1. Preamble

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

Accordingly, the Board of Directors of Parag Milk Foods Limited (the “Company”) has formulated and adopted a policy for “Preservation of Documents and Archival of Documents ( ‟ (“Policy”) to comply with the requirements of Regulation 9 and Regulation 30(8) of the Listing Regulations ..

2. Objective

The main objective of this policy is to establish the framework needed for effective records management at Parag Milk Foods Limited. This policy deals with preservation of records. It therefore provides a framework, for the management of information consistent with the Regulations.

The Company has a substantial volume of its Secretarial and related Statutory Records and other documents. In order to efficiently conduct its business, the storage, retrieval and management of these information reserves is a significant issue. This holds true not only for physical documents but also documents that are dealt with digitally. A policy on preservation of such documents would guide employees and ensure in safe-keeping of the records and safeguard the documents, for both statutory compliance and internal purposes, while at the same time, avoiding superfluous inventory of documents by appropriately providing for their safe disposal/ destruction/ archival, as the case may be.

A good record keeping program is fundamental to the Company’s commitment to transparency and accountability. It enables the company for the smooth systematic functioning of the Company.

. 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 categorisation 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 or electronic mode

• 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

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

3. Definitions

4. “Act” means the Companies Act, 2013, Rules framed thereunder and any amendments thereto.

5. “Archival Policy” In addition to the secretarial records this policy will cover preservation of all events disclosed to the Stock Exchange for a period of 5 years and beyond.

6. “Authorised Person” means the functional head of the concerned department or any other person duly authorised by the Board or the Chief Financial Officer(CFO) or Company Secretary and Compliance Officer   (CS)

7. “ Regulations” means Securities and Exchanges Board of India (Listing Obligations and Disclosures Requirements) Regulations, 2015 and any amendments thereto.

8. “Company” “This Company” wherever occur in the policy shall mean ‘Parag Milk Foods Limited”.

9. “Document(s)” refers to documents, writings, papers, notes, agreements, deeds, contracts, summons, notices, advertisements, requisitions, orders, declarations, forms, correspondence, minutes, indices, registers and or any other record/s maintained by the Company, whether issued, sent, received or kept in pursuance of the Act or under any other law for the time being in force or otherwise, maintained on paper / print form or in Electronic Form and does not include multiple or identical copies.

10. ”Current Document(s)” means any Document, that still has an ongoing relevance 

with reference to any ongoing litigation, proceedings, complaint, dispute, contract or any 

like matter.

8. “Board of Director” or “Board” means the collective body of the Directors of the company.

9. “Policy” or “This Policy” means “Policy on Preservation and Archival of Documents”

10. “Maintenance” means keeping Documents, either physically or in Electronic Form.

11. “Preservation” means to keep in good order and to prevent form being altered, damaged or destroyed.

12. “Electronic Form” means any contemporaneous electronic device such as computer, laptop, compact disc, floppy 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.

4. Interpretation

Terms which have not been defined in this Policy shall have the same meaning assigned to them in the Companies act 2013, Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements), Regulations 2015.

5. Classification

Classification 5.1. The preservation of Documents shall be done in the following manner:

5.1.1 Category A: Documents which are to be Preserved permanently, either under Applicable Law or as determined by the Authorised Person subject to the modifications, amendments, addition, deletion or any changes made therein from time to time. Provided that all such modifications, amendments, addition or deletion in the documents shall also be preserved permanently by the Company. ( Listed in Annexure -1)

5.1.2 Category B: Where a Document is required to preserved for not less than eight years after the completion of the relevant transactions under Applicable Law, then for such period. Where a Document is required to be preserved for a period less than eight years as per Applicable Law, then for such period required by Applicable Law. ( Listed in Annexure -1)

5.1.3. Category C: Where there is no such requirement as per Applicable Law, then for such period as deemed fit by the Authorised Person.

5.1.4. With respect to disclosures made by the Company under Regulation 30(8) of the Regulations, such disclosures shall be hosted and accessible on the Company’s website for a minimum of five years.

5. 2. As a general principle, a Document should be permanently preserved, even beyond the requirements of Applicable Law, where the Document has a particular legal, historical or business significance and is of such nature that it should be available to the Company for the long term.

6. 2. Notwithstanding anything contained in this policy in case of dispute with tax authorities or government authorities, records and documents relating to dispute will be preserved till the settlement of dispute or eight years whichever is later.

7. 2. An indicative list of Documents, along with their classification and the time frame for their preservation, has been set out at Annexure 1.

8. 2. Each employee shall abide by the Policy. Each Authorised Person shall guide the employees in his department and ensure that they identify and classify Documents and take appropriate action with regard to their Preservation in accordance with this Policy.

9. 2. In case of any doubt as to the appropriate classification, the employee shall refer the same to the relevant Authorised Person. In case of ambiguity as to the classification, the Authorised Person may refer the matter to the CFO or CS for final decision of the classification of the relevant Document.

