POLICY FOR PRESERVATION OF DOCUMENTS AND ARCHIVAL POLICY
POLICY FOR PRESERVATION OF DOCUMENTS AND ARCHIVAL POLICY
A. BACKGROUND:
Pursuant to the Regulations 9 and 30(8) of SEBI (Listing Obligations and Disclosure
Requirements) Regulations, 2015 (as defined below), the Company is required to frame a “Policy
for Preservation of Documents and Archival Policy”.
In this context, the Board of Directors has approved the “Policy for Preservation of Documents and
Archival Policy (as defined below) at its meeting held on October 11, 2023 with the objective of
classifying the various information and documents filed with the stock exchange(s), record and
register for the purpose of maintenance and preservation of such information and documents filed
with the stock exchanges, identification of custodian to retain and preserve such records/
information/ documents along with the mode in which such records/ information/ documents will
be maintained.
The Policy shall be applicable for preservation of documents/ records maintained by the
management/ employees of the Company as per the respective statutory/ non statutory
requirements either in (i) Physical mode; or (ii) Electronic Mode.
B. OBJECTIVE OF THE POLICY:
The objective of this Policy is to ensure that all the necessary documents and records of the
Company are adequately protected and preserved for the time limit as per the statutory
requirements and to ensure that the records of the Company which are no longer needed or which
are not required to be maintained as per the statutory requirements or are of no value are discarded
in proper manner, so that no one can have access to such discarded documents, after following the
due process for discarding the documents.
This Policy also outline the framework for all the employees and top management to understand the
roles and responsibilities towards retaining and preserving the documents and records. This Policy
shall also outline the custodian of the documents and records and detail process to get the access of
such documents.
This Policy shall provide the guidelines to classify the documents, records and registers of the
Company which are required:
i. To be preserved permanently; and
ii. To be preserved for a period of not less than 8 years.
C. SCOPE OF THE POLICY:
This Policy shall become applicable to all the departments of the Company by virtue of the
approval by the Board of Directors of the Company. Each and every department of the Company,
are required to maintain certain information, documents, registers and records either as per various
statutory requirement in physical mode or in electronic mode. This Policy will ensure that the
Company maintains the both electronic and physical documents as per various statutory
requirements and shall be preserved with same degree of confidentiality and care.
D. DEFINITION:
i. “Act” means the Companies Act, 2013 and rules framed thereunder (including any statutory
modification or amendment thereof);
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ii. “Board” means the Board of Directors of Srigee DLM Limited;
iii. “Company” means [Name of the Company] incorporated as per Companies Act, 1956/ 2013;
iv. “Documents” means all the business records like registers, records, papers, agreements,
notices, advertisements, requisitions, order, declarations, forms, show cause notice, minutes,
replies, or any other records and registers to be maintained as per the statutory requirement or in
order to comply with the requirements of any applicable law, whether required to be submitted
to concerned authority or sent to government department or any associates, or otherwise, and
records maintained in the electronic form received or kept pursuant to the Companies Act, 2013,
or under any other applicable laws for time being in force or otherwise, maintained in physical
or in electronic form.
v. “Listing Regulations” or “LODR Regulations” means SEBI (Listing Obligations and
Disclosure Requirements) Regulations, 2015.
vi. “Stock Exchange(s)” means the stock exchange where the securities of the Company is listed.
vii. “Maintenance” means keeping documents, either physically or in Electronic form.
viii. “Preservation” means to keep the documents under the custody of authorised person, which
shall prevent the documents from being altered, damaged or destroyed.
ix. “Policy” means this Policy for Preservation of Documents and Archival Policy
Any other term which are not defined herein shall have the same meaning as defined in the SEBI
(LODR) Regulations, 2015, Companies Act, 2013, or any other applicable laws or regulations.
E. PRESERVATION OF DOCUMENTS:
(a) Creation of documents:
Various documents are required to be filed as per the statutory requirements with the
statutory authorities such as stock exchanges. Employees of the Company, in order to
comply with the statutory requirements, may have to initiate and create number of
documents and information. All employees are required to create accurate documents
regarding their respective matters. The documents should:
i. facilitate proper scrutiny of the conduct of businesses by anyone authorised to undertake
such scrutiny;
ii. protect the legal, financial and other rights of the Company, its clients, employees and
any other connected person/ Company with the business of the Company;
iii. be confidential in nature and the confidentiality of such documents shall be maintained at
all the time.
