Policy on Preservation of Documents.

1) BACKGROUND

Regulation 9 of Preservation of Documents Regulations, 2015 ("Regulations") require every listed company to formulate a policy on Preservation of Documents which has to be approved by the Board of Directors.

In this context, the following policy has been framed by the Board of Directors ("Board") of Nanta Tech Limited ("Company") at its meeting held on 03/08/2024 with the objective of classifying various documents, records and registers for the purpose of maintenance and preservation of the documents of the Company. The Policy shall also be an effective tool to the assigned by the Directors only.

2) OBJECTIVE OF THE POLICY

The objective of this Policy is to classify the documents, records and registers of the Company which are required

• to be preserved permanently; and
• to be preserved for a period of not less than 8 (eight) years after completion of the relevant transactions.

3) DEFINITIONS

4) PRESERVATION OF DOCUMENTS

The Company shall ensure all the documents maintained and maintained the requirements and provisions of the Companies Act, 2013 and the rules made there under, the secretarial standards, the listing regulations and any other law, rules, regulations as may be applicable to the Company from time to time. Documents to be maintained permanently.

The Company shall maintain the follows documents on a permanent basis:

• Documents filed with ROC for incorporation of the Company;
• Certificate of incorporation and memorandum and articles of association of business, if any, and common seal;
• The original signed and stamped memorandum of association and the articles of association of the Company;
• Minutes of general meetings, board meetings and various committee meetings;
• Register of members along with index;
• Foreign register of members, if any;
• Debenture holder's register including register of debentures(s) or register for any other securities issued by the Company;
• Register of loans, guarantees, security and acquisition made by the Company;
• Register of investments held in its own name by the Company, if any;
• Register of contracts with related party and contracts and bonds etc. in which directors are interested;
• Register of charges;
• Register of reviewed and duplicate share certificates;
• Register of directors and KMP;
• Register of significant beneficial owners;
• Board resolutions and minutes;
• PF, Bonus, Gratuity and other Statutory Registrations, Returns and Records;
• Licenses issued and permissions by Regulatory Authorities;
• Any other records / Documents which will have value for the company even after the expiry of the of legal explanations period.

Documents to be maintained for at least eight financial years:

• Documents related to Accounts (including details of all entries in such books of accounts);
• Disclosure of interest received from the Directors of the Company in the manner prescribed;
• Attendance registers, notices, notes on agenda and other related papers of general meetings, board meetings and various committee meetings;
• Changes to the memorandum of association and the articles of association, if any;
• Register of deposits accepted or renewed, if any;
• Tax records - Tax records (including, but not limited to documents concerning tax assessment, tax filings, proof of deductions, tax returns, appeal preferred against any claim made by the Company with respect to such matters), which are maintained for a period of 8 (eight) years after a final order has been received with respect to any matter which was;
• Insurance policies and related documents;
• Employment/personnel record in case of employees of the Company;
• Relevant circulars, guidelines and notices;
• Legal documents including but not limited to contracts, legal opinions pleadings, orders passed by any court or tribunal, judgments, interim orders, documents relating to cases pending in any Court or Tribunal or any other authority provided to give a decision on any matter, awards, documents relating to property matters;
• Documents relating to shares, transfer of shares and refund thereon;
• Documents on which the common seal of the Company has been affixed (other than those which are prescribed to be preserved for a longer period of time);
• If any discrepancy noticed, certificates, statutory registers which may be requested to be maintained and preserved in this office with good documentation.

5) MODE OF MAINTENANCE

The Company may maintain these records either in physical or electronic mode. The applicable provisions of the rules and regulations with regard to electronic maintenance of records shall be adhered to by the Company.

All the records shall be maintained as per the prescribed formats, if any, as obtained from time to time under various rules and regulations.

6) DISPOSAL AND DESTRUCTION OF RECORDS

After expiry of the statutory retention period, the retained documents may be destroyed. Destruction of documents as a normal administrative practice shall be followed for the records that are no longer required to be preserved.

This applies to both physical and electronic documents. The documents may be destroyed as follows:

• Burn or shred the paper records or
• Shred or otherwise render unreadable confidential paper records or
• Delete or destroy electronically stored data.

The Company shall maintain a register wherein it shall enter brief particulars of the documents destroyed and all entries made therein shall be authenticated by the Secretary or such other person as may be authorized by the Board for the purpose. Inspection of the register is restricted.

7) LIMITATION AND AMENDMENT

In the event of any conflict between the provisions of this Policy and the Companies Act, 2013 (and the rules framed thereunder) or the Regulations or any other statutory enactments, rules shall prevail over this Policy. Any subsequent amendment / modification in the Regulations, Companies Act, 2015 (and the rules framed thereunder) and/or applicable laws in this regard shall be deemed to be covered under this Policy.