Policies

Policy on Preservation of Documents


Expo Gas Containers Ltd.

TABLE OF CONTENTS

Sr. No.

Details

1

Legal Framework

2

Definition

3

Objective

4

Provision with regard to preservation  of Documents under various  Regulations and laws

5

Mode of Preservation of Documents

6

General

7

Amendment

1. Legal Framework
Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”) imposed certain obligations and disclosure requirements on all the listed entities, one of the common obligation for all the listed entities pursuant to Regulation 9 is to formulate and put in place a policy for preservation of documents.
The Board of Directors of Expo Gas Containers Limited (the “Company”) is obliged to formulate a policy for “Preservation of Documents” to comply with the requirements of Regulation 9 of the Listing Regulations.
This Policy will be applicable to the Company effective 1 March, 2016.

2. Definitions
1. “Board” Board means “Securities and Exchange Board of India.”
2. “Company” Company means “Expo Gas Containers Limited”
3. “Documents” Documents means all papers, records, files, books etc., and the like as required to be maintained under any law or regulation for the time being in force.
4. “Listing Regulations” Listing Regulations means Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”)

3. Objective
The purpose of this policy is to have a binding framework for the preservation of documents of the company, as approved by the Board of Directors of the company, which shall classify them in at least two following categories as follows:

  • Documents whose preservation shall be permanent in nature;
  • Documents with preservation period of not less than eight (8) years after completion of the relevant transactions.

Provided further that the Company may keep the documents as specified above in electronic mode.

 4. Provision with regard to Preservation of Documents under various Laws
Documents whose preservation shall be permanent:

Sr. no. Name of the Document Regulation Reference
1 Shareholding Pattern 31 (1) (b)
2 Quarterly Financial Results 33 (3) (a)
3 Annual Financial Results 33 (3) (d)
4 Annual Report 34(1)
5 Shareholding Pattern in case of Capital Restructuring 31 (1) (c)
6 Voting Results by Shareholders 44 (3)
7 Draft Scheme of Arrangement 37 (2)
8 Yearly Disclosure of shareholding of Promoters 30 (2) of Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulation, 2011
9 Development/ Intellectual property and Trade Secretes Intellectual Property Act
10 Electronic Mail
11 Board and Committee Meeting Minutes Companies Act, 2013
12 Statutory Registers Companies Act, 2013

Preservation of Documents for 8 years:

Sr. no. Name of the Document Regulation Reference
1 Statement under Grievance Redressal Mechanism 13(3)
2 Corporate Governance Report 27(2)(a)
3 Statement of deviation or variation in use of issue proceeds 32(1)
4 Compliance Certificate to the exchange about the share related activities maintained by RTA registered with SEBI 7(3)
5 Compliance Certificate w.r.t. Transfer or transmission or
transposition of securities within 30 days
40(10)
6 Listing Fees 14
7 Intimation of appointment of Share Transfer Agent 7(5)
8 In‐principle approval prior to issue of securities 28(1)
9 Prior Intimations of Board Meeting for financial Result 29(1)(a)
10 Prior Intimations of Board Meeting for Buyback, voluntary delisting etc 29(1)(b), 29(1) (c),
29(1)(d), 29(1) (e)
and 29(1) (f)
11 Prior Intimations of Board Meeting for alteration in nature of securities 29(3)
12 Disclosure of Price Sensitive Information 30(6)
13 Shareholding Pattern prior to listing of securities 31(1)(a)
14 Record date or Date of closure of transfer books 42(2)
15 Record date for declaring dividend and /or cash bonus 42(3)
16 Change in name of listed entity 45(3)
17 Disclosure of information or events 30
18 Reconciliation of Share Capital Audit Report 55A of SEBI (Depositories and Participants) Regulations, 1996
19 Disclosures under Code of Internal Procedures And Conduct For Regulating, Monitoring And Reporting Of Trading By Insiders 10 (1)
20 Tax Records As per applicable  Act

5.  Mode of Preservation of Documents
The documents specified in Item Nos. 4 shall be kept in electronic mode and/or Physical mode as decide by the Board time to time.

6.  General
Notwithstanding anything contained in this Policy, the Company shall ensure to comply 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.

7. Amendment
Any change in the Policy shall be approved by the Board of Directors of the Company. The Board of Directors shall have the right to withdraw and / or amend any part of this Policy or the entire Policy, at any time, as it deems fit, or from time to time, and the decision of the Board in this respect shall be final and binding.

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