P a g e 1 | 10

POLICY ON RETENTION AND ARCHIVAL OF DOCUMENTS

P a g e 2 | 10

1. PREAMBLE: This Policy deals with the retention and archiving of the corporate records of Equitas Small Finance Bank Limited in accordance with the Banking Regulation Act 1949, and Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015.

1.2 OBJECTIVE:

The purpose of this Policy is to ensure that the all the necessary documents and records of the Bank are adequately protected and preserved as per the statutory requirements. This policy shall cover all business records of the Bank, including written, printed and recorded matter and electronic forms of records. The Chief Financial Officer and the Compliance Officer jointly would be responsible for overseeing the implementation of the Policy.

2. DEFINITIONS

a) Act: “Act” means the Companies Act, 2013 including any amendment or modification

thereof.

b) Board: Board means Board of Directors of the Bank

c) Chief Financial Officer: “Chief Financial Officer” means a person appointed as the Chief Financial Officer of the Bank under the Companies Act 2013 and SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015.

d) Bank: “Bank” means Equitas Small Finance Bank Limited.

e) Compliance Officer: “Compliance Officer” means the Company Secretary of the Bank

who is responsible to perform duties as required under Section 205 of the Companies Act 2013 and Regulation 6 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015.

f) Director: “Director” means a person as defined in Section 2(34) of the Companies Act,

2013 and presently appointed as a Director in the Bank.

g) Document: “Document” means all business records of the Bank in written, printed and recorded matter and electronic forms of records and includes summons, notice, requisition, order, declaration, form and register, whether issued, sent or kept in pursuance of the Companies Act 2013, SEBI Act 1992, Banking Regulation Act, 1949 or under any other law for the time being in force or otherwise, maintained on paper or in electronic form;

h) Employees: “Employees” shall mean the employees and office-bearers of the Bank,

including but not limited to Whole Time Directors.

i) Key Managerial Personnel: “Key Managerial Personnel” shall mean the officers of the

P a g e 3 | 10

Bank as defined in Section 2(51) of the Companies Act, 2013 and rules prescribed there under.

j) Regulations: “Regulations” shall mean SEBI (Listing Obligations and Disclosure

Requirements) Regulations, 2015

k) Secretarial Standards: “Secretarial Standards” means standards issued by the Institute of Company Secretaries of India under section 118 (10) of the Companies Act 2013.

l) Stock Exchange or Exchanges: “Stock Exchange or Exchanges” shall mean BSE

Limited and National Stock Exchange of India Limited

m) Any other term not defined herein shall have the same meaning as defined in the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015, Companies Act, 2013, Securities Contract Regulation Act or any other applicable law or regulations.

3. GOVERNING LAWS This Policy shall be governed by the Companies Act 2013, Banking Regulation Act, 1949, SEBI Act, Rules, Regulations, Circulars, Guidelines and Directions, Secretarial Standards, Labour Laws, Tax Laws and all other applicable laws for the time being in force.

4. CLASSIFICATION of DOCUMENTS Documents required to be maintained by the Bank shall be classified in the following categories:

a) Mandatory under governing laws

b) Non-Mandatory 5. GENERAL

i, Documents which are required to be mandatorily maintained and preserved by the Bank shall be preserved for such duration as may be specified by the relevant statute or regulation, as the case may be.

ii. Documents in respect of which no minimum maintenance timeline is stipulated under any of the laws shall be preserved in accordance with this policy.

iii. All the documents, records that are statutorily required to be hosted on the website of the Bank as per SEBI regulations or other applicable law, shall be hosted on the website for a minimum period of five (5) years or for such period as may be mentioned in the relevant law, whichever is longer.

iv. Any change in the governing laws affecting the change in period of preservation of documents shall prevail over this policy.

P a g e 4 | 10

6 PRESERVATION OF DOCUMENTS / RECORDS Subject to Clause 4 above, the Minimum Retention Requirement of the different categories of the Bank records is provided in the Retention Schedule which is disclosed by way of Annexure to this Policy. The Documents may be stored in soft copy also.

