Preservation of Documents and Archival Policy

Preamble:

Regulation 9 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, mandates listed entities to formulate a Policy for preservation and archiving of documents. It is in this context that the Preservation of Documents and Archival Policy (“Policy”) is being framed and implemented.

Scope:

This policy is intended to establish guidelines for the maintenance, management and orderly disposition of corporate records/documents. The Company recognises that all the documents, whether in physical or electronic mode, form an important and integral part of the Company’s records. The preservation of documents is important in order to ensure immediate access to the records, its retrieval and authentication.

Purpose:

The purpose of the policy is to facilitate the following:

  1. Identification of records that are to be maintained permanently or for any other shorter period of time.
  2. Deciding the mode of preservation of documents, whether in physical form or in electronic form.
  3. Retention of records for the periods required by applicable laws and regulations and for other business reasons for a period of time that will reasonably assure their availability when needed.
  4. Preservation of the confidentiality and security of records.
  5. Systematic and non-selective disposition of records not necessary for legal or business reasons.

Definitions:

  1. “Act” means the Companies Act, 2013.
  2. “Applicable Law” means any law, rules, circulars, guidelines or regulations issued by the Securities and Exchange Board of India (SEBI), Ministry of Corporate Affairs (MCA) , The Institute of Company Secretaries of India (ICSI).
  3. “Board” means the Board of the Directors of the Company.
  4. “Books of Accounts” includes records maintained in respect of –
    • All sums of money received and expended by the Company and matters in relation to which the receipts and expenditure take place
    • All sales and purchases of goods and services by the Company
    • The assets and liabilities of the Company; and
    • The items of cost as may be prescribed under section 148 of the Act in case the Company belongs to any class of companies specified under that section.
  5. “Company” means Dixon Technologies (India) Limited.
  6. “Documents” refers to papers, notes, agreements, notices, agenda, circulars, advertisements, declarations, forms, minutes, registers, correspondences, challan or any other record required under or in order to comply with the requirements of any Applicable Law, whether issued, sent, received or kept in pursuance of the Act or under any other law for the time being in force or otherwise, maintained on paper or in Electronic Form.
  7. “Electronic Form” means any electronic device such as servers, computer, laptop, compact disc, floppy disc, pen drive, space on electronic cloud or any other form of storage and retrieval device, considered feasible, whether the same is in possession or control of the Company or otherwise the Company has control over access to it.
  8. “Maintenance” means keeping documents, either physically or in Electronic Form.
  9. “Preservation” means to keep in good order and to prevent from being altered, damaged or destroyed.
  10. “SEBI LODR” means the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015. Words and phrases used in this Policy and not defined herein shall derive their meaning from the Applicable Law.

Any other term not defined herein shall have the same meaning as defined in the Companies Act, 2013, the Listing Agreement, Regulations or any other applicable law or regulation to the extent applicable to the Company.

Roles & Responsibilities:

The respective Functional/ Departmental heads of the Company shall be responsible for identification, maintenance and preservation of documents in respect of the areas of operations falling under the charge of each of them, in terms of this Policy.

Record Type and Preservation

All the documents can be categorised and preserved based on the below criteria:

  • Permanent Records: Documents so identified, shall be maintained permanently in the archives of the Company, and include such documents which:
    • evidences a statutory license/approval/sanction/permission/registration;
      (a) represents a title to an immovable property or an intellectual property;
    • lays down the terms and conditions regarding operation and management of manufacturing units;
    • governs purchase of shares/investments in an entity;
    • is a constitutional document;
    • is a record of statutory meetings/proceedings;
    • Orders passed by any Court /Tribunal/any Authority/ Judgment which are final in nature and cannot be superseded
  • Records maintained for atleast 8 (Eight) years after completion of relevant transactions which have been so decided to be preserved by the Function Heads, either under their own respective judgement or as required to be preserved by any specific Law.
  • Other Functional Documents / Records, which are of routine nature and as may be categorized as such by the Function Heads.

Destruction of Documents:

The documents which are not required to be maintained and preserved permanently may be destroyed after the expiry of the specified retention period in such mode and under the instructions approved by the Functional/ Departmental Heads. Any deviation will be approved by the Managing Director.

However, if a legal issue involving the Company is reasonably foreseeable, all destruction of any possibly relevant documents, including e-mail, must cease immediately. Documents relating to the lawsuit or potential legal issue will then be retained and organized under the supervision of the Group Company Secretary. In such an event, the IT Department shall immediately disable the “permanent delete” and “automatic delete” functions of the Company’s software with respect to the designated records and disable the automatic deletion of recycle bins and deleted items folders on appropriate Company computers; and the Group Company Secretary shall immediately notify all appropriate employees by e-mail that they are not to dispose of relevant temporary records or other records until notified otherwise.

Compliance and Violation

Failure to comply with this Document Retention and Archival Policy may result in disciplinary action.

Dissemination of the Policy:

The approved Policy shall be uploaded on the Company’s website www.dixoninfo.com

Review of Policy

This Policy shall be subject to review, if necessary. Any change/amendments in applicable laws with regard to maintenance and preservation of documents and records shall be deemed to be covered in this Policy without any review.

Any change/amendments to this policy shall be approved by the Managing Director.