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Policy on Preservation of Documents and archival of documents in its website
  1. Purpose and Scope
    The purpose of this documents to present a high level policy statement for ESAB India Limited (ESAB) regarding preservation of its documents in accordance with the provisions of the Companies Act, 2013 and in accordance with the provisions of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“LODR”)

    The policy is intended to define ESAB’s preservation of documents responsibilities and to provide guidance to the executives and staff working in ESAB in making decisions and undertaking other activities that may have an impact on the operations of the Company. It also frame the guidelines for fundamental accountability of ESAB to retain and preserve its documents as the basis for communication with a range of external stakeholders

    The policy is framed for the purpose of systematic identification, categorization, maintenance, review, retention and destruction of documents received or created in the course of business. The policy would contain guidelines on how to identify documents that need to be maintained, how long certain documents should be retained, how and when those documents should be disposed of, if no longer needed and how the documents should be accessed and retrieved when they are needed

    This policy has been adopted and approved by the Board of Directors at its meeting held on 5 November, 2015

  2. Statutory Mandate
    The policy on preservation of documents and archival is mandated by the provisions of regulation 9 of Chapter III of LODR, 2015. Under this regulation, the Company has a strategic objective of ensuring that significant documents are safeguarded and preserved to ensure its longevity of priority documents including its electronic resources

  3. Classification of Documents to be preserved / retained
    Based on the recommendation of the management of the Company, the Board of Directors have classified the following documents to be retained and preserved for posterity
    • Documents that need to be preserved / retained permanently – Doc 1
    • Documents that may be preserved / retained for a period of 8 years as specified under the Companies Act, 2013 or LODR – Doc 2
    • Documents to be preserved electronically and archived when necessary – Doc 3
    • Documents that may be required by judicial proceedings and which may be destroyed after closure of the legal case – Doc 4
    • Emails of all employees in the grade M3 (E6) and above for a period of 3 years – Doc 5
    • Documents like budget papers, bank guarantees etc., which may be retained for less than 8 years – Doc 6

  4. Principle of Responsibility of Employees for Preservation of Documents
    All the Employees in the permanent rolls of the Company are responsible for taking into account the potential impacts on preservation of the documents in their work area and their decision to retain/preserve or destroy documents pertaining to their area. Such policy bestowing responsibility on the Company’s employees would immensely help company’s litigation preparedness tool helping the Company’s and Outside legal counsel to track down documents to handle the legal cases

  5. Periodical Review of the Policy by Top Management
    The Policy should be flexible and easy to understand and comply with by all levels of employees. The policy should be reviewed periodically by the Top Management and amendments effected to subject to approval of the Board if and when practical difficulties are encountered. The Top management may also review the policy on document retention to comply with any local, state, central legislations that may be promulgated from time to time

  6. Administration
    The Record Retention Schedule approved by the Board of Directors for initial maintenance, retention and disposal schedule for physical records is as given in the annexure

  7. Suspension of Record Disposal in the event of Litigation or Claims
    In case the Company is served with any notice for request of documents or any employee becomes aware of a governmental investigation or audit concerning ESAB India or commencement of any litigation against the Company, such employee shall inform the Top Management and any further disposal of documents shall be suspended until such time as the Top Management with the due advice from the legal counsel determine otherwise. The Top Management in such case shall inform all the employee by mail under “Userlist” of the need to retain the documents and suspension of disposal of the same

  8. Disaster Preparedness
    ESAB India maintains a business continuity plan (BCP) designed to ensure safety of staff as well as members of the general public, safeguard the documents and records and to enable a return to normal operating with minimal disruption. Detailed procedures for responding to an incident are part of the BCP

    In the event of major incident, the first priority is the safety of the people, followed by immediate action to rescue or prevent further damage to the records. Depending on the immediate threat, emergency response and recovery actions will take precedence over all other Company activities

    The Company has made appropriate provision for the backup of its digital collections, including the provision of offsite security copies. The backup copies are actively maintained to ensure their continued viability. The Company’s BCP ensures that the digital collections and technical infrastructure required to manage and access them can be restored in the event of an emergency

  9. Board’s Approval
    This policy was approved by the Board of Directors at its meeting held on 5 November, 2015

Type of Record
  1. Accounting and Finance records including Annual Financial statement
  2. Insurance Records
  3. Tax records
  4. Contracts entered into by the Company including Marketing Contracts
  5. Corporate Records including Certificate of Incorporation, Listing Agreement and other approvals from other statutory authorities
  6. Legal Files and Records
  7. Property Records
  8. Payroll Records
  9. Pension and retiral related Records
  10. Personnel and HR Records
  11. Programs & Service Records
  12. Sponsorship Projects Records
  13. Corporate Social Responsibility Records
  14. Correspondence and Internal Memoranda
  15. Electronic Documents including email retention and back up
  16. Miscellaneous Records
1. Accounting and Finance records including Annual Financial statement

