan Williams, J. observed that “I want to say generally of auditors that I have no doubt myself but that auditors who have to perform that duty are not only in this case but in all cases, officers of the company.” The same was also reiterated by the Allahabad High Court in the case of “L. Hudson vs. Official Liquidator of Dehra Dun Electric Tramway Co. (1929)” where the court held that “The general result of the decisions is that where an auditor has been appointed by a limited liability company at a general meeting of the shareholders, he must be taken to be an officer of the company.”
Section 139 also mandates listed companies and the following categories of the companies to rotate the auditors i.e. re-appoint or change the auditors or in other words to limit the tenure of auditors to one term of 5 consecutive years in case of such auditor being an individual or two terms of 5 consecutive years each:
·         All unlisted public companies having paid up share capital of rupees ten crore or more;
·         All private limited companies having paid up share capital of rupees fifty crores or more;
·      All companies having paid up share capital below threshold limit as mentioned above, but having public borrowings from financial institutions, banks or public deposits of rupees fifty crores or more.
The intent of the legislature to mandate the concept of rotation of auditor can be understood to not have the same auditor certify the financials for a longer time so as to avoid any personal relationship by an auditor with the company as it would enable the entity to exert its influence to inflate the financial figures as per their requirement. The statute also provides a cooling period as such that an individual can be appointed as an auditor of the same company after a period of 5 years post his completion of tenure and in case of an audit firm, such firm can be appointed as the auditor of the company after five years of completion of its term. Likewise the section also empowers the board of directors to appoint an interim auditor in case of casual vacancy within a period of 30 days from such vacancy and in case where the auditor resigns from the company, the board shall make recommendation to the shareholders within a period of 30 days and the shareholders shall approve such appointment as they deem fit within 3 months from the recommendation of the board. In both these scenarios the interim auditor so as appointed shall hold office till the conclusion of the next annual general meeting.
It is extremely important to understand why the term ‘till the conclusion of the next annual general meeting’ is used. The statutory auditor has to be present at the annual general meeting to answer the queries raised by the shareholders and to address the appropriate issues raised to him/her. Effectively a statutory auditor is not discharged from his duties until he/she is made accountable to the shareholders. The recommendation of the Audit Committee on any matter relating to financial management including Audit Report shall be binding on the Board. This Audit Committee is expected to independently audit the accounts of the companies. The Board is bound by the report of the Audit Committee. Certain amount of power and autonomy has been given to the Audit Committee. In case the Board disagrees with the observations of the Audit Committee, the entire matter is required to be placed before the general body of the company. Section 139 casts the responsibility on the audit committee where required to be formed, to make recommendation to the board of directors pertaining to the appointment of the auditors. Likewise removal of auditor before the expiry of his/her term is channelized through a mechanism in which the shareholders are bestowed with the autonomy to remove a statutory auditor from his position only after obtaining the approval of the respective Regional director. The Delhi High Court in the case of “S. P. Gupta vs. M/s. Packwell Manufacturers Pvt. Ltd. (2013)” reiterated that “The auditors can be removed only by the company but the power has to be exercised in the general meeting of the shareholders. There is always a distinction between the company and its shareholders.” The Bombay High Court in the case of “Union of India vs. The Company Law Board (2013)” held that “From a plain reading of the statute it is clear that it prohibits a company in its general meeting from removing a statutory auditor before the expiry of his term if the previous approval of the Central Government in that behalf has not been obtained.”
WHERE DOES IT GO WRONG?
The board of directors have a significant hand on the appointment of an auditor and also on the entire audit exercise. It cannot be said that the independent audit exercise keeps aside the interest of the board of directors. It must be remembered that the shareholders are empowered to appoint the auditors but the management of affairs is done by the directors and not always are the shareholders in the corporate office of the company. The board of directors are in the cushion to exert influence on the auditors to act in the interest of the board and in return the auditors are assured recurring services. Though the shareholders appoint statutory auditors, they do so upon the recommendation of the board of directors. The question therefore arises, how the shareholders get to know whether the auditor is a known person to the board or has any connection with the board unless the requisite disclosure is made by the board on voluntary basis which does not occur in majority of circumstances. The true position of the auditor gets diluted over the period of time. The Delhi High Court in the case of “Amar Nath Malhetra vs. M.C.S. Limited (1992)” remarked that “It is significant to mention that much importance has been attached by the Act to the independence of the auditors. In fact the auditor is to act as a watchdog for the protection of the shareholders and is required to examine the accounts with a view to give the shareholders true and fair picture of the same.” Over the year some auditors have tended to certify financial statements without making a satisfactory audit assessment or even without verifying the authenticity of accounts. Frequently, auditors have tended to regard audit as merely a financial obligation to certify accounts which are supposed to have been examined by them.
