DGMS Mine Safety Compliance Cement Limestone Mining Cost Reconciliation

A Tier-1 Indian cement producer operating a captive limestone mine at an 8 MTPA extraction rate in the Rajasthan-Sirohi belt sits under the Directorate General of Mines Safety compliance perimeter established by the Mines Act 1952, the Mines Rules 1955 and the Metalliferous Mines Regulations 1961 — limestone falls under the metalliferous mining category as distinct from coal mining which is governed by the Coal Mines Regulations 2017, and every captive limestone mine of a cement producer is subject to the DGMS discipline administered under the Ministry of Labour and Employment. The compliance stack across the operating year covers the appointment of a Safety Manager (Safety Officer under the Mines Act nomenclature) holding a DGMS certificate of competency where the mine employs above the 150-worker threshold notified under the Mines Rules 1955, the constitution of a Safety Committee with equal management and workmen representation running a monthly meeting, the appointment of a Rescue Station with quarterly rescue rehearsals, the annual First Aid training of designated First Aid personnel, the filing of Form B (production) / Form C (employment) / Form D (accidents) / Form E (safety mechanic and machinery) annual returns under Section 55 of the Mines Act 1952, the reporting of fatal and serious accidents on Form N and dangerous occurrences on Form K within the statutory time window to the Chief Inspector or Regional Inspector of Mines, and the clearing of a DGMS annual compliance audit against the Metalliferous Mines Regulations 1961 technical standards covering bench design, blast design, haul road design, electrical installation safety and personal protective equipment issuance. Parallel to the DGMS compliance, the mine holds a valid Petroleum and Explosives Safety Organisation (PESO) licence under the Explosives Act 1884 and the Explosives Rules 2008 for the explosives magazine used in overburden and limestone bench blasting. The reconciliation discipline that ties every rupee of the recurring DGMS compliance cost stack to a Section 37 revenue-expense deduction under the Income-tax Act 1961, loads the stack under Ind AS 2 as a directly-attributable conversion cost to the limestone raw material carrying value, threads Section 194J 2 percent TDS on the compliance-consultant fee leg, and closes an Ind AS 37 provision on any probable DGMS penalty arising from an unresolved inspection observation is the subject of this DGMS mine safety compliance cement limestone mining cost walkthrough.

Quick reference

The reconciliation in one paragraph

A Tier-1 Indian cement producer operating a captive limestone mine must capture every rupee of the six recurring DGMS compliance cost buckets at the mine cost centre, deposit each fee to the correct payee within the statutory due date, maintain the six compliance obligations (Safety Manager appointment, Safety Committee monthly meeting, Rescue Station and rescue rehearsals, First Aid training, statutory annual returns filing, PESO magazine licence renewal) on a standing compliance calendar, close the Section 194J 2 percent TDS mechanic on the compliance-consultant fee leg, and thread Section 37 revenue-expense deduction against Ind AS 2 conversion cost inclusion across the six cost buckets. The core reconciliation surface is a mine DGMS compliance ledger keyed on the mine identifier and the operating year, holding the Safety Manager appointment record with the DGMS certificate of competency reference, the DGMS compliance consultant retainer with the Section 194J TDS treatment tag, the annual DGMS audit engagement and Form B / C / D / E filing acknowledgement, the Rescue Station roster and quarterly rescue rehearsal record, the PESO magazine licence certificate with expiry date and Form 22 possession licence, the safety training and First Aid programme calendar, the monthly Safety Committee meeting minutes register, the accident register on Form N and Form K, the corrective action tracker against every DGMS inspection observation with a Metalliferous Mines Regulations 1961 reference and target closure date, and the standing 90-day compliance calendar heatmap covering PESO licence expiry, Safety Manager tenure and any DGMS notice response window as a Class A control on the mine head monthly close packet. Every material deviation between scheduled and actual Safety Committee meeting, between statutory and actual accident reporting date on Form N or Form K, between issued and deposited Section 194J TDS on the consultant fee, or between DGMS observation target and actual closure date is flagged as a month-end break for the mine head, the Safety Manager and the plant CFO.

