Preservation of Documents

 

POLICY ON PRESERVATION OF DOCUMENTS


1. Scope/ Legal Frame work:
A policy on preservation of Documents (defined below) would ensure safe keeping of the records
and safeguard the documents for getting man handled, while at the same time avoiding
superfluous inventory of Documents. The Company, therefore, formulates this policy, in
pursuance to Regulation 9 of the Securities Exchange Board of India (Listing Obligations and
Disclosure requirements) Regulations, 2015 on preservation of the Documents to aid the
employees in handling the documents efficiently. It not only covers the various aspects on
preservation of the Documents, but also the safe disposal/destruction of the Documents.

2. Definitions
i) “Act” means the Companies Act, 2013.
ii) Applicable Law” means any law rules, circulars, guidelines or standards issued by the Securities
Exchange Board of India, Ministry Corporate Affairs and The Institute of Company Secretaries of
India under which the preservation of the documents has been prescribed.
iii) “Authorised Person” means any person duly authorized by the Board
iv) Board” means the Board of directors of the Company or its Committee
v) “Company” means M/s. Genera Agri Corp Limited
vi) “Current Document(s)”means any Document, that still has an ongoing relevance with
reference to ongoing litigation, proceedings, complaint, dispute, contract or any like matter
vii) Document(s) “refers to papers ,notes, agreements, notices, advertisements, requisitions,
orders declarations, forms, correspondence, minutes, indices, registers and or any other record,
require d under or in order to comply with the requirements of any Applicable Law, whether
issued, se nt, 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 and does not include multiple or
identical copies
viii) Electronic Record(s)”means the electronic record as defined under clause (t) of subsection
(1) of section 2 of the Information Technology Act, 2000
ix) 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.
x) Maintenance” means keeping Documents, either physically or in Electronic Form.
xi) “Preservation”means to keep in good order and to prevent from being altered, damaged or
destroyed.
xii) “Regulations”means the Securities Exchange Board of India (Listing Obligation and Disclosure
Requirements) Regulations, 2015The words and phrases used in this Policy and not defined here shall derive their meaning from
the Applicable Law.

3. Coverage / Objective:
This Policy is intended to guide the Company and its officers on maintenance of any Documents,
their preservation and disposal. The purpose of this policy is to have a binding 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:
• Documents whose preservation shall be permanent in nature;
• Documents with preservation period of not less than eight (8) years after completion of the
relevant transactions.
The classification of the documents has been made in the Annexure which forms part of this
Policy. While prescribing different time periods for preservation of records, the following aspects
have been taken into account:
(a) Compliance with statutory and regulatory requirements.
(b) Requirements of SEBI/RBI/MCA officials to have access to certain records.
(c) Requirements of internal and external auditors to have access to certain records. The
documents or records not covered by this Policy shall be maintained by the Company for the time
period specified for their preservation under any statute or regulation, for the time being in force.
Provided further that the Company may keep the documents as specified above in electronic
mode.

4. Provision with regard to Preservation of Documents under various Laws: The Company from
time to time establishes retention or destruction of policies or documents or schedules for specific
categories of records in order to ensure legal compliance, and also to accomplish other objectives,
such as preserving intellectual property and cost management. Several categories of documents
that bear special consideration are identified below. While minimum retention periods are
suggested, the retention of the documents identified below and of documents not included in the
identified categories should be determined primarily by the application of the general guidelines
affecting document retention identified above, as well as any other pertinent factors.
(a) Tax Records: Tax records include, but may not be limited to, documents concerning payroll,
expenses, proof of deductions, business costs, accounting procedures, and other documents
concerning the Company's revenues. Tax records may be retained for at least Eight years from the
date of filing the applicable return.
(b) Employment Records/Personnel Record: Several Central & State statutes require the
Company to keep certain recruitment, employment and personnel information. The Company
should also keep personnel files that reflect performance reviews and any complaints brought
against the Company or individual employees under applicable Central & State statutes. The
Company should also keep all final memoranda and correspondence reflecting performancereviews and actions taken by or against personnel in the employee's personnel file. Employment
and personnel records should be retained for six years or till the cessation of the employee.
(c) Board and Board Committee Materials: Meeting minutes should be retained in perpetuity in
the Company's minute book. A clean copy of all Board and Board Committee materials should
be kept as long as they remain current or for 8 financial years, whichever is later.
(d) Press Releases/Public Filings: The Company should retain permanent copies of all press
releases and publicly filed documents under the theory that the Company should have its own
copy to test the accuracy of any document a member of the public can theoretically produce
against that Company. Press releases / public filings related documents should generally be
maintained for a period of eight years or till the completion of the case, whichever is later.
(e) Legal Files: Legal counsel should be consulted to determine the retention period of particular
documents, but legal documents should generally be maintained for a period of eight years or till
the completion of the case, whichever is later.
(f) Marketing and Sales Documents: The Company should keep final copies of marketing and sales
documents for the same period of time it keeps other corporate files, generally eight (8) years.
(g) Development/Intellectual Property and Trade Secrets: Development documents are often
subject to intellectual property protection in their final form (e.g., patents and copyrights). The
documents detailing the development process are often also of value to the Company and are
protected as a trade secret where the Company:
(i) Derives independent economic value from the secrecy of the information; and
(ii) The Company has taken affirmative steps to keep the information confidential. The Company
should keep all documents designated as containing trade secret information for at least the life
of the trade secret.
(h) Contracts: Final, execution copies of all contracts entered into by the Company should be
retained. The Company should retain copies of the final contracts for at least eight (8) years
beyond the life of the agreement, and longer in the case of publicly filed contracts.
(i) Electronic Mail: E-mail that needs to be saved should be either:
(i)Printed in hard copy and kept in the appropriate file; or
(ii)Downloaded to a computer file and kept electronically or on disk as a separate file.
Electronic documents will be retained as if they were paper documents. Therefore, the
electronic files should be maintained for the appropriate amount of time depending upon
the subject matter of the email and should be determined primarily by the application of
the general guidelines affecting document retention. If a user has sufficient reason to
keep an e-mail message, the message should be printed in hard copy and kept in theappropriate file or moved to an “archive” computer file folder. Backup and recovery
methods should be tested on a regular basis.

5. General: Notwithstanding anything contained in this Policy, the Company shall ensure
to comply 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. 6. Amendment: The
Board of Directors of the Company reserves the right to amend or modify this Policy in
whole or in part, as may be required, at any point of time.