The Chairman of ABC Limited, a listed company, seeks your opinion for framing a policy for preservation of documents to avoid stringent penal provisions for non-compliance of the provisions of the Companies Act, 2013 and

To, The Chairman ABC Limited Re: Classification of documents for period of preservation under SEBI (LODR) Regulations, 2015 Dear Sir, The legal requirements of preservation of documents in accordance with the provisions of the Companies Act, 2013 and Regulation 9 of the SEBI (LODR) Regulations, 2015 are as under: A. 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 Chief Executive Officer of the Company from time to time. B. Documents whose preservation period shall not be less than eight years after completion of the relevant transactions: Books of Account, Bank Statements and vouchers Filings with Stock Exchanges, Registrar of Companies and other statutory authorities. Payroll Records, Employee deduction authorisations, attendance records, employee medical records, leave records, Pension and retrial related Records, etc. Corporate Social Responsibility Records Sponsorship Projects Records Correspondence and Internal Memoranda Any other record as may be decided by the Chief Executive Officer of the Company from time to time. C. 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 6.1 Proof of sending Notice of the meetings of the Board / Committee and General meetings and its delivery 6.2 Proof of sending Agenda and Notes on Agenda and their delivery 6.3 Proof of sending and delivery of the draft of the Resolution 6.4 Proof of sending draft Minutes and its delivery 6.5 Proof of sending signed Minutes and its delivery Any other record as may be decided by the Chief Executive Officer of the Company from time to time.