What the scenario looks like in India — a Rajasthan-Sirohi 8 MTPA captive limestone mine persona

The illustrative persona for this walkthrough is a Tier-1 Indian cement producer operating a captive limestone mine at Sirohi in the Rajasthan limestone belt, with an extraction rate of 8 MTPA feeding an integrated cement plant located adjacent to the mine or connected by a captive conveyor and a small captive railway siding. The Rajasthan limestone belt — spanning Sirohi, Chittorgarh, Nimbahera and Beawar — is one of the highest-quality limestone reserves in India and hosts captive mining operations for Shree Cement, Birla Corporation, JK Cement, JK Lakshmi Cement and UltraTech Cement across the district cluster. Every one of these captive limestone mines sits under the DGMS compliance perimeter, appoints a Safety Manager holding a DGMS certificate of competency, constitutes a Safety Committee, runs the quarterly rescue rehearsal cadence, files the statutory Form B / C / D / E annual returns and holds a PESO explosives magazine licence for the overburden and bench blasting operations. The Madhya Pradesh limestone belt spanning Satna, Rewa and Katni hosts identical captive limestone mine operations for Prism Johnson and UltraTech Cement; the Karnataka limestone belt spanning Kalaburagi and Wadi hosts operations for ACC and UltraTech; the Andhra Pradesh-Telangana belt spanning Kadapa and Nalgonda hosts operations for Ramco Cements, Dalmia Bharat Cement, Sagar Cements and India Cements; the Tamil Nadu belt spanning Ariyalur and Salem hosts operations for Dalmia Bharat, Ramco and UltraTech; the Chhattisgarh-Odisha belt spanning Baloda Bazar and Rajgangpur hosts operations for Ambuja Cements and Dalmia Bharat; the Meghalaya belt at Lumshnong hosts operations for Star Cement and Dalmia Bharat. The compliance mechanic documented here is the standing operational discipline for any branded cement producer’s captive limestone mine operation across the Indian regional clusters.

The captive limestone mining lease and the per-tonne royalty plus DMF plus NMET stack that runs alongside the DGMS compliance mechanic is the subject of the Cement Wave 1 cornerstone at limestone royalty plus DMF plus NMET cost accounting for a cement plant and the Wave 1 walkthrough at MMDR Act 1957 limestone mining lease cement industry cost reconciliation — the DGMS compliance stack documented here sits alongside those raw-material-input cost mechanics and complements them at the mine cost centre.

The regulatory overlay — Mines Act 1952, Metalliferous Mines Regulations 1961, PESO and Section 37

Seven regulatory anchors govern a cement plant’s captive limestone mine DGMS compliance cost accounting. The Mines Act 1952 is the parent statute establishing the DGMS as the regulator and casting the primary safety obligation on the owner, agent and manager of every mine. The Mines Rules 1955 are the subordinate legislation prescribing operational discipline — Safety Manager appointment threshold, Safety Committee constitution, First Aid provisioning, Rescue Station appointment and quarterly rehearsal cadence, and the qualification requirements for the Safety Manager position. The Metalliferous Mines Regulations 1961 are the technical safety standards governing limestone mining operations (as distinct from the Coal Mines Regulations 2017 governing coal mining) covering bench design, blast design, haul road design, electrical installation safety and personal protective equipment. The Explosives Act 1884 read with the Explosives Rules 2008 administered by PESO governs the explosives magazine licence at every captive mine using explosives for blasting. Section 37 of the Income-tax Act 1961 governs the revenue-expense deduction for the recurring DGMS compliance cost stack. Ind AS 2 governs the loading of the compliance cost stack as a directly-attributable conversion cost to the limestone raw material inventory. Ind AS 37 governs the recognition of a provision for a probable DGMS penalty on an unresolved inspection observation.

Section 25 of the Mines Act 1952 provides for the appointment of a Safety Officer (designated as Safety Manager in the operational vocabulary) at every mine where the number of persons employed exceeds the threshold notified under the Mines Rules 1955. The threshold has been set at 150 workers per mine for the applicability of the Safety Manager appointment mandate. The Safety Manager must hold a DGMS certificate of competency issued after specified professional experience and examination under Rule 8 of the Mines Rules 1955. Section 55 of the Mines Act 1952 requires the owner, agent or manager of every mine to submit annual returns in Form B (production data), Form C (employment data), Form D (accident data) and Form E (safety mechanic and machinery data) on the prescribed dates to the DGMS. Chapter VI of the Mines Act 1952 (Sections 22 to 27) prescribes the accident notification mechanic — every fatal accident, serious bodily injury and dangerous occurrence must be reported to the Chief Inspector or the Regional Inspector of Mines in the prescribed form (Form N for fatal and serious bodily injury, Form K for dangerous occurrence) within the prescribed time window (typically 24 to 48 hours for fatal and serious injury with a full report following in the extended window).

