Securities and Exchange Board of India has issued the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (hereinafter referred to as ‘the Regulations’) vide notification dated 2nd September 2015 coming into effect from 1st December 2015. The said Regulations are in substitute of compliance requirement of listing agreements entered into with recognized Stock Exchanges in India in respect to listing of equity shares, debts and other securities. The Regulations inter alia provides for preservation of documents by classifying them in atleast two categories as follows:
The said documents may be kept in electronic mode by a listed entity.
This Policy is called "Policy on preservation of documents"; or the "Policy"; and shall come into force from 1st December 2015.
This Policy has been approved by the Board in its meeting held on 28th October 2015 and the same shall come into effect from 1st December 2015 or from such other date as per the Regulations coming into effect and applicable.
"Board" or "Board of Directors" means Board of Directors of the Company.
"Company"; means Next Mediaworks Limited.
"Documents"; means all papers, records, files, books etc., and the like as required to be maintained under any law or regulation for the time being in force.
"Electronic Form"; with reference to information means any information generated, sent, received or stored in media, magnetic, optical, computer memory, micro film, computer generated micro fiche or similar device.
"Financial Year"; shall have the same meaning as assigned to it under Section 2(41) of the Companies Act, 2013.
"Key Managerial Personnel"; or "KMP"; shall have the same meaning as assigned to it under Section 2(51) of the Companies Act, 2013.
"Regulation"; or "Listing Regulation"; means the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended or re-enacted from time to time.
"SEBI"; means Securities and Exchange Board of India constituted under SEBI Act 1992 or similar authority.
The words importing the singular include the plural and vice versa and pronouns importing a gender include each of the masculine, feminine and neuter genders and shall be interpreted in the wide sense in spirit of this Policy.
Documents and Records of the Company required to be preserved under the Regulations shall be classified in the following two categories as below:
The above mentioned documents can be preserved in electronic or physical mode. Accordingly, the Company has classified the preservation of documents to be done in the following manner:
An indicative list of the Documents and the time-frame of their preservation is provided in Annexure- I
Any disclosure of events or information which have been submitted by the Company to the Stock Exchanges under Regulation 30(8) of the Regulations will be available on the website of the Company for a period of 5 years from the date of its disclosure and shall thereafter be archived from the website of the Company for a period of 3 years.
The official of the Company required to preserve the document shall be Authorised Person who is generally expected to observe the compliance of statutory requirements as per applicable law. The custody of the documents shall be with the Key Managerial Persons. Where the Authorised KMP tenders resignation or is transferred from one location of the Company to another, such Person shall hand over all the relevant Documents, lock and key, access control or password, or Company Disc, other storage devices or such other Documents and devices in his possession under the Policy. The Board may authorise such other person as it may deem fit as the Authorised Person.
The Board is authorized to make such alterations to this Policy as considered appropriate, subject, however, to the condition that such alterations shall be in consonance with the provisions of the Acts and Regulations.
The physical documents preserved may be converted, whenever required or felt necessary, into electronic form to ensure ease in maintenance of records and efficient utilization of space. This will be done after obtaining prior approval of the Board.
Where a Document is being maintained both in physical form and in Electronic form, the authenticity with reference to the physical form should be considered for every purpose.
This policy as amended from time to time shall be made available at the website of the Company. The right to interpret/amend/modify this Policy vests in the Board of Directors of the Company.
I. PERMANENT PRESERVATION:
II. TEMPORARY PRESERVATION UPTO 8 YEARS: