Policy on Preservation Of Documents
34/A, Kailash Park Society, Nr. United Way Garba Ground, Old Padra Road, Vadodara-390005,
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 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 Neopolitan Pizza Limited (“the Company or NEO”) is required to formulate a policy for “Preservation of Documents” to comply with the requirements of Regulation 9 of the Listing Regulations.
This Policy is effective December 1, 2015.
A. “Board of Directors” or “Board”
Board of Directors or Board shall mean the Board of Directors of Neopolitan Pizza Limited as constituted from time to time.
Company shall mean “Neopolitan Pizza Limited”.
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 (“Listing Regulations”)
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
For all new Employees, a copy of this policy shall be handed over as a part of the joining documentation, along with other HR related policies. For all existing Employees and Directors, a copy of this policy shall be posted on the intranet and the web-site of the Company.
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.
ANNEXURE 1: DOCUMENTS WHOSE PRESERVATION SHALL BE PERMANENT IN NATURE:
| Sr. No
|| Nature of Document(s)
||Licenses & Statutory Approvals
||Statutory Registers required under applicable laws
||Audited financial statements
||Minutes of General Meeting
||Minutes of Board Meeting
||Minutes of various Committee Meetings
||Orders issued by Courts/Statutory bodies
||Investment Documents/proofs including certificates etc.
||Any other document as may be required to maintain permanently in terms of applicable law(s), maintained and preserved from time to time.
ANNEXURE 2: DOCUMENTS WITH PRESERVATION PERIOD OF NOT LESS THAN EIGHT YEARS AFTER COMPLETION OF THE RELEVANT TRANSACTIONS:
| Sr. No
|| Nature of Document(s)
||Books of Accounts
||Insurance Policies/ Claims under various policies
||Correspondences with Departments/shareholders
||Films, Videos, CDs, DVDs, tapes etc.
||Any other document as may be required to maintain in terms of applicable law(s), maintained and preserved from time to time.