The Metalliferous Mines Regulations 1961 prescribe the technical basis against which the DGMS annual compliance audit assesses the operating mine. Every observation raised by the DGMS inspection team maps to a specific Regulation — for example a bench-height observation maps to the bench design Regulations, a blast-vibration observation maps to the blast design Regulations, a dumper-operator observation maps to the haul road and dumper competency Regulations, an electrical protective-relaying observation maps to the electrical installation safety Regulations. The corrective action for each observation has a specified closure timeline and a stated or implied penalty risk under the Mines Act 1952 for non-closure.

The PESO explosives magazine licence under the Explosives Act 1884 and the Explosives Rules 2008 carries an annual renewal cadence with a renewal fee schedule notified by PESO. The magazine licence renewal application must be initiated ahead of the licence expiry date with the required attachments — the magazine inspection certificate from a PESO-authorised inspector, the storage capacity utilisation record, the magazine security personnel roster and the daily explosives inventory reconciliation ledger between explosives received, explosives issued for the shift blast schedule and explosives closing stock. A lapsed PESO magazine licence stops all blasting operations at the mine, forcing an extraction shutdown until the licence is reinstated.

Section 37 of the Income-tax Act 1961 governs the revenue-expense deduction for the recurring DGMS compliance cost stack — Safety Manager remuneration, DGMS compliance consultant retainer, annual DGMS audit and statutory returns filing cost, rescue rehearsals and rescue station operating cost, PESO magazine licence renewal fee, and safety training and First Aid programme cost are all recurring expenses incurred wholly and exclusively for the operation of the captive limestone mine. Section 194J of the Income-tax Act 1961 requires Section 194J 2 percent TDS on the compliance-consultant fee stream above the Rs 30,000 per year threshold per consultant-payee — the correct payment code sits in the Section 393 successor framework introduced by the Income-tax Act 2025 and can be cross-verified against the Section 393 payment code finder. Section 40(a)(ia) sits parallel with a 30 percent expenditure disallowance for short-deducted or non-deposited Section 194J TDS. Ind AS 2 loads the six recurring DGMS compliance cost buckets as a directly-attributable conversion cost to the limestone raw material carrying value on a per-tonne basis reflecting the extraction volume for the period. Ind AS 37 governs the recognition of a provision for a probable DGMS penalty arising from an inspection observation with a corrective action not yet closed as at the balance sheet date.

A worked example — 8 MTPA Sirohi captive limestone mine FY 2026-27 DGMS compliance budget

Illustrative — the following figures represent the operating pattern of a Tier-1 Indian cement producer operating a captive limestone mine at an 8 MTPA extraction rate in the Rajasthan-Sirohi belt. Public disclosures by listed Indian cement majors do not reveal mine-level DGMS compliance cost quantum in the granularity below; cross-verify against the current DGMS fee schedule and PESO fee schedule effective for the operating year, the actual mine worker headcount, the actual consultant retainer terms and your own mine compliance ledger before action.

The captive limestone mine at Sirohi with an 8 MTPA extraction rate feeding an adjacent integrated cement plant closes its FY 2026-27 DGMS compliance cost position across the six recurring buckets. The annualised full-year picture is:

The Rs 38 lakh annual recurring DGMS compliance cost is a Section 37 revenue-expense deduction under the Income-tax Act 1961 against the cement producer’s profits and gains from business for FY 2026-27, and loads under Ind AS 2 as a directly-attributable conversion cost to the limestone raw material carrying value flowing into the clinker inventory. At the 8 MTPA extraction rate this works out to an approximate Rs 0.48 per tonne of limestone conversion cost overhead from the DGMS compliance stack (Rs 38 lakh divided by 8 million tonnes) — a small per-tonne overhead but a material CFO monthly-close line item at the mine cost centre.