Record Type

Retention Period

Document Type

Accounts Payable ledgers and schedules 8 Years Doc -2
Accounts Receivable ledgers and schedules 8 Years Doc – 2
Annual Audit Reports and Financial Statements, Tax and Vat Audit Permanent Doc – 1
Annual Audit Records, including work papers and other documents that related to the audit 8 years after completion of audit Doc - 2
Annual Plans and Budgets 3 years after the budget year is closed Doc – 6
Bank Statement and Cancelled Cheques 8 years Doc – 2
Employee Expense Reports 8 years Doc – 2
General Ledger Permanent Doc – 1
Interim Financial Statements 8 years Doc – 2
Notes Receivable ledgers and schedules 8 years Doc – 2
Investment Records Permanent Doc – 1
Security deposit receipt copies 3 years after termination of the contract Doc – 6
Fixed Asset Register with supporting Purchase Orders and Bills for fixed assets addition Permanent Doc – 1
Cost records 8 years Doc – 2
Payroll extract, salary advice and payroll JVs 8 years Doc – 2
Payroll TDS, PF, ESI return and challan applicable on payroll Permanent Doc – 1
Treasury documents – Credit approvals from bank Permanent Doc – 1
Bank Account passbook or statement, Bank Reconciliation Statement and LC Documents 8 years Doc – 2
Bank Guarantees Till the expiry of the claim period Doc – 6
Tax Litigation documents Permanent Doc – 1
Bill of entries Permanent Doc – 1
 
2. Insurance Records

Record Type

Retention Period

Document Type

Annual Loss Summaries 8 Years Doc -2
Audits and Adjustments 8 Years Doc – 2
Claim Files (Including correspondence, medical records, injury documentation, etc. Permanent Doc – 1
Group Insurance Plans – Active Employees 8 years Doc - 2
Group Insurance Plans - Retireees Permanent Doc – 1
Insurance Policies for the Company Permanent Doc – 1
Journal Entry Support Data 8 years Doc – 2
Releases and Settlements Permanent Doc – 1
 
3. Tax records

Record Type

Retention Period

Document Type

Tax-Exemption Documents and related correspondence Permanent Doc -1
Excise Tax records Permanent Doc – 1
Payroll Tax records 8 years Doc – 2
Tax Bills, Receipts, Statements 8 years Doc – 2
Tax Returns – Income, Franchise, Property Permanent Doc – 1
Tax workpaper packages - Originals 8 years Doc – 2
Sales Tax Records 8 years Doc – 2
Annual Information Returns – State and Central Permanent Doc – 1
Service Tax Records 8 years Doc – 1
Responsibility : FINANCE AND ACCOUNTS DEPARTMENT
4. Contracts entered into by the Company including Marketing Records

Record Type

Retention Period

Document Type

Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documents 8 years Doc – 2
Responsibility : LEGAL AND MARKETING DEPARTMENT
5. Corporate Records including Certificate of Incorporation, Listing Agreement and other approvals from other statutory authorities.

Record Type

Retention Period

Document Type

Corporate Records (certificate of incorporation, commencement of business, listing agreement, common seal, minutes book of board and committees thereof, annual reports originals, etc.) Permanent Doc – 1
Licence and Permits, Industrial entrepreneurial Memorandum, and other statutory approvals Permanent Doc – 1
ROC Filings and Stock Exchange filings in physical and Electronic form 5 years from the date of filing Doc - 6
Responsibility : LEGAL AND SECRETARIAL DEPARTMENT

Record Type

Retention Period

Document Type

Legal Memoranda and Opinions 3 years after the closure of the matter Doc – 4
Litigation files 1 year after expiration of disposal of the case Doc – 4
Court Orders Permanent Doc – 1
Responsibility : LEGAL AND SECRETARIAL DEPARTMENT
7. Property Records

Record Type

Retention Period

Document Type

Correspondence, Property Deeds, Assessments, Licenses, Rights of Way Permanent Doc – 1
Original Purchase / Sale Deeds Permanent Doc – 1
Original Lease Agreements 3 years after expiration of the lease Doc – 6
Responsibility : LEGAL AND SECRETARIAL DEPARTMENT
8. Payroll Records

