Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("Listing Regulations") imposes certain obligations and disclosure requirements on all listed entities. One of the common obligations for all listed entities pursuant to Regulation 9 is to formulate and put in place a policy for preservation of documents.
Accordingly, the Board of Directors of Berger Paints India Limited ("the Company") has approved this Policy for Preservation of Documents.
"Board"
Board shall mean the Board of Directors of Berger Paints India Limited.
"Company"
Company shall mean "Berger Paints India Limited".
"Documents"
Documents shall mean all papers, records, files, books, etc., be in printed or in digital form and the like as required to be maintained under any law or regulation for the time being in force.
"Listing Regulations"
Listing Regulations shall mean Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("Listing Regulations").
The purpose of this Policy is to have a 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:
Provided that the Company may keep the documents as specified above in electronic/digital mode.
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.
The Company will preserve documents relating to matters which are continuing in nature and are relevant to understanding of business.
After the expiry of the 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.
The Company operates in an ERP environment. The database will be maintained and data purging, if necessary, will be carried out in accordance with this Policy.
The Director – Finance & Chief Financial Officer and the Company Secretary shall be jointly authorised to address any question or doubt and remove any difficulty during the course of implementation of this Policy in accordance with the same.
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.
Documents whose preservation shall be permanent in nature
Documents with preservation period of not less than eight (8) years