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1. Legal Framework

Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("Listing Regulations") imposes certain obligations and disclosure requirements on all listed entities. One of the common obligations for all listed entities pursuant to Regulation 9 is to formulate and put in place a policy for preservation of documents.

Accordingly, the Board of Directors of Atcom Technologies Limited ("the Company") has approved this Policy for Preservation of Documents.

2. Definitions

A. "Board"

Board shall mean the Board of Directors of Atcom Technologies Limited.

B. "Company"

Company shall mean "Atcom Technologies Limited".

C. "Documents"

Documents shall mean and include, but not limited to documents such as data, printed materials, books of accounts, forms, permits, registers, approvals, licenses, memorandums, contracts, minutes of statutory meetings, auditor’s reports, employee records, strategic documents, intellectual property documents, title deeds, court/tribunal orders, tax

returns/assessments, etc.

D. "Listing Regulations"

Listing Regulations shall mean Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("Listing Regulations").

3. Objectives of the Policy

The documents of the Company are important assets of the Company (“Documents”). Preservation of Documents is an important requirement under various laws. The objective of this Policy is to provide a binding framework for preservation of Documents maintained by the Company under various applicable laws including Listing Regulations.

The Policy provides that the Company shall maintain Documents which shall classify them in at least two following categories as follows:

a. Documents whose preservation shall be permanent in nature as given in Annexure 1 attached to this Policy.

b. Documents with preservation period of not less than eight (8) years after completion of the relevant transactions as given in Annexure 2 attached to this Policy.

Provided that the Company may keep the documents as specified above in electronic/digital mode.

4. Roles & Responsibilities

The respective Departmental Heads of the Company shall be responsible for maintenance, preservation and destroying of documents in respect of the areas of operations falling under the charge of each of them, in terms of this Policy.

If an employee has reasons to believe, or the Company informs the employee concerned, that Company Documents are relevant to litigation or potential litigation (i.e., a dispute that could result in litigation), then the employee must preserve those Documents until the Legal department determines that the Documents are no longer needed. This exception supersedes any previously or subsequently established destruction mechanism for those Documents. If an employee(s) believe that exception may apply or have any question regarding the possible applicability of that exception, he/she may consult the Head of Legal.

While minimum retention periods are suggested in regard to certain Documents, the retention of the Documents not included in the above schedule shall be determined by the Head of the Function/Department in compliance with any other policy/law that governs those Documents.

The physical documents preserved may be converted, whenever required or felt necessary, into electronic form to ensure ease of maintenance of records and efficient utilization of space. Where a Document is maintained both in physical and electronic form, the authenticity with reference to the physical form should be considered for every purpose.

5. Destruction Of Documents

After the expiry of the retention period, the preserved documents may be destroyed in such mode under any instructions approved by the department head(s). Destruction of documents as a normal administrative practice will also be followed for the records which are duplicate/unimportant/irrevelant.

The destruction and disposal of Documents shall be done in compliance with the applicable laws and the policy of the Company. All the Documents containing information of a confidential or sensitive nature on paper, card, or electronic media must be securely destroyed when they are no longer required.

This applies to both physical and electronic Documents.

6. Amendments

The Board may subject to the applicable laws amend any provision(s) or substitute any of the provision(s) with the new provision(s) or replace this policy entirely with a new policy.

Annexure 1

Documents whose preservation shall be permanent in nature

1. Registration/Incorporation Certificates

2. Constitution documents such as Memorandum and Articles of Association

3. Licenses & Statutory Approvals

4. Statutory Registers & Annual Return required under applicable laws

5. Audited financial statements

6. Minutes of General Meeting

7. Minutes of Board Meeting

8. Minutes of Statutory Committee Meetings

9.Various policies adopted by the Board of Directors.

10. Material Agreements/Contracts, which, even if terminated, may have an impact on business

11.Orders/judgments issued by Courts/statutory bodies and other background documents relevant for understanding such Orders

12. Investment documents/proofs including certificates, etc.

13. Title deeds and documents pertaining to immovable freehold and leasehold properties

14. Any other document as may be required to maintain permanently in terms of applicable law(s), maintained and preserved from time to time.

15. Documents relating to any property owned by the Company.

Annexure 2

Documents with preservation period of not less than eight (8) years

1. Books of Accounts

2. Notices and Agenda of the Board Meeting/Annual General Meeting/Extra Ordinary General Meeting and Attendance Registers of Board/committee meetings, declarations from Directors etc

3. Personnel Documents after retirement/resignation of the person concerned

4. Insurance Policies/ Claims under various policies after expiry or receipt of claim

5. Correspondences with Departments/shareholders

6. Non Statutory Registers/Documents

7. All Emails received from Internal and External Sources related to business issues

8. Documents as are required to be maintained under relevant laws relating to direct and indirect tax

9. Any other document as may be required to be maintained for eight years in terms of applicable law(s).

10. Tax Exemption, Subsidy documents and related correspondences

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