Policy on Preservation of Documents
(as approved and adopted by the Board of directors in its meeting held on April 8, 2024)
Introduction
Tara Capital Partners India Private Limited (hereinafter referred as the “the Company”), being a listed entity, is mandated to frame a policy for preservation of documents in terms of Regulation 9 of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI LODR”). As per Regulation 9, the listed entity shall have a policy for preservation of documents, approved by its Board of Directors, classifying them in at least two categories i.e.
Documents whose preservation shall be permanent in nature; and
Documents with preservation period of not less than eight years after completion of the relevant transactions.
The Company may keep such documents in electronic mode. In accordance with the above Regulation 9, the Company has framed a Policy for Preservation of Documents (hereinafter referred as the “Policy”). The Policy is framed in line with the existing provisions of SEBI LODR. Any future changes in the SEBI LODR will ipso facto apply to this Policy.
Definition
“Act” means the Companies Act, 2013, Rules framed thereunder and any amendments thereto.
Board of Directors” or “Board” means the Board of Directors of TARA CAPITAL PARTNERS INDIA PRIVATE LIMITED, as constituted from time to time and as defined in Section 2(10) of the Companies Act, 2013.
“Company” means Tara Capital Partners India Private Limited.
“Document” includes summons, notices, requisitions, orders, declarations, forms and registers, whether issued, sent or kept in pursuance of this Act or under any other law for the time being in force or otherwise, maintained on paper or in electronic form as defined in Section 2 (36) of the Companies Act, 2013.
“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.
Preservation” Preservation” means to keep in good order and to prevent from being altered, damaged or destroyed.
“Policy” means Policy on Preservation of Documents.
“Year” means calendar year occurring after the completion of the relevant transaction.
Objectives of Policy
The main objective of this policy is to ensure that all the statutory documents are preserved in compliance with the Regulations and as per Policy framed in compliance with the Regulations and to ensure that the records no longer needed or which are of no value are discarded after following due process for the same.
The major objectives of the policy are:
To identify statutory records to be preserved.
To identify records to be maintained either for a period of eight years or permanently.
To decide the mode of preserving the documents, whether in physical form or in electronic form.
To decide the procedure to destroy the documents after eight years or other applicable period,
To help employees understanding their obligations in retaining and preserving the documents and records.
Scope of the Policy
The Policy shall apply to all documents which include records maintained in the form of books or stored on a computer or tapes or in any other electronic form.
The preservation of documents, as mandated under the policy, shall apply to all documents, irrespective of locations, includes all Company locations, offsite locations, computer storage or employee laptops.
Preservation of Documents
Documents whose preservation shall be permanent in nature
The following documents shall be maintained and preserved permanently by the Company. All modifications, amendments, additions, deletions to the said documents shall also be preserved permanently by the Company.
Corporate Records including Certificate of Incorporation, Common Seal, Minutes of Board, Committee and Shareholders’ Meetings, Register of Members and other Statutory Records.
Agenda Papers and notices pertaining to Annual General Meeting; Extraordinary General Meeting; Board Meeting and Committees thereof.
Statutory Register maintained under the Companies Act, 2013.
Notices, Orders and Communications received from various Government and Other Authorities.
Forms filed with the Registrar of Companies (RoC) as prescribed under the Companies Act, 2013.
Property records including purchase and sale deeds, licences, copyrights, patents & trademarks.
Any other document, certificates, statutory registers that may be required to be preserved permanently in terms the Companies Act, 2013 and/ or SEBI Regulations.
Documents to be preserved for not less than eight years after competion of the relevant transaction
The following documents shall be maintained and preserved for a term not less than eight years after completion of the relevant transactions. All modifications, amendments, additions, deletions to the said documents shall also be preserved for a term not less than eight years.
Books of Account, Bank Statements and vouchers.
Filings with Stock Exchanges, Registrar of Companies and other statutory authorities Filings with Stock Exchanges, Registrar of Companies and other statutory authorities.
All ballot papers received during the course of poll conducted in General Meetings.
Scrutinizer’s Report and other related papers pertaining to Annual General Meeting and Extraordinary General Meeting.
Payroll Records, Employee deduction authorizations, attendance records, employee medical records, leave records, Pension and retiral related Records, etc.
Corporate Social Responsibility Records.
Any other document, certificates, statutory registers which may be required to be maintained and preserved for not less than eight years after completion of the relevant transaction under the Companies Act, 2013 and/or SEBI Regulations.
Documents with preservation period as per specified laws
Notwithstanding anything contained in this policy, if a higher period of retention of documents is stated in any Act / Statute or prescribed by Statutory Authorities in the form of orders, direction or otherwise, such higher period becomes applicable.
General exception to preservation schedule
If there are reasons to believe, or the Company informs the employee concerned, that Company records are relevant for potential litigation (i.e., a dispute that could result in litigation), then the employee must preserve those records until the Legal or Respective Department determines that the records are no longer needed.
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.
