POLICY FOR PRESERVATIONOF DOCUMENTS

1. PREFACE:

Regulation 9 of Securities and Exchange Board of India (Listing Obligations and Disclosure
Requirements) Regulations, 2015 [“ Listing Regulations”] requires every listed Company to have
a policy on Preservation of Documents / records maintained by the Company either in Physical
Mode or Electronic Mode.

2. SCOPE:

This policy shall govern the maintenance and preservation of documents as per applicable
statutory and regulatory requirements.

3. OBJECTIES OF THE 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 are of no value are discarded after
following the due process for discarding the same.

 The major objectives of the policy are:

 Identification of statutory registers and other records of the Company which are required to
be preserved.

 Identification and categorization of the statutory registers and other records to be
maintained either for eight years or permanently.

 Decide whether the statutory records and documents are to be preserved in physical form or
in electronic form.

 After completion of 8 years, for the statutory documents which are to be preserved for 8
years only may be disposed of as per the guidelines of the Policy or as decided by the Board
of Directors at that time.

 Aiding employees of the Company in understanding their obligations in retaining and
preserving the documents and records.

4. DEFINITIONS:

(a) “Act” means the Companies Act, 2013, Rules framed thereunder and any amendments thereto;

(b) “Regulations” means Securities and Exchange Board of India (Listing Obligations and
Disclosure Requirements) Regulations, 2015 and any amendments thereto;

(c) “Company”, “This Company”, “The Company”, “Company” wherever occur in the policy shall
mean “Gautam Exim Limited".

(d) “Current” means running matter or whatever is at present in course of passage.

(e) "Board of Director" or "Board",means the collective body of the Directors of the Company;

(f) “Policy” or “This Policy”means, “Policy on Preservation of Documents.”

(g) “Maintenance” means keeping Documents, either physically or in Electronic Form.

(h) “Preservation”means to keep in good order and to prevent from being altered, damaged or
destroyed.

i) “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.

5. GUIDELINES:

Regulation 9 of the Listing Regulations mandates that a listed entity shall have a policy for
preservation of documents, approved by its board of directors, classifying them in at least two
categories as follows‐

a) documents whose preservation shall be permanent in nature ;

b) documents with a preservation period of not less than eight years after completion of the
relevant transactions.

Provided that the listed entity may keep documents specified in clauses (a) and (b) in electronic
mode.

Accordingly, the company has classified the preservation of documents to be done in the
following manner:

a) documents that needs to be preserved and retained permanently;

b) documents that needs to be preserved and retained for a period of 8 years as specified under
the Companies Act, 2013 or SEBI (LODR) Regulations;

c) documents that need to be preserved and retained for such period as prescribed under any
statute or regulation as applicable to the Company.

d) where there is no such requirement as per applicable law, then for such period as the
document pertains to a matter which is “Current”. An indicative list of the Documents and the
time‐frame of their preservation is provided in Annexure‐ I

6. MODE OF PRESERVATION:

The Documents may be preserved in

a) Physical form; or

b) Electronic Form.

The official of the Company required to preserve the document shall be Authorized Person who
is generally expected to observe the compliance of statutory requirements as per applicable
law.

The preservation of documents should be such as to ensure that there is no tampering,
alteration, destruction or anything which endangers the content, authenticity, utility or
accessibility of the documents.

The preserved documents must be accessible at all reasonable times. Access may be controlled
by the concerned Authorized Person with preservation, so as to ensure integrity of the
Documents and prohibit unauthorized access.

7. DESTRUCTION OF DOCUMENTS:

The documents of the Company which are no longer required as per the time schedule
prescribed in the Annexure I may be destroyed. The concerned officer may direct employees in
charge from time to time to destroy the documents which are no longer required as per
Schedule given under Annexure I. The details of the documents destroyed by the Company
shall be recorded in the Register for Disposal of Records to be kept by Employees who are
disposing of the documents in the format prescribed at Annexure II. The entries in the register
shall be authenticated by the Authorized Person.

8. AMENDMENTS TO THE POLICY:

The Board can amend this Policy, as and when deemed fit. Any or all provisions of this Policy
would be subject to revision/ amendment in accordance with the Rules, Regulations,
Notifications etc. on the subject as may be issued by relevant statutory authorities, from time to
time. In case of any amendment(s), clarification(s), circular(s) etc. issued by the relevant
authorities are not consistent with the provisions laid down under this Policy, then such
amendment(s), clarification(s), circular(s) etc. shall prevail upon the provisions hereunder and
this Policy shall stand amended accordingly from the effective date as laid down under such
amendment(s), clarification(s), circular(s) etc.

ANNEXURE – I

A. PERMANENT PRESERVATION:

a. Common Seal, if any

b. Minutes books of Board, General Meetings and Committee Meetings

c. Statutory Registers

d. License and Permissions

e. Statutory Forms and disclosures except for routine compliance

f. Scrutinizers’ Reports

g. Register of Members

h. Index of Members

B. TEMPORARY PRESERVATION UPTO 8 YEARS:

a. Annual Returns

b. Board Agenda and supporting documents

c. Attendance Register

d. Office copies of Notice of General Meeting and related papers

e. Office copies of Notice of Board Meeting / Committee Meeting, Notes on Agenda and other related
papers

f. All notices pertaining to disclosure of interest of directors

g. Instrument creating a charge or modification

h. Books of accounts, financial statements etc.

i. Register of debenture holders or any other security holders

C. OTHERS: As per applicable law.

ANNEXURE – II

SPECIMEN FORMAT OF THE REGISTER FOR DESTRUCTION OF DOCUMENTS