The purpose of this document is to present a policy statement for DCM Financial Services Limited (Company) regarding preservation of its documents and archival of documents in the website in accordance with the provisions of the Companies Act, 2013 and Regulation 9 and 30(8) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("LODR").
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 gives 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.
The Company's physical and electronic documents shall be classified for the purpose of preservation as follows:
- Documents whose preservation shall be permanent in nature;
- Documents whose preservation period shall not be less than eight years after completion of the relevant transactions;
- Documents whose preservation shall be for a minimum period of three years after completion of the event.
The details of documents for the above three categories are given in the "Annexure".
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.
The Company Secretary or any other person, who is authorized by the Board of Director of the Company, is authorized to periodically review the policy and make such changes as considered necessary.
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 the Company or commencement of any litigation against the Company, any further disposal of documents connected with the matter shall be suspended until such time the investigation / litigation ends.
If as per any other law of land including Information Technology Act, Companies Act or SEBI Regulations, a physical or electronic record should be preserved for a longer period than what has been stipulated in this policy, then the document shall be preserved as per the applicable statutory stipulations.
- The Company shall disclose on its website the events or information of the Company disclosed to the stock exchanges (the "Disclosed information"), where the securities of the Company are listed, shall be disclosed on the website of the Company i.e. www.dfslonline.in (the "Website").
- Such disclosures shall be retained on the website of the Company for a minimum period of five years.
- At the end of the fifth year the information shall be archived and preserved for a further period of three years.
"Annexure"
Documents whose preservation shall be permanent in nature:
- Property records including purchase and sale deeds, licences, copyrights, patents & trademarks
- Corporate Records including Certificate of Incorporation, Common Seal, Minutes of Board, Committee and Shareholders' Meetings, Register of Members and other Statutory Records
- Personal files of all live employees.
- Any other record as may be decided by the Board of Directors of the Company from time to time.
- Intellectual Property Documents shall include, but shall not be limited to copyrights, Trademarks, Patents, and Industrial Design, Intellectual Property Rights documents that are owned by the Company shall be retained by the Company permanently.
Documents whose preservation shall be for at least eight years:
- Books of Accounts, Bank Statements and vouchers
- Filings with Stock Exchanges, Registrar of Companies and other statutory authorities.
- Payroll Records, Employee deduction authorizations, attendance records, employee medical records, leave records, Pension and retrial related Records, etc.
- Corporate Social Responsibility Records
- Sponsorship Projects Records
- Correspondence and Internal Memoranda
- Register of deposits for each branch and a consolidated
- Necessary records of transactions from the date of cessation of transaction between the NBFCs and the client.
- Any other record as may be decided by the Board of Directors of the Company from time to time.
Documents whose preservation shall be for a minimum period of three years after completion of the event:
- Tender Documents
- Lease Deeds and Contracts
- Legal files
- Insurance Records including policies and claims
- All e-mail correspondence, internal & external
- Documents under Secretarial Standards
- Proof of sending Notice of the meetings of the Board / Committee and General meetings and its delivery
- Proof of sending Agenda and Notes on Agenda and their delivery
- Proof of sending and delivery of the draft of the Resolution
- Proof of sending draft Minutes and its delivery
- Proof of sending signed Minutes and its delivery
- Any other record as may be decided by the Board of Directors of the Company from time to time.