There can be no doubt that when an auditor starts to sell management services, other advices and offers various unspecified services, he immediately compromises his objectivity. Virtually one ends up with a situation where the company that has purchased the services of the auditors in various forms, follows the recommendations of its own auditor consultant leaving little else for audit. As time would fly by, balance sheets may no longer be accepted by shareholders and gradually by other authorities as a true index of the state of affairs of a business enterprise. There may even be a feeling that when the auditor has other interests in the company, or other incomes from the company, he may tend to conceal things in his own interest. The Karnataka High Court in the case of “T.S. Natraj vs. Union of India and Ors. (1985)” held that “The independence of the auditor is essential also for the orderly development of trade and industry.” Normal business losses are not regarded as something which a shareholder would be concerned off but when a potential company which undertakes transactions on recurring basis and yet sustains loss would be under the cloud of suspicion by the shareholders and the regulators. The Supreme Court of India in the case of “Madhusudan Gordhandas & Co. vs. Madhu Woollen Industries Pvt. Ltd. (1972)” opined that “The mere fact that the company has suffered trading losses will not destroy its substratum unless there appears a serious misconduct on the part of those who manage the affairs of the entity.” Every corporate board and also the auditors aim at enhancing the value of a company but at a cost which is unacceptable by the regulator.
THE VALUE OF A CORPORATE ENTITY AND THE ROLE OF THE AUDITOR:
In the prevailing corporate domain, investors capital has more choice and mobility than ever before. The key to survival and growth lies in organizational change initiatives that will contribute directly to the economic value of the entity and its ability to satisfy the financial return requirements of its investors. The Delhi bench of Income Tax Appellate Tribunal in the case of “Marubeni India (P) Ltd, New Delhi vs. Assessee (2009)” categorically remarked that “The main object of an entity established in India traditionally is to attract and retain competitively sought after investors capital or in other words shareholders wealth.” The existence of legislation can be justified to give and promote a balance between the owners and the agents. The agents undertake various kinds of risk depending on the circumstances to run a corporate structure. If we carefully observe, the approach of law had slowly shifted to a business friendly approach. The Delhi High Court in the case of “J.B. Exports Ltd. and Anr. vs. BSES Rajdhani Power Ltd. (2006)” contemplated that “The main intent of shift in the focus of law is to encourage entrepreneurs to start new business ventures and thus help in the process of industrialisation.”
In every business there is a risk that the business may fail due to recession, competition etc. Hence, businessmen were reluctant to set up new industrial ventures out of fear that if it failed, recovery would be issued in respect of the loans they had taken and thereupon even their household and personal effects may be sold in connection with the recovery. Hence, businessmen were reluctant to take risks and start new industrial ventures. To get over this hurdle and to encourage industrialisation the legal principle was carved out that if a company is incorporated under the Companies Act, the liability of the shareholders becomes limited because the shareholders, directors etc. are legally treated as being different from the company. Corporate entities have made an important transition in their object, while earlier entities focused on establishment of their position irrespective of the utilization of the investments, a gradual shift to protection and focusing on enhancing the value of company had been in focus. Not only that but also such focus had been termed in much more optimistic manner as “business purpose”. The Mumbai bench of Income Tax Appellate Tribunal in the case of “LML Ltd, vs. Assessee (1999)” opined that “Business purpose being a term of wide import would mean and has to be meant and equated to maximizing shareholder's wealth or value.” Thus the role of auditors can be observed to be more peculiar in nature as they work towards the authentication of the usage of the wealth of the investors. In other words, the auditing was intended for protection of the beneficiaries and the auditor is expected to examine the accounts maintained by the trustees with a view to inform the beneficiaries of the true financial position.
The auditor is, in such a case is under a clear duty towards the beneficiaries 'to probe into the transactions' and to report on their true character. The Calcutta High Court in the case of “London Oil Storage Co. Ltd. vs. Seear, Hasluck and Co. (1956)” categorically remarked that “He, the auditor must exercise such reasonable care as would satisfy a man that the accounts are genuine, assuming that there is nothing to arouse his suspicion of honesty and if he does that, he fulfils his duty; if his suspicion is aroused, his duty is to probe the thing to the bottom and tell the directors of it and get what information he can.”  In the matter of “London and General Bank (1895)” Lindley L.J. observed that “It is no part of an auditor's duty to give advice, either to directors or shareholders, as to what they ought to do. An auditor has nothing to do with the prudence or imprudence of making loans with or without security. It is nothing to him whether the business of a company is being conducted prudently or imprudently, profitably or unprofitably. It is nothing to him whether dividends are properly or improperly declared, provided he discharges his own duty to the shareholders. His business is to ascertain and state the true financial position of the company at the time of the audit, and his duty is confined to that.
THE FOOTPRINTS FORWARD:
Following can be measures which can be undertaken by the regulators concerning the best interest of the company and the investors:
·     Has the time come for the appointment of auditor by an independent agency? This question has been put forth by the changing times. The Ministry of Corporate Affairs (‘MCA’) may appoint an independent agency and could delegate the power to appoint auditors of every company domiciled in the Indian landscape. The power of the company to appoint auditors can be very well shifted to an independent agency as deputed by the MCA which can coordinate with the Comptroller and Auditor-General to exclusively appoint and govern the role of auditors of the company.
