POLICY ON PRESERVATION OF DOCUMENTS
1. LEGAL FRAMEWORK
Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“LODR”) imposed certain obligations and disclosure requirements on all listed entities, one of the common obligations for all listed entities pursuant to Regulation 9 being to formulate and put in place a policy for preservation of documents.
The Board of Directors of Shree Narmada Aluminium Industries Limited (“the Company”) is required to formulate a policy for “Preservation of Documents” to comply with the requirements of Regulation 9 of the Listing Regulations.
- a. “Board of Directors” or “Board” Board of Directors or Board shall mean the Board of Directors of Shree Narmada Aluminium Industries Limited, as constituted from time to time.
- b. “Company” Company shall mean “Shree Narmada Aluminium Industries Limited”.
- c. “Documents” Documents shall mean all papers, records, files, books, tapes, CDs, DVDs, electronic storage devices etc., and the like as required to be maintained under any law or regulation for the time being in force.
- d. “Listing Regulations” Listing Regulations shall mean Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“LODR”).
This policy sets the standards for managing, storing and preservation of documents of the Company broadly classified in the following two categories:
- A. The documents of a permanent nature (listed in Annexure 1) shall be maintained and preserved permanently by the Company subject to the modifications, amendments, additions, deletions or any changes made therein from time to time.Provided that all such modifications, amendments, additions, deletions in the documents shall also be preserved permanently by the Company.
- B. The documents to be maintained and preserved for a specified time period after completion of the relevant transactions (listed in Annexure-2) shall be preserved by the Company for the term not less than eight years after completion of the relevant transactions subject to the modifications, amendments, additions, deletions or any changes made therein from time to time.Provided that all such modifications, amendments, additions or deletions in the documents shall also be preserved for a term not less than eight years.
Provided further that the Company may keep the documents as specified above in an electronic mode.
4. ROLES & RESPONSIBILITIES
The respective Departmental Heads of the Company shall be responsible for maintenance, preservation and destroying of documents in respect of the areas of operations falling under the charge of each of them, in terms of this policy.
Notwithstanding anything contained in this policy, the Company shall ensure compliance with any additional requirements as may be prescribed under any laws/regulations either existing or arising out of any amendment to such laws/regulations or otherwise and applicable to the Company, from time to time.
6. DESTRUCTION OF DOCUMENTS
After the expiry of the statutory retention period, the preserved documents may be destroyed in such mode under any instructions approved by the department head(s). Destruction of documents as a normal administrative practice will also be followed for the records which are duplicate/unimportant/irrelevant. This applies to both Physical and Electronic Documents.
7. COMMUNICATION AND DISSEMINATION OF THE POLICY
This Policy shall be disclosed on the Company website.
The Board may subject to the applicable laws amend any provision(s) or substitute any of the provision(s) with the new provision(s) or replace this policy entirely with a new policy. However, no such amendment or modification shall be inconsistent with the applicable provisions of any law for the time being in force.
Documents whose preservation shall be permanent in nature:
- 1. Registration Certificates;
- 2. Licenses & Statutory Approvals;
- 3. Statutory Registers required under applicable laws;
- 4. Audited financial statements;
- 5. Minutes of General Meetings;
- 6. Minutes of Board Meetings;
- 7. Minutes of various Committee Meetings;
- 8. Material Agreements/Contracts;
- 9. Orders issued by Courts/Statutory bodies;
- 10. Investment Documents/proofs including certificates etc.;
- 11. Insurance Policies/ Claims under various policies;
- 12. Any other document as may be required to maintain permanently in terms of applicable law(s), maintained and preserved from time to time.
The documents to be maintained and preserved for a specified time period after completion of the relevant transactions:
- Contracts entered into by the Company including Marketing Records:
- Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documents.
- Accounting and Finance records including Annual Financial statement:
- Accounts Payable ledgers and schedules;
- Accounts Receivable ledgers and schedules;
- Bank Statement and Cancelled Cheques;
- Employee Expense Reports;
- Interim Financial Statements;
- Notes Receivable ledgers and schedules.
- Insurance Records:
- Annual Loss Summaries;
- Audits and Adjustments;
- Group Insurance Plans – Active Employees;
- Journal Entry Support Data.
- Tax records:
- Payroll Tax records;
- Tax Bills, Receipts, Statements;
- Tax work paper packages ‐ Originals;
- Sales Tax Records;
- Service Tax Records.