1. SCOPE
In compliance with Regulation 9 of the Securities and Exchange Board of India
(Listing Obligations and Disclosure Requirements) Regulations, 2015 (the
‘Listing Regulations’), this Policy for Preservation of Documents provides
framework for preservation of documents of the Company. This Policy aims to
ensure preservation of documents of the Company in compliance with the
applicable statutory and regulatory provisions.
This Policy also aims to ensure business continuity and appropriate
dissemination of information to the stakeholders of the Company through
proper maintenance and retention of corporate records.
2. DEFINITIONS
“Document(s)” refers to papers, notes, agreements, notices, advertisements,
requisitions, order, declarations, forms, correspondence, minutes, indices,
registers and or any other record, required under or in order to comply with the
requirements of any applicable law, whether issued, sent, the time being in or
otherwise, maintained on paper or in Electronic form received or kept in
pursuance of the Act or under any other law for and does not include multiple
or identical copies.
“Electronic Form” means on any electronic device such as computer, laptop,
compact disc, floppy disc, space on electronic cloud, or any other form of
storage and retrieval device, considered feasible, whether the same is in
possession or control of the Company or otherwise the Company has control
over access to it. “Maintenance” means keeping Documents, either physically
or in Electronic Form.
“Preservation” means to keep in good order and to prevent from being altered,
damaged or destroyed.
"Authorised Person" means any person duly authorised by the Board.
3. PERIOD OF PRESERVATION
Documents of the Company shall be classified in the following categories for
determining the period of preservation:
- a) Documents which shall be preserved permanently;
- b) Documents with the preservation period as defined under the applicable
statutory / regulatory provisions.
4. COVERAGE OF DOCUMENTS
The Company shall preserve all its documents as per the requirements and
provisions of the Companies Act, 2013 and the rules made thereunder, the
Secretarial Standards, the Listing Regulations and any other law, rules,
regulations as may be applicable to the Company from time-to-time. While this
Policy lays down the minimum period for preservation of documents, the
retention of documents as identified specifically in the Policy and documents
not identified herein should be determined by the relevant Head of the
Department by applying general guidelines and other important factors.
5. MAINTENANCE OF DOCUMENTS
- a) Documents shall be maintained and preserved properly and stored in
chronological order or in any other logical manner to facilitate easy
identification and retrieval.
- b) Documents shall be properly dated so that their preservation period can be
identified easily.
- c) Documents shall be stored in such a manner that their confidentiality can be
maintained.
- d) Authorised Person shall actively consider maintenance and preservation of
the documents in electronic form unless maintenance and preservation of
documents in physical form is a statutory requirement.
- e) On completion of the Preservation Period, documents may be destroyed at
the instruction of the relevant HoDs after obtaining approval of the
Authorized Person.
An indicative list of documents alongwith the preservation period is given at
Annexure-I to the Policy.
6. REVIEW / AMENDMENT
The Board may amend, abrogate, modify or revise any or all clauses of this
Policy in accordance with the applicable provisions of the Listing Regulations
and amendment(s) thereto notified by the Securities and Exchange Board of
India and/or Stock Exchanges, from time to time. However, amendments in the
Listing Regulations shall be binding even if not incorporated in this Policy.
This Policy was originally approved by the Board of Directors at its meeting
held on October 29, 2015 and revised at the Board meeting held on May 24,
2016,September 4, 2020.
Indicative list of Documents
A. List of documents to be preserved permanently
| Sr. No. |
Particulars of Documents |
| 1 |
Minutes of all Meetings of the Board of Directors and its Committees |
| 2 |
Minutes of General Meetings |
| 3 |
Register of Members along with the index |
| 4 |
Register of Charges |
| 5 |
Register of Contracts in which Directors are interested |
| 6 |
Incorporation documents and documents related to changes in any of the clauses of Memorandum and Articles of Association |
| 7 |
Register of loans, investments, guarantees and securities |
| 8 |
Register of Directors and Key Managerial Personnel |
| 9 |
Registers of Renewed and Duplicate Share Certificates |
| 10 |
Orders of Courts / NCLT relating to mergers, amalgamations or restructuring |
| 11 |
Approvals, licenses and registrations received from Central / State Government authorities |
| 12 |
Intellectual Property documents including patents, trademarks, copyrights and designs owned by the Company |
B. List of documents to be preserved for a period of atleast 8 years
| Sr. No. |
Particulars of Documents |
| 1 |
Copies of Annual Returns prepared under Section 92 and copies of all certificates and documents required to be annexed thereto |
| 2 |
Office copies of Notices, Agenda, Notes on Agenda and other related papers of Board and its Committee meeting including Attendance Registers |
| 3 |
Office copies of Notices of Annual General Meeting, Scrutinizer’s Report and related papers |
| 4 |
The Register of Debenture Holders or any other security holders along with the index |
| 5 |
Disclosure of interest by Directors |
| 6 |
ROC Filings other than Incorporation and changes in any clause of the Memorandum and Articles of Association |
| 7 |
Instrument creating a charge or modification thereon |
| 8 |
Relevant records including the Structured Digital Database pursuant to the Code of Conduct for Prevention of Insider Trading. In the event of receipt of any information from SEBI regarding any investigation or enforcement proceedings, the relevant information in the Structured Digital Database shall be preserved till completion of such proceedings. |
| 9 |
Books and documents relating to the issue of share certificates, including the blank forms of share certificates |
| 10 |
Books of account together with the vouchers relevant to any entry in such books of account |
| 11 |
Tax Records - Tax records including, but not limited to documents concerning tax assessment, tax filings, proof of deductions, tax returns, appeal preferred against any claim made by the relevant tax Authorities, shall be maintained for a period of 8 years or for a period of 8 years after a final Order has been received with respect to any matter which was preferred for appeal, as the case may be |
| 12 |
Employment /Personnel Record should be retained for a period of eight (8) years following cessation of employment in case of employees of the Company. |
| 13 |
Relevant marketing and sales documents |
| 14 |
Legal documents including but not limited to contracts, legal opinions, pleadings, Orders passed by any court or tribunal, Judgments, Interim Orders, Documents relating to cases pending in any Court or Tribunal or any other Authority empowered to give a decision on any matter, Awards, Documents relating to property matters |
| 15 |
Orders passed by any court or tribunal, Judgments, Interim Orders, Documents relating to cases pending in any Court or Tribunal or any other Authority empowered to give a decision on any matter, Awards, Documents relating to property matters |
C. List of documents which are to be maintained on website of the Company
for a minimum period of five (5) years:
| Sr. No. |
Particulars of Documents |
| 1 |
Disclosure of all events and information provided to the Stock Exchanges as per the Listing Regulations |
| 2 |
Investor Presentation and audio video recordings/transcripts of investor calls |
| 3 |
Press Release. |