POLICY ON PRESERVATION OF DOCUMENTS

INTRODUCTION

In terms of Regulation 9 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”), the Board of Directors (the “Board”) of M/S. SUCHITRA FINANCE & TRADING CO. LTD has adopted this Policy for Preservation of Documents, as required under applicable regulations.

This Policy is effective from December 01, 2015.

In any circumstance, where the terms of this policy differ from any existing or newly enacted law, rule, regulation or standard governing the Company, the law, rule, regulation or standard will take precedence over this Policy and procedures until such time as this Policy is changed to conform to the law, rule, regulation or standard.

OBJECTIVES

This Policy mechanism provides the comprehensive framework for preservation of documents for a specified period of time to achieve the following objectives:

1. Effective corporate governance and risk management;
2. Effective information management to support the work of the administrations and provision of continued access to it at times when needed;
3. Systematic disposal/destruction of Company’s non-current records that have outlived their administrative usefulness.
4. Identification of the Company’s records that are of continuing administrative and historical value to warrant their transfer to and preservation in the Company’s Archives

DEFINITION

In this policy unless the context otherwise requires

1. “Act” means the Companies Act, 2013 and rules made there under, as amended from time to time
2. “SEBI Regulations” shall mean Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, as may be amended from time to time
3. “Company” means M/s. Suchitra Finance & Trading Co. Ltd.
4. “Document” includes summons, notice, requisition, order, declaration, form and register, whether issued, sent or kept in pursuance of this Act or under any other law for the time being in force or otherwise, maintained on paper or in electronic form;
5. “Key Managerial Personnel” or “KMP” shall have the same meaning ascribed to it under the Act.
6. “Board” or “Board of Directors” shall mean the Board of Directors of Suchitra Finance & Trading Co Ltd, as may be re-constituted from time to time
7. “Financial Year” shall have the same meaning ascribed to it under the Act.
8. “Electronic Form” with reference to information means any information generated, sent, received or stored in media, magnetic, optical, computer memory, micro film, computer generated micro fiche or similar device.

The words or expressions used but not defined herein, but defined under Companies Act, 2013 or the SEBI Regulations shall have the same meaning assigned therein.

SCOPE

For the purpose of achieving the above objectives, the documents covered as per this Policy have been divided into two sections, i.e. the records or the documents that will be preserved permanently by the Company and the records or the documents that will be preserved for the period of atleast 8 years and not permanently. This Policy applies to the records maintained by the Company in any format or medium. The records which are not required to be retained permanently shall be disposed off according to this Policy.

RESPONSIBILITY

The departmental head concerned will be responsible for the maintenance, preservation and destruction of records pertaining to the respective Department.

All staff and management of the Company shall assist in implementing this Preservation Policy as appropriate to their respective roles and responsibilities.

PRESERVATION PERIOD

Based on the requirement and for the purpose of effective management, the period for which the records of the Company shall be maintained have been classified into two categories:

1. Documents whose preservation shall be permanent in nature;
2. Documents whose preservation shall be at least for 8 years.

The classification of the documents has been made in the Annexure which forms part of this Policy.

While prescribing different time periods for preservation of records, the following aspects have been taken into account:

1. Compliance with statutory and regulatory requirements.
2. Requirements of SEBI/RBI/MCA officials to have access to certain records.
3. Requirements of internal and external auditors to have access to certain records.



The documents or records not covered by this Policy shall be maintained by the Company for the time period specified for their preservation under any statute or regulation, for the time being in force.

PRESERVATION LOCATION

The preservation location will be the concerned department. If the location is other than the concerned department, the same should be documented and kept in a file for reference purpose in the respective department.

MODE OF PRESERVATION

Records/documents may be preserved either physically or in electronic form.

RECORD RETENTION SCHEDULE

The records referred to in Annexure A of this Policy shall be maintained permanently and the records which are required to be preserved permanently on the website of the Company shall be preserved in line with the Archival Policy of the Company.
Records should not be kept longer than is necessary and should be disposed of at the right time as unnecessary retention of records consumes time, space and equipment use. The records referred to in Annexure B shall be preserved for at least 8 years or may be disposed of after the expiry of the periods of their preservation, after the approval of the Company Secretary and Chief Financial Officer of the Company.
The Company shall maintain a register of disposal of records in the custody of the Compliance Officer of the Company, wherein the brief particulars of the records disposed off shall be entered. The register of disposal of records shall contain the following columns:

1. Item Number;
2. Brief Particulars of the records disposed of;
3. Date of approval for disposal of records;
4. Date of disposal; and
5. Mode of destruction

This register of disposal of records shall be maintained permanently by the Company with the assistance of the Compliance Officer either in physical or electronic form.

AMENDMENT

The Board of Directors of the Company reserves the right to amend or modify this Policy in whole or in part, as may be required, at any point of time.

Annexure A

 

 

RECORDS TO BE PRESERVED PERMANENTLY
 

Item No.	Records
1.	Certificate of incorporation
2.	Certificate for commencement of business
3.	Memorandum and Articles of Association
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
6.	Register and Index of Members, debenture-holders, if any or other security holders, if any
7.	Register of Contracts as per Companies Act, 2013
8.	Register of Charges as per Companies Act, 2013
9.	Register of Investments as per Companies Act, 2013
10.	Files relating to premises viz. Title Deeds/Lease Deeds of owned premises/land and building, etc. and related Ledger / Register
11.	Authorization / licenses obtained from any statutory authority
12.	Policies of the Company framed under various regulations
13.	Register of disposal of records
14.	Certificates obtained from various statutory authorities
15.	Such other records as may be required under any law from time to time

Annexure B

 

 

RECORDS TO BE PRESERVED FOR MINIMUM PERIOD OF EIGHT YEARS
 

Item No.	Records
1.	Instrument creating charge or modification (from the date of satisfaction of charge) as per Companies Act, 2013
2.	Register of Inter Corporate Loans and Investments as per the Companies Act, 2013
3.	Annual Returns as per Companies Act, 2013
4.	Register of Deposits as per Companies Act, 2013
5.	Register of Allotment (from the date of each allotment) as per Companies Act, 2013
6.	Annual financial statements including: * Annual accounts * Directors report * Auditors report
7.	Vouchers / Voucher register and books of accounts as defined under sub-section 13 of section 2 of the Companies Act, 2013
8.	Income Tax Returns filed under Income Tax Act, 1961
9.	All notices in form MBP 1 received from Directors and KMPs alongwith any amendment thereto
10.	Return of declaration in respect of beneficial interest in any share as per Companies Act, 2013
11.	Copy of newspaper advertisement or publications
12.	Records relating to Court Cases / CBI Cases / Police Cases/ Civil Suits/ Labour Court Cases/ Arbitration Cases.
13.	Compliance Reports received from any statutory authority
14.	Correspondences made with any statutory authority
15.	Register of Power of attorneys, if any
16.	Forms and returns filed with RBI/MCA or with any other statutory