7. CUSTODY OF DOCUMENTS

All documents shall be under the custody of respective head of the departments as detailed below:

Sl. No.

Documents Authorised persons

1 Tax / Accounting Records / Financial Statements

CFO

2 Board and Committee Minutes / Statutory Registers

Company Secretary

3 Employment / Personnel Records / Lease Documents / Contracts

Head-HR

4 Customer Transaction documents & KYC documents

Head-Operations

5 Legal Documents Head-Legal 6 Intellectual Property Head- IT

8. DESTRUCTION OF DOCUMENTS The documents specified in the Annexure to this Policy, kept by the Bank, may be destroyed after the expiry of the minimum retention period specified in the Annexure and after review and approval by the aforementioned authorized persons. The documents not specified in the Annexure shall be destroyed after the period of five years after review and approval by Authorised persons. However, in the case of pending matters/ litigation/ disputes, the documents shall be preserved till the resolution of pending matter/ litigation/ dispute.

9. AMENDMENTS TO THE POLICY

The Board of Directors can amend this Policy, as and when deemed fit. In case of any amendment(s), clarification(s), circular(s) etc. issued by the relevant authorities, not being consistent with the provisions laid down under this Policy, then such amendment(s), clarification(s), circular(s) etc. shall prevail upon the provisions hereunder and this Policy shall stand amended accordingly from the effective date as laid down under such amendment(s), clarification(s), circular(s) etc.

P a g e 5 | 10

ANNEXURE- RETENTION SCHEDULE

SI No. Record Category

Record Type Retention Requirement

1 Board Meeting

& Committee

Meeting records

1. Minutes of the meeting of Board of Directors and

Committee constituted by the Board

Permanent

2 General Meeting records

1. Register & Index of members 2. Minutes

Permanent

3

Other

Secretarial

Records

1. Incorporation / Conversion/

Business commencement

Certificates. 2. Memorandum of Association &

Articles of Association. 3. Various Statutory Registers

pursuant to the Companies

Act, 1956 and/or Companies

Act, 2013.

4. Share Transfer, transmission

etc. correspondences with the

Registrar & Share Transfer

Agent.

Permanent

1. Non-statutory Registers

under the Companies Act,

1956 and/or Companies

Act, 2013

2. Attendance register of

Board of Directors

Meeting and General

Meetings

8 years from the

Financial Year in which

the latest entry is

made.

8 years from the

Financial Year in which

the latest entry is made

15 years after the 1. Copies of all annual returns

alongwith certificates &

documents required to be

annexed thereto.

8 years from the date

of filing with the

Registrar.

4 Insurance records

1. Insurance Policy Execution/Renewal Certificate

For Policies with no claim – 3 years from the

2. Insurance Claims under various Policies

lapse of the Policy

For Policies in respect of which claim is

preferred – 5 years from the date of settlement

of the claim.

P a g e 6 | 10

SI No. Record Category Record Type Minimum Retention Requirement

5 Contracts/

Agreements/

Purchase Orders

1. Renewal 2. Modification

3. Termination of :

Contracts/

8 years from termination of

Contract/ Agreement/

completion of purchase.

6 Loan

Agreements

with the

Clients

1. Agreement 2. Modification 3. Loans involving mortgage

of property 4. Title Deeds deposited by

borrowers

8 Years 8 Years

12 Years

Permanent till the customer takes it back.

6 SEBI & Stock

Exchange Records

1. Listing Agreement 2. Statutory Returns/

Reports etc. submitted from time to time

Permanent 8 years

7

RBI Records

1.License Certificate/ Renewal Certificate

Permanent

1. Client Records & transactions pursuant to the 'Know YourCustomer' (KYC)

Guidelines – Anti-Money Laundering Standards (AML) - 'Prevention of

2. Records pertaining to the identification of the customers and their address (e.g. copies of documents like passports, identity cards, driving licenses, PAN card, utility bills, etc.) obtained while opening the account and during the course of business relationship.