5.7. It is further clarified that Documents may be subject to periodic internal review and may accordingly be reclassified appropriately by the Authorised Person and/ or the CFO /CS.

5.8. As a general rule, a particular Document shall be considered to belong to a particular department if it originated in such department or if it comes under the scope of responsibility of the head of department of such department. In case a Document is part of two or more departments or if there is ambiguity as to the department to which a particular Document belongs, the matter may be referred to the CFO/CS, whose decision shall be final. Each Authorised Person shall be required to preserve the Document pertaining to its department. The CFO and CS shall be responsible for the overall compliance of the Policy. Each Authorised Person shall act under this Policy in consultation with the CFO/CS and shall perform all acts and extend all cooperation to the CFO/CS to enable him/ her to ensure compliance with the Policy and the Regulations.

5. Modes Of Preservation

6.1. The Documents may be preserved in:

6.1.1.Physical form or

6.1.2.Electronic form.

5. 2. 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, other than disposal of Documents as permitted under this Policy.

6.3. The preserved Documents must be accessible at all reasonable times. Access shall be controlled by the Authorised Persons, so as to ensure integrity of the Documents and prohibit unauthorized access.

7. Custody of the Documents

7.1Subject to the Applicable Law, the custody of the Documents shall be with the Authorised Person. 

Where the Authorised Person tenders resignation or is transferred from one location of the Company to another, such Person shall hand over all the relevant Documents, lock and key, access control or password,  or  Company  Disc,  other  storage  devices  or  such  other  Documents and devices in his possession   under the Policy to the new head of such department. Information of the cessation or transfer of the Authorised Person shall also be intimated to the CS and information technology department of the Company.

7.2TheAuthorised Person will co-ordinate with the IT Department of the Company to ensure Preservation of Documents in electronic form, as appropriate.

7.3. Notwithstanding anything contained elsewhere in the Policy but subject to the requirements of Applicable Law, the Authorised Person may permit other means of storage including usage of a third party service provider or a centralized system of storage for the Preservation of Documents.

 8. Destruction of Documents

8.1Destruction as a normal administrative practice usually occurs because the records are duplicated, 
unimportant or for short term use only. This applies to both Physical and Electronic Documents .

8.2The temporary Documents, excluding the Current Document(s) shall be destroyed after the relevant or 

prescribed period, by the Authorised Person in whose custody the Documents are stored, after the prior approval of the Board or any other authority as required under the Applicable Law pursuant to which the Documents 
have been preserved. The categories of Documents may be destroyed as normal administrative practice are 

listed in Annexure ­ 2

8.3 A register  of  the  Documents  disposed/destroyed  shall  also  be  maintained.  It  shall  state  the  brief Particulars of the Documents destroyed, date of disposal/destruction and the mode of destruction. 

8.4 The entries in the register shall be authenticated by the Authorised Person.

• The format of the register has to be in accordance with Annexure­-3.

9. Conversion of the form in which the Documents are preserved

9.1  The physical Documents preserved may be converted, whenever required or felt necessary, into electronic 

form to ensure ease in maintenance of records and efficient utilization of  space. 

9.2 This will be done after obtaining prior approval of the Authorised Person/CFO/CS or Board where necessary

10. Archiving of Documents which are hosted on the Company’s website

Recognizing the need to ensure the preservation and availability of the Documents of the Company after their required preservation period as set out under the Regulations and hereunder, for any legal, administrative, and historical purposes, the Company adopts the following archival policy in respect of Documents which are hosted on the website of the Company:-

10.1. All Documents generated, disclosed or received by the Company, on its website are the properties of the Company and constitute archival material. Archival material of the Company shall not be destroyed without the approval of the Authorised Person. Provided that this shall not apply in case of an accidental deletion, or deletion due to any system flaw, virus, or any other deletion, inaccessibility or loss due to any reason other than deliberate and determinate deletion.

10.2. Archiving of the Documents to be submitted to the stock exchange, in terms of the Regulations, shall be done after the lapse of the preservation period of 5 years, as per the archival policy.

10.3. For the Documents to be submitted to the stock exchange to comply with disclosure norms as required by any other Applicable Law, the Documents are to be archived after the lapse of the specified/required time period.

10.4. Material so selected for Preservation shall be sent to the Company archives.

10.5. The Authorised Person will be responsible for deciding how long archival material is to be retained after the minimum period of five years, if the law or this Policy does not specify any time period.

11. Authority To Make Alterations To The Policy

The Board shall have power to amend any of the provisions of this Policy, substitute any of the provisions with a new provision or replace this policy entirely with a new Policy according to subsequent modification(s) / amendment(s) to Regulations..

Placement Of The Code On Website

Pursuant to SEBI (LODR) Regulations, 2015, this ‘Policy’ shall be posted on the website of the Company.