Archival Policy

OBJECTIVE

This Policy is intended to ensure compliance particularly with the Regulation 9 and Regulation 30(8) of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”) and to lay down the principles for the preservation of documents and records of the Company and outlines the methodology for the archival of material information/ material events that have been disclosed to the stock exchanges where securities of Anupam Rasayan India Limited (the “Company”) have been listed. In the event of any inconsistency between this Policy and the Listing Regulations, the Listing Regulations as amended from time to time, will prevail over this Policy.

DEFINITIONS

• 1. “Archival” means accumulation/storage of historical records on server/network or at a physical place.
  2. “Company” or “the Company” shall mean Anupam Rasayan India Limited.
  3. “Documents” or “Records” mean a piece of written, printed, or electronic matter that provides information or evidence or that serves as an official record of the Company.
  4. “Policy” or “this Policy” shall mean the Policy on Preservation & Archival of documents and records.
  5. “Preservation” or “preserve” means maintenance of documents and records (whether physical or electronic) in usable form and in good order, to prevent from being damaged or destroyed or tampered with.

PRESERVATION OF DOCUMENTS

I. The Company shall preserve all its records as per the requirements and provisions of the Companies Act, 2013 and the Rules made thereunder, the Secretarial Standards and the Listing Regulations and any other applicable law, rule, regulation or internal policy of the Company, in force.

II. Subject to (I) above, certain documents and records (as specified by the applicable law / regulation) shall be preserved for not less than 8 years after completion of the relevant transaction.

III. Other documents and records (as specified by the applicable law / rule /regulation) shall be preserved either:

• • • Permanently, or

    • For such other period as may be prescribed under the applicable law/ rule/regulation for the time being in force and thereafter the records can be destroyed.

ARCHIVAL

a) Archival Policy for submissions made to Stock Exchanges:

The Company shall also disclose on its website all such events or information which has been disclosed to stock exchange(s) under Regulation 30(8) of the Listing Regulations. Documents submitted to stock exchanges for dissemination to stakeholders will be retained on the website of the Company for a minimum period of five (5) years.

The Document may thereafter be shifted to the archive section of the website, where it shall be retained for period of one (1) year or such period as may be decided by the management of the Company from time to time.

b) Archival Policy for other information hosted on the website pursuant to applicable legislations:

All other documents/ information which are hosted on the website of the Company pursuant to any law/ regulations/ guidelines as may be applicable to the Company from time to time, shall be retained on the website for such minimum period of time as may be specified under such law/ regulation/ guidelines. The Documents may thereafter be shifted to the archive section of the website, where it shall be retained for such period as may be determined by the management of the Company.

c) Archival Policy for other information voluntarily hosted on the website:

All information/ documents hosted on the website of the Company voluntarily by the management, shall be retained on the website/ Archive section for such period of time as may deem fit at the absolute discretion of the management of the Company.

GENERAL

The documents and records may be archived in physical and/or electronic mode as the Board of Directors of the Company may deem fit. The documents and records archived in electronic form shall be backed up automatically on a periodic basis. This policy shall be hosted on website of the Company.

REVIEW AND AMENDMENTS

The Board may, subject to the applicable laws amend any provision(s) or substitute any of the provision(s) of this Policy with new provision(s) or replace this Policy in entirety.