Preservation of Documents and archival of documents

Plan on Preservation of Documents and archival of documents in its website

1. Purpose and Scope :

The purpose of this document to present a high level plan for M/s. Alfa Transformers Ltd 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 Plan is intended to define M/s. Alfa Transformers Ltd’s preservation of documents responsibilities and to provide guidance to the executives and staff working in M/s. Alfa Transformers Ltd in making decisions and undertaking other activities that may have an impact on the operations of the Company. It also frames the guidelines for fundamental accountability of M/s. Alfa Transformers Ltd to retain and preserve its documents as the basis for communication with a range of external stakeholders.

The plan 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 plan 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 plan has been adopted and approved by the Board of Directors at its meeting held on 11th February, 2016.

2. Statutory Mandate:

The plan 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. 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 plan 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.

4. Periodical Review of the Plan by Top Management:

The Plan should be flexible and easy to understand and comply with by all levels of employees. The plan 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 plan on document retention to comply with any local, state, central legislation that may be promulgated from time to time.

5. 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.

6. This plan was approved by the Board of Directors at its meeting held on 11th February, 2016.

APPENDIX

1. Accounting and Finance records including Annual Financial statement

Record Type	Retention Period
Accounts Payable ledgers and schedules	8 Years
Accounts Receivable ledgers and schedules	8 Years
Annual Audit Reports and Financial Statements	Permanent
Annual Audit Records, including work papers and other documents that related to the audit	8 years after completion of audit
Bank Statement and Cancelled Cheques	8 years
Employee Expense Reports	8 years
General Ledger	Permanent
Interim Financial Statements	8 years
Notes Receivable ledgers and schedules	8 years
Investment Records	Permanent
Security deposit receipt copies	3 years after termination of the contract

2. Insurance Records

Record Type	Retention Period
Annual Loss Summaries	8 Years
Audits and Adjustments	8 Years
Claim Files (Including correspondence, medical records, injury documentation, etc.	Permanent
Group Insurance Plans – Active Employees	8 years
Group Insurance Plans - Retirees	Permanent
Insurance Policies for the Company	Permanent
Journal Entry Support Data	8 years
Releases and Settlements	Permanent

3. Tax records

Record Type	Retention Period
Tax-Exemption Documents and related correspondence	Permanent
Excise Tax records	Permanent
Payroll Tax records	8 years
Tax Bills, Receipts, Statements	8 years
Tax Returns – Income, Franchise, Property	Permanent
Tax work paper packages - Originals	8 years
Sales Tax Records	8 years
Annual Information Returns – State and Central	Permanent
Service Tax Records	8 years

Responsibility: FINANCE AND ACCOUNTS DEPARTMENT

4. Corporate Records including Certificate of Incorporation, Listing Agreement and other approvals from other statutory authorities.

Record Type	Retention Period
Corporate Records (certificate of incorporation, commencement of business, listing agreement, common seal, minutes book of board and committees thereof, annual reports originals, etc.)	Permanent
Licence and Permits, Industrial entrepreneurial Memorandum, and other statutory approvals	Permanent
ROC Filings and Stock Exchange filings in physical and Electronic form	5 years from the date of filing

Responsibility: SECRETARIAL DEPARTMENT

5. Legal Files and Records

Record Type	Retention Period
Legal Memoranda and Opinions	3 years after the closure of the matter
Litigation files	1 year after expiration of disposal of the case
Court Orders	Permanent

Responsibility: SECRETARIAL DEPARTMENT

6. Payroll Records

Record Type	Retention Period
Employee Deduction Authorization	3 years after termination of service of employment
Payroll Deductions	3 years after termination of service of employment
Labour Distribution Cost Records including details regarding gratuity and retiral disbursements	3 years after termination of service of employment
Payroll Registers (Gross and Net)	3 years after termination of service of employment
Time Cards / Sheets	2 years
Unclaimed Wage Records	3 years
Leave Records	2 years after the relevant period