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JET KNITWEARS LIMITED

POLICY FOR PRESERVATION OF DOCUMENTS

 

LEGAL FRAMEWORK

 

In term of Regulation 9 of the “SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (the “Regulations”) require every listed Company to formulate a policy on Preservation on Documents which has to be approved by the Board of Directors.

In this context, the Board of Directors of Jet Knitwears Limited (“the Company) is required to formulate a policy for “Prevention of documents” to comply with the requirements of Regulation 9 of the “SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (the “Regulations”) with an objective of classifying various documents, records and registered for the purpose of maintenance and preservation.

The policy can be modified and or amended with the approval of the Board of Directors of Jet Knitwears Limited

Accordingly, the Board of Directors of Jet Knitwears Limited has adopted this Policy for Preservation on Documents in its meeting of the Board held on 24th March 2017

 

 

 

POLICY OBJECTIVES

 

 

 

The purpose of this policy is to ensure that all necessary documents of the Company are adequately protected and maintained/preserved as per the statutory and regulatory requirements. Further, documents of the Company which are no longer needed may be destroyed after following due process in this regard. This policy is also for the purpose of aiding employees of the Company in understanding their obligations in retaining and preserving the documents and records which are required to be maintained as per the applicable statutory and regulatory requirements.

POLICY OBJECTIVES

 

A. “Board of Directors” or “Board” Board of Directors or Board shall mean the Board of Directors of Jet Knitwears Limited, as constituted from time to time.

 

B. “Company” Company shall mean “Jet Knitwears Limited”

 

C. “Listing Regulations” Listing Regulations shall mean Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015(“Listing Regulations”).

 

D. “Act” means the Companies Act, 2013, Rules framed there under and any amendments thereto.

 

E. Documents: For the purpose of this Policy the term “Documents” shall mean statutory records, registers, returns, forms etc. required to be maintained and preserved by the Company in physical or electronic form under the Companies Act, 1956 / Companies Act,2013, Securities and Exchange Board of India Act, 1992, Securities Contracts (Regulation)Act, 1956 and the Depositories Act, 1996 and includes 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.


F. “Electronic Form” means any contemporaneous electronic device such as computer, laptop, compact disc, Floppy disc, 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.

 

G. “Maintenance” means keeping documents, either physically or in electronic form.

 

H. “Policy” or “This Policy” means, “Policy on Preservation of Documents”.

 

I. “Preservation” means to keep the documents preventing them from being altered, damaged or destroyed. “Register” means a register maintained under the Companies Act, 2013 or the SEBI Act.

 

K. “Regulations” means Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 and any amendments thereto.

 

 

 

POLICY FOR PRESERVATION OF DOCUMENTS

 

I. Documents and records of the Company required to be maintained under the SEBI Regulations shall be classified in two categories as below:


a) Documents whose preservation shall be permanent in nature shall be preserved permanently by the Company subject to the modifications, amendments, addition, deletion or any changes made therein from time to time;

 

b) Other Documents shall be preserved for a period of not less than eight (8) years after completion of the relevant transactions, subject to the modifications, amendments, addition, deletion or any changes made therein from time to time.

 

 

 

PRESERVATION PERIOD

 

The preservation period starts with the conclusion of financial year, in which the document has been formed or the last entry was made; the preservation period of agreements starts with the end of the financial year in which the agreement period expires.

For determining the preservation period, the records are categorized into following three categories:

 

 

Category & Description Period of Preservation
Records/documents with short reference value – i.e. Records, which are to be preserved for a short period for enquiry, evidence, verification, evaluation, etc. Less than 8 years
Records/documents required to be maintained as per statutory requirements under Companies Act 2013, SEBI (LODR) Regulations, other Laws, Rules and Regulations and having higher reference value – i.e. records having contractual/legal implications, which need to be preserved for a prescribed periods per statutory requirement; and records, which need to be, preserved for a particular period according to Company’s own reference needs. Documents to be preserved for a period of 8 to 12 years
Records which will have a permanent value for the
Company even after the expiry of legal preservation period.
Permanent
Records which are required for adducing evidence in
judicial or quasi judicial or other dispute redressal forum
Till the time the matters are finally disposed of.

 

 

Notwithstanding the general guidelines, care should be taken by the respective departments to ensure that records of special nature such as unsatisfied claims by or against the Company, suits pending in courts, tribunals, quasi judicial forum and other mediation and alternate dispute forum industrial disputes forum etc. are preserved according to specific needs and even beyond the prescribed period as may be decided by the board of directors.

Also, in the case of statutory records such as licenses, certificates, sanctions, approvals, etc. from Government/ Statutory Bodies, care should be taken to maintain and preserve the records in accordance with the specific guidelines/instructions, if any, by the issuing authority.

PRESERVATION LOCATION

 

The preservation location will be the concerned department and the registered office of the company. If the location is other than the concerned department or registered office, the same should be documented and kept in a file for reference purpose in the respective department. In case of critical documents which need to be preserved for very long periods or permanently, the same shall be preserved in fire proof or other such secure cabinets.

 

 

 

MODE OF PRESERVATION

 

Records/documents may be preserved either physically or in electronic form.

 

 

 

DISSEMINATION OF THE POLICY

 

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

 

 

 

DESTRUCTION OF RECORDS

 

The records/documents preserved shall be reviewed every year or according to need by the respective department and action taken to destroy those records which are due for disposal.

 

 

 

DESTRUCTION OF RECORDS

 

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, Chief Financial Officer, Company Secretary and Board of Directors of the company.