(b) Preservation of documents:
The Company shall preserve all the documents as per the requirements and provisions of the
Companies Act, the Secretarial Standards, LODR Regulations, and any other law, rules,
regulations as may be applicable to the Company from time to time.
Every employees and top management of the Company is responsible for making and
keeping the documents as may be necessary to fully and accurately record the functions,
activities, transactions and affairs of the Company. They must ensure that the documents
once freezed in complete aspect, shall be tamper-free and no one shall have access to any
confidential information of such documents. They must further ensure that the documents are
handle with care and are preserved to avoid any damage before its prescribed time limit.
(c) Discarding the documents:
Documents are created and are maintained for certain time limits which is a statutory
requirement and failure to adhere to such requirement of preservation of statutory documents
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shall attract penalty and fine on top management. In order to avoid any legal action, it is
necessary for the Company to maintain all the statutory documents for the time limits as
prescribed and to maintain the records of documents disposed of after meeting the statutory
requirements of preserving such documents.
All the documents mentioned in “Annexure – I” need to be permanently preserved by the
Company during its entire life time.
All documents mentioned in “Annexure – II” which is temporary in nature must be
preserved for a period not less than 8 years or such other period as may be prescribed under
any law for the time being in force and thereafter the records can be destroyed. The details of
the Documents destroyed by the Company shall be recorded in the Register for Disposal of
Records to be kept by employees who are disposing the Documents in the format prescribed
at “Annexure – III”.
F. CUSTODY OF THE DOCUMENTS:
Documents which are required to be maintained and preserved by the respective head of the
departments are provided in the table entailed below. Following are the list of authorised person
who shall act as the custodian of the documents:
Sr.
No.
Documents Authorised person / Custodian
Legal Files/ Documents Head – Legal department
Secretarial related documents Head – Secretarial Department
Tax / Accounting Records Chief Financial Officer
Employment / Personal data
of employees
Head – Human Resources department
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ARCHIVAL POLICY:
Regulation 30(8) of the Listing Regulations requires the listed companies to disclose on its website all
such events or information which has been disclosed to stock exchange(s) pursuant to the various
provisions of the Listing Regulations, and such disclosures shall be hosted on the website of the
Company for a period of minimum 5 (five) years and thereafter as per the Policy of the Company, as
disclosed on its website. The purpose of the Policy is to disseminate equal, adequate and timely
information to the shareholders through the website of the Company and to enable them to track the
performance/ events of the Company over regular intervals of time and provide sufficient information to
enable investors to access the current status of the Company.
The website of the Company viz., www.srigee.com shall be reviewed on regular intervals for ensuring
that all the above mentioned disclosures are available on the website of the Company as required.
POLICY REVIEW:
This Policy shall be reviewed from time to time so that the Policy remains compliant with the applicable
legal requirements. The Company Secretary will keep the Policy updated as per applicable statutory
guidelines.
This Policy can be modified and/ or amended only with the approval of the Board of Directors.
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ANNEXURE – I: DOCUMENTS TO BE PRESERVED PERMANENTLY
Following are the list of documents which shall be preserved permanently by the Company subject to the
modifications, amendments, addition, deletion or any changes made therein from time to time:
Item No. Records/ Documents
1 Certificate of incorporation
2 Certificate for commencement of business
3 Memorandum and Articles of Association (along with the amended copies)
4 Agreements made by the Company with Stock Exchanges, Depositories, etc.
5 Minute Books of General Meetings, Board and Committee Meetings as per Companies
Act, 2013 and Secretarial Standards
6 All the registers and records as per Companies Act and LODR Regulations
7 Such other records as may be required under any law from time to time
8 Intellectual Property Documents shall include but shall not be limited to Copyrights,
Trademarks, Patents, and Industrial Designs, Intellectual Property rights documents that
are owned by the Company shall be retained by the Company permanently
9 All the documents like agreements, application, stamp duty payment receipts for all the
properties that are owned in the name of the Company