Policy on Document Retention 2015

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

5.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

Accounting and Finance records including Annual Financial statement
Insurance Records
Tax records
Contracts entered into by the Company including Marketing Contracts
Corporate Records including Certificate of Incorporation, Listing Agreement and other approvals from other statutory authorities
Legal Files and Records
Property Records
Payroll Records
Pension and retiral related Records
Personnel and HR Records
Programs & Service Records
Sponsorship Projects Records
Corporate Social Responsibility Records
Correspondence and Internal Memoranda
Electronic Documents including email retention and back up
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

6. Legal Files and Records

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