Record Type

Retention Period

Document Type

Employee Deduction Authorization 3 years after termination of service of employment Doc – 6
Payroll Deductions 3 years after termination of service of employment Doc – 6
Labour Distribution Cost Records including details regarding gratuity and retiral disbursements 3 years after termination of service of employment Doc – 6
Payroll Registers (Gross and Net) 3 years after termination of service of employment Doc – 6
Time Cards / Sheets 2 years Doc – 6
Unclaimed Wage Records 3 years Doc – 6
Leave Records 2 years after the relevant period Doc – 6
Responsibility : HUMAN RESOURCES DEPARTMENT
9. Pension and retiral related Records

Record Type

Retention Period

Document Type

Retirement and Pension Records Permanent Doc – 1
Responsibility : HUMAN RESOURCES DEPARTMENT
10. Personnel and HR Records

Record Type

Retention Period

Document Type of transaction

Personnel Files of individual employees Permanent Doc – 1
Commission / Bonuses / Incentives / Awards 8 years Doc – 2
Employee Earnings Records 3 years after termination of service of employment Doc – 6
Employee Handbook & Induction Manual Permanent Doc – 1
Employee Medical Records 3 years after termination of service of employment Doc – 6
Attendance records, application forms, job or promotion records, performance evaluations, termination papers, test results, training and qualification records, enquiry related papers 3 years after termination of service of employment Doc – 6
Employment Contracts - Individual 3 years after termination of service of employment Doc – 6
Correspondence with Employment Agencies and Advertisements for job openings 3 years Doc – 6
Job Description 3 years after superseding the earlier document Doc – 6
Responsibility : HUMAN RESOURCES DEPARTMENT
11. Programs & Service Records

Record Type

Retention Period

Document Type

Attendance Records 3 years Doc – 6
Program statistics, etc. 3 years Doc – 6
Research & Publications Permanent Doc – 1
Responsibility : HUMAN RESOURCES DEPARTMENT
12. Sponsorship Projects Records

Record Type

Retention Period

Document Type

Sponsorship agreements Permanent Doc – 1
Responsibility : HUMAN RESOURCES DEPARTMENT
13. Corporate Social Responsibility Records

Record Type

Retention Period

Document Type

Records on CSR Projects(including amount budgeted, spent and balance if any) projects undertaken and progress thereon Permanent Doc – 1
Responsibility : HUMAN RESOURCES DEPARTMENT
14. Correspondence and Internal Memoranda
General Principle : Most correspondence and internal memoranda should be retained for the same period as the document they pertain to or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract
  1. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within two years
  2. Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently
Responsibility : RESPECTIVE DEPARTMENT
15. Electronic Documents including email retention and back up
  1. Electronic Mail : Not all email needs to be retained, depending on the subject matters
    • All e-mail – from internal and external sources to be deleted after 24 months
    • Staff will strive to keep all but an insignificant minority of their email related to business issues
    • Central I.T team would archive email for six months after the staff has deleted it after which time the email will be permanently deleted
    • Staff will not store or transfer the Company related emails on non-work related computers except as necessary or appropriate with due approvals from the Central IT team and the respective Managers
    • Staff will take care not to send confidential / proprietary information to outside sources
    • Any e-mail that the staff deemed vital to the performance of their job should be copied to the staff’s specific folder and/or printed and stored in the employee's workplace

  2. Document Type : Doc 5

  3. Electronic Documents including PDF files
    • PDF documents – Can be a maximum period of 8 years. But the said document may be destroyed depending upon the completion of the job or its use coming to an end
    • Text/ Formatted files : All word / excel / Power point files may be deleted once every year depending on the importance or lack of it

  4. Document Type : Doc – 3

  5. Web page files
    • May be retained for a period of 5 years as specified in SEBI’s LODR Regulations, 2015
    • May be archived by the I.T. department with the support of the service provider for a period of 3 years after the initial period of five years of live page

  6. Document Type : Doc – 3
Responsibility : INFORMATION TECHNOLOGY DEPARTMENT
16. Miscellaneous Records

Record Type

Retention Period

Document Type

Consultant Reports 3 years Doc – 6
Policy and procedures manuals – Original Current version with revision history Doc – 6
Policies and procedures manuals - Copies Retain current version only Doc – 6
Dealership agreements Current version with revision history Doc – 6
Annual Reports Permanent Doc -1
Export Documentation – FIRC details Permanent Doc – 1
Import Documentation Permanent Doc -1
Responsibility : RESPECTIVE DEPARTMENT