SHYAM TELECOM LIMITED

POLICY ON PRESERVATION OF RECORDS

PURPOSE OF POLICY

In terms of Regulation 9 of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”) the Board of Directors (the “Board”) of SHYAM TELECOM LIMITED (the “Company”) has adopted this Policy at its meeting held on February,8th 2016 for preservation of Records.

OBJECTIVE OF POLICY

This Policy contains guidelines for identifying Records that need to be maintained, the period of preservation of such Documents. This Policy aims to provide efficient and systematic control on the preservation of business related Documents.

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

a)Effective corporate governance and risk management;

b)Identification of the Company’s records that are of continuing administrative and historical value to warrant preservation.

DEFINITIONS

  1. “Act” means the Companies Act, 2013 and rules made thereunder, as amended from time to time.
  1. “Board” or “Board of Directors” shall mean the Board of Directors of Shyam Telecom Limited, as may be re-constituted from time to time.
  1. “Company” means Shyam Telecom Limited
  1. “Financial Year” shall have the same meaning ascribed to it under the Act.
  1. “Listing Regulations” means the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015;
  1. “Policy” means Policy of Shyam Telecom Limited on preservation of records pursuant to regulation 9 of Securities and Exchange Board of India (Listing Obligations and Disclosures) Regulations, 2015;
  1. “Records” in relation to this policy means document maintained in any medium (paper, electronic, optical, magnetic, etc.), that is created, received, transmitted or used in the course of and in relation to the business of the Company.

The words and expressions used which are not defined in this Policy, but defined in the SEBI Act, 1992, Companies Act, 2013, the Income Tax Act, 1961 and other applicable Laws, and/or the rules and regulations made thereunder shall have the same meaning as respectively assigned to them in such Acts or rules or regulations or any statutory modification or re-enactment thereto, as the case may be.

Words importing the singular number shall, unless the context otherwise requires, also include the plural number and vice versa.

SCOPE

This Policy applies to all departments and business functions of the Company.

RESPONSIBILITY

TheHeads of respective Works/Zones/Functions shall be responsible for monitoring the implementation of this Policy.

CLASSIFICATION OF RECORDS

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 three categories:

  1. Records whose preservation shall be permanent in nature;
  2. Records whose preservation shall be for at least 8 years.
  3. Records whose preservation is required for less than 8 years

The classification of the Records and periodicity of the preservation of records has been made in the Annexure which forms part of this Policy.While prescribing different time period for preservation of Records compliance with statutory and regulatory requirements have been taken into account.

If any record is not mentioned in the Annexure,then the period of preservation of such record shall be determined by the provisions of relevant Act, Statute, rules and regulations and in other cases as determined by the respective head of the department.

LOCATION OF RECORDS

Preserved Records shall be kept confidentially, securely and with ease of retrieval, whether in-house or externally subject to the requirement of applicable law(s), statute(s), rules and regulations.

RECORD APPRAISAL

The Heads of respective Works/Zones/Functions shall at regular intervals carry out the appraisal of the Records preserved as per this Policy. The purpose of the appraisal process is to ensure the Records are examined at the appropriate time to determine whether they are worthy of preservation, whether they need to be retained for a longer period as they are still in use, or whether they should be destroyed.

EFFECTIVE DATE AND POLICY ENFORCEMENT

This Policy shall be effective from February,8th 2016.

REVIEW OF THE POLICY

The Policy shall be reviewed by the Board as and when required to ensure that it meets the objectives of the Statutory Provisions and remains effective.

ANNEXURE

PERIODICITY OF PRESERVATION OF DOCUMENTS

Document Category / Document type / Preservation period
Company Operations /
  • Memorandum / Articles of Association
  • Certificate of incorporation
  • Licenses, certificates, approvals and other such documents issued by Central/State Government and any other statutory and/or regulatory body
  • Policies, Charters and Codes of the Company
  • Other related Documents
/ Permanent
Tax and Finance records /
  • Books of accounts, including inter-alia, financial statements, vouchers relevant to entry in books of accounts, audit records, invoices, expense records, bank records etc. in accordance with the applicable provisions of Companies Act, 2013, Income tax Act, and any other applicable laws.
  • Application/correspondence with various Direct and Indirect tax authorities
  • Excise invoices / bills / Challans
  • Returns and Assessment Records
  • Sales Tax documents
  • Loan related Documents
  • Agreements pertaining to creation of charge
  • Documents related to all other taxes and duties
  • Orders passed by Tax authorities
  • Other related Documents
/ Eight financial years
Secretarial records /
  • Minutes of the meetings of the Board of Directors and of its Committees
  • Minutes of all meetings of shareholders
  • Office copies of Notices, scrutinizer’s report and other documents related to meetings of shareholders/ creditors of the Company
  • Attendance register of the meetings of the Board and its Committees
  • Register of Members, Register of Contracts, Register of Charges, Register of Transfer of shares, Register of Investments in securities not held in the name of the Company etc.
  • Agreements with Stock Exchanges, Depositories etc.
  • Statutory filings with ROC, Ministry of Corporate Affairs.
  • Applications and approvals for issuance and listing of securities
  • Land title deeds/documents/receipts
  • Other Documents required to be permanently preserved under the Companies Act, 2013.
/ Permanent
  • Instrument creating charge or modification (from the date of satisfaction of charge) under Companies Act, 2013
  • Notice, agenda and notes to agenda of meetings of the Board and its Committees
  • All notices in form MBP – 1 received from Directors
  • Return of declaration in respect of beneficial interest in any share under Companies Act, 2013
  • Copy of newspaper advertisement or publications
  • Register of Deposits, Register of Sweat Equity, Register of Inter Corporate Loans and Investments under Companies Act, 2013
  • Statutory filings with SEBI/ Stock Exchanges
/ Eight financial years
Legal
Records / Executed copies of contracts/ agreements entered by the Company / Five years beyond the life of the contract
.
  • Case file of all disputes with statutory Authorities.
  • Documents relating to Trade Marks
  • Orders, judgments of judicial authorities
/ Permanent
Production/ Purchase related records /
  • Production procedures, production data, system based records, MIS, yield, rejections etc.
  • Other production related records required to be maintained under any applicable law/statute etc.
  • Purchase orders, annual rate contracts, quotations and comparative quotation analysis etc.
  • Bill of entry/bill of lading, shipping bill, airway bill etc.
/ Eight financial years
HR /
  • Documents relating to individual personnel records, payroll, salary history, bonuses, performance reviews etc.
/ Four years from the date of cessation of employment.
Marketing and Sales records /
  • Sales & Marketing policies
  • Agreements with Dealers
  • Related MIS
/ Eight financial years