·     The shareholders in case of companies which are required to constitute audit committee and required to appoint independent directors can be empowered to appoint a representative independent director in the audit committee who would may or may not be one among themselves. For the purpose of the same, for every 1000 shareholders one independent director may be appointed, who may be a company secretary or a cost accountant or a chartered account by qualification or an individual who has expertise knowledge in finance, economics, law etc. Such independent director may put forth his opinion to the committee in the best interest of the shareholders. A provision can also be made that such director retires by rotation and maybe subsequently re-appointed every 6 months subject to the approval of the shareholders.
·      Few more skew of measures can be undertaken by the MCA such as introducing an affidavit to be given by the auditors stating that they would not resort to any other services to the company with they are dealing with either on annual basis or when they are appointed.
·     The system of interim audit for companies above a stipulated threshold can be introduced which can be undertaken on half yearly basis. The companies on the other hand would be required to hold a mandatory extra-ordinary general meeting for the approval of the said interim audit report. This way a company stimulates the shareholders to effectively be informed about the company, its management and the state of affairs.
·     Any complaint / remark on the accuracy of audit made by the shareholders (present and voting at a general meeting) holding five percent of shares or more either individually or collectively should be compulsorily followed up by an independent investigation.
·     The rotation of auditors should be made mandatory without any threshold limits. That is to say that rotation of auditors should be made applicable for every company except small companies and one person companies. At present, one term of auditor is 5 years consecutively till which he or she can act as auditor. The MCA can reduce this tenure from 5 years to 3 years, that is to say an auditor can act as the statutory auditor of the company for one term of three consecutive years if such auditor is an individual or two terms of three consecutive years in case such auditor is a firm.
·     A measure can be introduced as such that a mandatory report be presented by the audit committee at every Annual General Meeting confirming the role of auditors played during the financial year and the scope of work that may be recommended for the upcoming financial year.
·   The board of directors shall present a list of auditors proposed to be appointed at the respective general meetings. In traditional practice, the board selects and recommends, however the board should prepare an exclusive list of auditors who may be appointed and which shall be placed at the general meetings and the chairman ought to explain the parameters for recommending each auditor so that the shareholders can make the most effective decisions.
·     Another important measure that the regulator could deploy is a supervisory audit that should be made mandatory and which should be undertaken every two years by an audit firm other than the one contractually employed as auditor of a particular company. The supervisory audit should be done by an auditor nominated by the Comptroller and Auditor-General of India on the auditor who audits the company. Likewise the statutory auditors can be also be entrusted with the role of supervisory audit to be conducted over the internal auditors of the company appointed, if any.
ENDING REMARKS:
Seen with two different views, two different interpretations can be drawn on what a company’s wealth. It’s something bigger than articulating the affairs of the company. It is much more than pursuits and profits. It is much more than examination of the activities. It is the collective effort that each personnel at every level undertakes to reach a good market standing, be it internal personnel who work with diligence or the external personnel like auditors who work independently. The Bombay High Court in the case of H.J. Doshi and Ors. vs. Commissioner Of Wealth-Tax (1977)” stated that “The wealth of a shareholder arising from shareholdings is one thing, while the wealth of the company itself is a different matter. A company's net wealth which law recognises is not the sum total of the net wealth of the individual shareholders but a larger picture portrayed among the public. The company and the shareholders are different assessable entities under law.”
The reality of the company is much broader than that of an association of capital, it is a human working community that performs a collective action for the common good. The status of auditors undoubtedly changed from being the extended arms of corporate boards to the extended arms of good corporate governance but requires more changes. It is pertinent to reiterate the findings of the Gujarat High Court held in the case of “Panchmahals Steel Limited vs. Universal Steel Traders (1975)”. The court stated that “Time-honoured approach that the company law must safeguard the interest of investors and shareholders of the company would be too rigid a framework in which it can now operate. New problems call for a fresh approach.”

DISCLAIMER:

This is a personal blog. Any views or opinions represented in this blog are personal and belong solely to the blog owner and do not represent those of people, institutions or organizations that the owner may or may not be associated with in professional or personal capacity, unless explicitly stated. All content provided on this blog is for informational purposes only. The owner will not be liable for any losses, injuries or damages from the display or use of this information.  

                                                                                    



Comments

Popular posts from this blog

FORM VS. EFFECT BASED APPROACH – THE STORY OF COMPETITION

ASSERTION THROUGH THE LENS OF STATUTE COUPLED WITH ESTABLISHED CRIMINAL INTENT SACROSANCT FOR EFFECTUATING ATTENDANCE OF CHAIRMAN AND DIRECTOR

KNOW YOUR LAW #5 - ESSENCE OF NAME OF A COMPANY