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Policy for Determination of Materiality of Events

[Framed under Regulation 30 (4) (ii) of SEBI (Listing Obligations & Disclosure Requirements) Regulations, 2015]

  1. Preface:

    The Board of Directors of The Sivanandha Steels Limited, (the "Company") has formulated this Policy to determine materiality based on the criteria specified herein and to authorize one or more Key Managerial Personnel for determining materiality of an event or information and to make disclosures as per the Regulations 30(4)(ii) and 30(5) of Securities and Exchange Board of India (Listing Obligations & Disclosure Requirements) Regulations, 2015, with effect from 1st December 2015.

  2. Definitions:

    In this Policy, unless the context otherwise requires:-

    "Company" means " Sivanandha Steels Limited".

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

    Words and expressions used in this code but not defined shall have the meaning as given in the Regulations.

    Any subsequent modification and / or amendments brought about by SEBI in the Regulations shall automatically apply to this Policy.

  3. Criteria for determining materiality of events /informations:
    1. The omission of an event or information, which is likely to result in discontinuity or alteration of event or information already available publicly; or
    2. The omission of an event or information is likely to result in significant market reaction if the said omission came to light at a later date;
    3. In case where the criteria specified in sub-clauses (a) and (b) are not applicable, an event / information may be treated as being material if in the opinion of the Board of Directors of the Company, the event / information is considered material.
  4. Disclosure of Events/Informations:
    1. Events or information which may have a material effect on the company and / or as specified by the Board of Directors of the Company from time to time and/ or such other events or information prescribed by the SEBI or any other authority for disclosure, from time to time shall be disclosed by the company.
    2. The Events as specified in Para A of Part A of Schedule III of the Regulations mentioned in Annexure I to this Policy shall be disclosed without any application of the guidelines for determining materiality as mentioned in clause 3 of this policy.
    3. The events as specified in Para B of Part A of Schedule III of the Regulations mentioned in Annexure - II to this Policy shall be disclosed upon application of the guidelines for determining materiality as mentioned in clause 3 of this policy.
    4. Any other events or information as per Para C of Part A of Schedule III of the Regulations viz. major development that is likely to affect business, e.g. emergence of new technologies, expiry of patents, any change of accounting policy that may have a significant impact on the accounts, etc. and brief details thereof and any other information which is exclusively known to the company which may be necessary to enable the holders of securities of the company to appraise its position and to avoid the establishment of a false market in such securities, shall be disclosed by the company.
    5. As per Para D of Part A of Schedule III of the Regulations, without prejudice to the generality of Clauses 4(b), 4(c) and 4(d) of this policy, the Company may make disclosures of events / information as specified by the Board from time to time.
  5. Time Limit for Disclosure:

    The Company shall first disclose to the Stock Exchange(s) of all events / information specified in Clause 4(b) of this Policy, as soon as reasonably possible but not later than twenty four (24) hours from the occurrence of the event or information and / or on becoming aware of it. However the outcome of Meetings of the Board of Directors to consider the subjects specified in Serial No. 4 of Annexure - I to this policy to be disclosed to the Stock Exchange(s) within 30 minutes of the closure of the Meeting. Provided that in case the disclosure is made after twenty four (24) hours of such occurrence of the event / information, the company shall along with such disclosures provide explanation for delay. The events / information specified in clause 4(c) and 4(d) of this policy shall be disclosed to the Stock Exchange(s) as soon as reasonably possible.

  6. Website:

    All the above disclosures which have been disclosed to stock exchange(s) under the Regulations shall be hosted on the website of the Company for a period of five years and thereafter as per the Company's Policy on Preservation and Archival of Documents.

  7. Authority to key managerial personnel:

    The Board of Directors of the Company authorize Sri.Ramakrishnan Rajan , Compliance Officer of the Company for the purpose of determining materiality of an event or information in accordance with the principles enunciated in Chapter II, Regulation 4(1) of the said Regulations, in consultation with Sri.P.Venkatesan, Chairman and Managing Director of the Company, and for the purpose of making disclosures to the Stock Exchange. The contact details shall also be disclosed to the stock exchange(s) and the Company's website.

    Contact Details:

    Name :R.Ramakrishnan Rajan

    Contact Number : 044-42031951/2625-1187

    Email ID : ram@sivanandha.com

    Address: Plot No.18,19 & 20,Ambit Park Road,Ambattur Industrial Estate, Chennai 600058

  8. Amendment

    The Board of Directors of the Company reserves the right to amend or modify this policy or in whole or in part, as may be required, at any point of time.

  9. Policy Review & Disclosure:

    In case of any changes in the Regulations which make any of the provisions in the policy inconsistent, the provisions of the Regulations would prevail over the policy and the policy would be modified in due course to make it consistent with the Regulations.

    This policy has been adopted and approved by the Board of Directors of the Company at their meeting held on 04th February 2016.