On the Section 194J dimension, the Rs 8 lakh DGMS compliance consultant retainer paid to a single consultant clears the Rs 30,000 per year threshold by a wide margin, so Section 194J 2 percent TDS = Rs 16,000 per year on the retainer, deducted at each invoice payment and deposited to the credit of the Central Government within the statutory due date with the Form 26Q quarterly TDS return entry against the consultant PAN. Failure to deduct the Section 194J TDS on the consultant fee would attract Section 40(a)(ia) 30 percent expenditure disallowance on the Rs 8 lakh consultant fee at Income-tax assessment (Rs 2.4 lakh disallowance for the year), reversible in a subsequent year on deposit of the deducted TDS.

On the Ind AS 37 dimension, assume the FY 2026-27 DGMS annual compliance audit at the mine surfaces three inspection observations against the Metalliferous Mines Regulations 1961 — one on bench-face fragmentation quality (blast design Regulation reference), one on dumper haul-road-camber (haul road Regulation reference) and one on personal protective equipment issuance frequency (PPE Regulation reference). All three carry corrective action targets within the next 60 days. The mine head monthly close packet at the March 2027 balance sheet date assesses the penalty risk on each observation — if the corrective action is closed for all three by the target date the penalty risk is remote and no Ind AS 37 provision is recognised; if one observation slips past the target date with a probable penalty risk classified at Rs 1 lakh estimate the mine cost centre recognises an Rs 1 lakh Ind AS 37 provision, posts the provision expense to the mine profit-and-loss account and discloses the provision in the notes to accounts.

Common reconciliation breakages

Three breakages recur across Indian cement producers’ captive limestone mine DGMS compliance packets, each mapping to a specific control failure that a DGMS inspection team, a PESO magazine inspector, a statutory auditor reviewing inventory carrying value or an Income-tax Officer under Section 37 assessment will surface.

• PESO explosives magazine licence approaching expiry without renewal application initiated — extraction shutdown risk. The most consequential operational failure is a PESO magazine licence approaching the annual renewal window without the renewal application initiated ahead of the expiry date — the licence lapses on the expiry date and all blasting operations at the mine stop immediately, forcing an extraction shutdown that cascades into a limestone raw material stockout at the cement plant kiln within days depending on the finished-material bin buffer. The gap typically arises from a spreadsheet-based compliance calendar that treats the PESO licence as a routine renewal rather than a Class A control, or from a discontinuity between the mine head office holding the licence certificate and the treasury office initiating the renewal fee deposit. Reconciliation discipline: the compliance ledger drives a standing 90-day PESO licence expiry heatmap alongside the DGMS Safety Manager tenure heatmap on the mine head monthly close packet, with the renewal application initiated 60 days ahead of the expiry date and the magazine inspection certificate secured 45 days ahead.

• Section 194J TDS not deducted on DGMS compliance consultant fee — Section 40(a)(ia) 30 percent expenditure disallowance exposure. A treasury clerk processing the DGMS compliance consultant retainer as a mine operating expense without deducting Section 194J 2 percent TDS above the Rs 30,000 per year threshold would deposit the full retainer invoice amount without the TDS deduction. At Income-tax assessment the Officer applies Section 40(a)(ia) 30 percent expenditure disallowance on the consultant fee (Rs 8 lakh times 30 percent = Rs 2.4 lakh disallowance on the illustrative Sirohi mine), reversible in a subsequent year on deposit of the deducted TDS but a working capital hit in the assessment year. Reconciliation discipline: the compliance ledger holds a consultant-payee master with the PAN, the Section 194J TDS treatment tag and the year-to-date payment position against the threshold, and the payment processing routes through the master rather than being a case-by-case judgement by the treasury clerk. The reconciliation failure mode analysis for India design pillar frames the master-driven-classification discipline that surfaces this failure at the payment-processing stage.

• DGMS inspection observation corrective action not closed by target date — Ind AS 37 provision not recognised at balance sheet date. A mine head running the DGMS observation corrective action tracker on a physical file or a spreadsheet without a balance sheet date review can miss recognising an Ind AS 37 provision on a corrective action that has slipped past the target closure date with a probable penalty risk. The statutory auditor reviewing the notes to accounts flags the missing provision as a departure from Ind AS 37, and the following year’s assessment surfaces the actual penalty levied by DGMS as a prior period item. Reconciliation discipline: the corrective action tracker holds every DGMS observation raised with the observation date, the Metalliferous Mines Regulations 1961 reference, the responsible officer, the target closure date, the actual closure date, the penalty risk classification (probable / possible / remote) and the Ind AS 37 provision amount if applicable; the tracker is refreshed at every balance sheet date with the mine head sign-off and the plant CFO review. The parallel ICFR internal financial controls reconciliation India walkthrough (referenced in the Cement Wave 2 cornerstone at BIS certification cost accounting India) frames the internal-controls anchor for the Ind AS 37 balance sheet date review.

