Iceberg Cement (India) Limited, a top 1000 listed public company (the company), is a subsidiary of a global conglomerate of Iceberg Cement Plc. The group has a common policy of not declaring any dividend on its equity sh

With effect from 08/07/2016, according to Regulation 43A of SEBI (Listing Obligations and Disclosure Requirements) (Second Amendment) Regulations, 2015 (LODR), top 1000 listed companies shall formulate a dividend distribution policy which shall be disclosed on the website of the listed company and also a web-link shall be provided in its annual reports. The company has to disclose both on its website and in its annual reports its dividend distribution policy. Non-payment of dividend on equity shares as a matter of policy is also a dividend distribution policy. Thus, the contention of CFO is incorrect. The listed entities other than top 1000 listed entities based on market capitalization may disclose their dividend distribution policies on a voluntary basis on their websites and provide a web-link in their annual reports. Thus, in this case it is a voluntary disclosure requirement for the company.