3. Records pertaining to complex, unusual, large transactions and all unusual patterns of transactions, which have no apparent economic or visible lawful purpose.

4. Statutory Returns/ Reports etc. submitted from time to time.

8 years after completion of the relevant transactions

8 years after the business relationship ended

8 years after the business relationship ended

8 years after the business relationship ended 8 years

P a g e 7 | 10

SI No.

Record Category

Record Type Minimum Retention Requirement

8 Misc Licenses

obtained from

Statutory Authorities

- Permanent

9 Property Records 1. Agreements/ Contracts

2. Documents

relating to

acquisition and

sale of Real

Property.

Permanent

10 Legal Correspondence

with Courts/ other

statutory bodies

regarding any

petition/ case/suit

etc.

5 years from the date of decree

11

Personnel Records

Official Personnel Files of Active Employees

To be retained during active employment

Official Personnel Files of inactive Employees

3 years from the date of termination of employment.

12

Labour Law records

1. Registration/ Renewal Certificate under various Acts relating to Labour laws.

2. Maintenance of various Registers under the various acts in force read with the Rules made thereunder, relating to Labour laws.

Permanent 3 years or such period as may be prescribed from time to time

13

Finance

1. Audited Financial Statements

2. Auditors Reports 3. Books of Accounts

& Vouchers

8 financial years following the

relevant Financial Year.

In cases where books and

vouchers are subjects of

enquiry, the relevant

documents shall be kept till

the expiry of 3 years after the

final resolution of the enquiry.

P a g e 8 | 10

14

Taxation

1.Registration/Amendment Certificate under various relevant provisions

Permanent

Preservation of specific books of accounts

8 financial years following the

relevant Financial Year.

In cases where books and

vouchers are subjects of

enquiry, the relevant

documents shall be kept till

the expiry of 3 years after the

final resolution of the enquiry.

15 Other documents

not covered herein above

Records pertaining to various other laws inforce

As required under various other

laws in force, from time to time.

P a g e 9 | 10

RETENTION SCHEDULE UNDER THE BANKING COMPANIES (PERIOD OF

PRESERVATION OF RECORDS) RULES, 1985

S.No

Record Category

Record Type Retention Requirement

1 Ledgers and Registers

(1) Cheque Book Registers (2) Delivery Order Registers (3) Demand Liability Registers (4) Demand Remittances Dispatched Registers (5) Demand Remittances Received Registers (6) Vault Registers

5 Years

2 Ledgers and Registers

(1) All Personal ledgers (2) Loans and Advance Registers or Ledgers (3) Call, Short or fixed Deposit Registers or Ledgers (4) F.D. Interest Registers (5) Draft T.T and Mail Transfer Registers (6) Remittance Registers (7) Bills Registers (8) Clearing Registers (9) Demand Loan Liability Registers (10) Draft and Mail Transfer Advices Dispatched Registers (11) Draft and Mail Transfer Advices Received Registers (12) Draft Payable Registers (13) Drawing Power Registers (14) Stock Registers of Goods Pledged (15) Stock and Share Registers (16) Government Securities Registers or Ledgers (17) Registers showing Collection of Dividends and Interest on Securities on behalf of Constituents (18) Registers or ledgers of Bank’s own Investments (19) Branch Ledgers (20) Overdrafts and Loan Registers (21) Safe Custody Registers (22) Equitable Mortgage Registers (23) Trust Registers (24) Clean Cash Books (25) Bank Cash Scrolls (26) Bank Transfer Scrolls (27) Remittance Schedules

8 Years

P a g e 10 | 10

(28) Paid Cheques (29) Paying in slips (30) Vouchers relating to DDs. TTs, MTs, Fixed Deposits, Call Deposits, cash credits and other deposit and loan accounts including vouchers relating to payment to nominees. (31) Account opening forms, inventories prepared in respect of articles in safe custody and safety locker and nomination forms. (32) Standing Instructions regarding Current Accounts. (33) Applications for TTs, DDs, MTs and other Remittances. (34) Applications for Overdrafts, Loans and Advances.