• Safety Committee monthly meeting minutes register incomplete — DGMS inspection observation on Mines Rules 1955 non-compliance. A mine constituting a Safety Committee under the Mines Rules 1955 but running the monthly meeting on a sporadic basis without documented minutes will attract a DGMS inspection observation on Mines Rules 1955 non-compliance at the annual audit. The observation carries a corrective action requirement and a stated or implied penalty risk. Reconciliation discipline: the compliance ledger holds a standing monthly Safety Committee meeting calendar with the meeting date, the attendee register (equal management-workmen representation), the agenda covering safety incidents review, near-miss reports review, corrective action closure status and safety training scheduling, and the minutes signed by the meeting chair. The seven-family human-error taxonomy that surfaces the meeting-schedule-drift gap sits in the human errors detection envelope anchor.

How a reconciliation platform handles this

A purpose-built cement reconciliation platform ingests every DGMS compliance ledger entry at the mine level — every Safety Manager appointment record with the DGMS certificate of competency reference, every DGMS compliance consultant invoice with the Section 194J 2 percent TDS deduction and Form 26Q entry, every annual DGMS audit engagement letter and Form B / C / D / E filing acknowledgement, every quarterly rescue rehearsal record with breathing apparatus maintenance log, every PESO magazine licence certificate with expiry date and Form 22 possession licence, every safety training and First Aid programme completion record, every monthly Safety Committee meeting minutes entry, every accident report on Form N or Form K with the DGMS acknowledgement, every DGMS inspection observation with the Metalliferous Mines Regulations 1961 reference and corrective action target closure date, and every Ind AS 37 provision amount if the penalty risk is probable. Standing dashboard controls surface any PESO magazine licence approaching the 90-day renewal window without renewal application initiated, any Safety Manager appointment gap or DGMS certificate expiry approaching, any Safety Committee monthly meeting missed, any Section 194J TDS not deducted on a consultant invoice above the threshold, any accident report not filed within the statutory time window, any DGMS observation past the target closure date without corrective action closure, and any Ind AS 2 per-tonne conversion cost allocation not reconciled to the mine cost centre year-to-date position. The 51 to 88 percent match-rate improvement on the DGMS compliance calendar reconciliation and on the mine cost centre to limestone raw material inventory allocation, combined with an ISO 27001:2022 posture and DPDP Act 2023 aligned data handling for regulator-facing submissions to DGMS and PESO, is what makes the platform an infrastructure investment for a Tier-1 or Tier-2 Indian cement producer operating a captive limestone mine at scale — rather than a spreadsheet substitute that leaves the six compliance obligations, the six recurring cost buckets, the Section 194J TDS mechanic on the consultant fee and the Ind AS 37 provision on unresolved inspection observations as manual overheads on a hybrid mine-head-plus-plant-finance team. The commercial pillar for the cement sub-cluster is cement reconciliation software India; the broader authority for the platform is reconciliation software India.

Cross-cluster bridges and where to read next

The DGMS mine safety compliance cost accounting mechanic documented here closes the Cement Wave 3 Theme 1 captive-limestone-mining-lifecycle series alongside four sibling walkthroughs. The Section 135 CSR cement plant 2 percent Schedule VII reconciliation India Wave 3 cornerstone unpacks the Companies Act 2013 Section 135 mandatory CSR spend mechanic that runs at the cement producer’s holding-company level parallel to the mine-level DGMS compliance. The Section 194C transport contractor rail-road siding cement plant TDS reconciliation Wave 3 walkthrough covers the Section 194C 2 percent TDS mechanic on the railway contractor and road-freight contractor payments that carry limestone from the mine to the plant and finished cement from the plant to the market. The CEPI Comprehensive Environmental Pollution Index cement plant MoEFCC critical area reconciliation walkthrough unpacks the CPCB-mandated CEPI score mechanic that flags critically-polluted-area cement plants for additional compliance and expansion moratorium. The cement industry CBAM Carbon Border Adjustment Mechanism EU export reconciliation walkthrough covers the EU Regulation 2023/956 CBAM Certificate mechanic for Indian cement clinker and Portland cement exports to the EU market.

The Cement Wave 1 Theme 1 captive-limestone-mining-lease-and-royalty series at limestone royalty plus DMF plus NMET cost accounting for a cement plant and MMDR Act 1957 limestone mining lease cement industry cost reconciliation documents the parallel raw-material-input-side cost mechanic — the three-layer per-tonne royalty plus DMF plus NMET stack, the Ind AS 16 mining rights capitalisation and the Ind AS 2 limestone raw material loading — that runs alongside the DGMS compliance stack at the same mine cost centre. The Section 194Q limestone purchase mining lease cement reconciliation Wave 1 walkthrough covers the Section 194Q buyer-side TDS mechanic on the third-party limestone purchases that supplement captive mine supply for some producers. The Wave 1 environmental compliance cornerstone at cement plant CTE and CTO MoEFCC Category A EIA cost accounting India and the sibling walkthroughs at CPCB Red Category cement plant CTO annual renewal cost reconciliation and CAAQMS CEMS and ATFEMS cement plant emission monitoring cost capex opex frame the parallel MoEFCC and CPCB compliance perimeter that operates alongside the DGMS compliance perimeter — the two perimeters overlap at the mine-and-plant boundary and the compliance calendar must hold both. The cement plant CEMS quarterly NABL calibration TÜV SÜD SGS cost reconciliation Wave 2 sibling documents the parallel Section 194J TDS mechanic on the CEMS-calibration-consultant fee leg that runs identical to the DGMS-compliance-consultant fee mechanic documented here.

The Chemicals Wave 3 sibling at MoEFCC CTE and CTO clearance chemical plant cost accounting India frames the parallel Section 37 versus Ind AS 38 boundary mechanic for the chemical-plant environmental clearance costs, transferring directly to the cement industry DGMS compliance mechanic by direct substitution of the regulator (DGMS instead of CPCB and MoEFCC) and the statute (Mines Act 1952 instead of the Environment (Protection) Act 1986). The variance-classification and operational reconciliation methodology framework — mapping each DGMS compliance obligation to a reconciliation surface, holding the PESO licence expiry heatmap and the Safety Manager tenure heatmap as Class A standing controls, running the Safety Committee monthly meeting minutes register, closing the Section 194J TDS mechanic on the compliance consultant fee, and threading the Ind AS 2 conversion cost allocation and the Ind AS 37 provision through the mine cost centre — sits in reconciliation failure mode analysis and reconciliation playbook for monthly close. The seven-family human-error taxonomy and trust posture on coverage limits sits in human errors detection envelope. Operational lookups sit in the Section 393 payment code finder for the correct TDS payment code on Section 194J deductions against the DGMS compliance consultant fee and the cement limestone royalty DMF NMET cost calculator for the parallel per-tonne royalty stack at the same mine cost centre.

The five FAQs below address the operational questions Indian cement plant mine heads, Safety Managers, plant CFOs, statutory auditors and DGMS inspection teams ask most often when building the annual DGMS compliance packet across the six recurring cost buckets under the seven regulatory anchors — Mines Act 1952 (parent statute), Mines Rules 1955 (subordinate legislation), Metalliferous Mines Regulations 1961 (technical standards), Explosives Act 1884 and Explosives Rules 2008 (PESO magazine licence), Section 37 IT Act 1961 (revenue-expense deduction), Ind AS 2 (conversion cost inclusion) and Ind AS 37 (provisions for probable DGMS penalty) — with Section 194J sitting parallel for the compliance-consultant fee TDS mechanic.

Terra Insight Editorial Team Reconciliation Infrastructure

Content authored by practitioners with experience at Amazon India, Intuit QuickBooks, and the Tata Group. Meet the team →

Published 28 July 2026

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TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops

Reviewed by

NK

Navin Krishnan

Managing Director & Founder — Terra Insight

Ex Amazon India · Intuit QuickBooks · Tata nexarc

ISO 27001:2022 Patent Pending Incorporated 2024