SAKTHI SUGARS LIMITED
Coimbatore.
POLICY FOR DETERMINATION OF MATERIALITY OF EVENT OR INFORMATION
1. Preface
Pursuant to Regulation 30(4)(ii) of Securities and Exchange Board of
India (Listing Obligations and Disclosure Requirements) Regulations 2015 (Listing Regulations), the
Board of Directors (“the Board”) of Sakthi Sugars Limited (“the Company”) has adopted this Policy at
its meeting held on 13th February 2016 for determination of materiality of events or information for
disclosure to the Stock Exchanges under the Listing Regulations.
2. CRITERIA FOR DETERMINATION OF
MATERIALITY OF EVENTS OR INFORMATION
The Company shall consider the criteria as specified in clause (i) of
sub-regulation (4) of Regulation 30 of the Listing Regulations 2015 for determination of materiality
of events or information.
3. GUIDELINES FOR DETERMINING
MATERIALITY
- Materiality will be determined on a
case to case basis depending on specific facts and circumstances relating to events or
information. In order to determine whether a particular event or information is material in
nature, ‘quantitative’ criteria will be applied.
- Events or information that are to be
disclosed on application of materiality criteria and the basis for determination of materiality
are given in Annexure.
- In cases where the quantitative
criteria are not applicable or cannot be applied, materiality will be determined based on the
criteria specified in clause (i) of sub-regulation (4) of Regulation 30 of the Listing
Regulations.
- Notwithstanding the above, all the
events or information specified in para A of Part A of Schedule III to the Listing Regulations
shall be deemed to be material events or information and will have to be disclosed without
application of materiality criteria upon occurrence of the same.
4. AUTHORISATION TO KEY MANAGERIAL
PERSONNEL FOR DETERMINING MATERIALITY OF AN EVENT OR INFORMATION
In terms of Regulation 30(5) of the Listing Regulations, the Board of Directors of the Company
authorises Dr.M.Manickam, Chairman and Managing Director, for the purpose of determining materiality
of an event or information and the appropriate period/stage for disclosures to be made, based on the
guidelines of this policy on matters not falling within the events or information and the criteria
mentioned in Annexure. Sri S.Baskar, Company Secretary (Compliance Officer), has been authorised for
the purpose of making disclosures to the Stock Exchanges and on the website of the Company based on
the decision of the Chairman and Managing Director.
5. EFFECTIVE DATE
This Policy comes into force with immediate effect.
6. AMENDMENT
Any amendment/modification in the Listing Regulations and/or other applicable laws in this regard
shall become applicable to this Policy and this Policy shall be deemed to have been amended
accordingly.
The Board of Directors shall have the right to withdraw, substitute and/or amend this Policy at any
time as it may deem necessary and appropriate. The decision of the Board in this respect shall be
final and binding.
ANNEXURE – 1
Events or information and corresponding criteria for determining their materiality pursuant to Para
B of Part A of Schedule III of Securities and Exchange Board of India (Listing Obligations and
Disclosure Requirements) Regulations, 2015 and Clause 3 of this Policy.
S.No.
|
Events or Information
|
Criteria
|
1.
|
Commencement or any postponement in the date of commencement of commercial production or
commercial operations of any unit/division
|
Commencement of or postponement of any new unit or operation resulting in an impact exceeding
25% of the turnover of the Company for the previous financial year.
|
2.
|
Change in general character or nature of business brought about by arrangements for
strategic, technical, manufacturing, or marketing, tie-up, adoption of new lines of business
or closure of operations of any unit/division (entirety or piecemeal)
|
Resulting in an impact exceeding 25% of the turnover of the concerned division of the Company
for the previous financial year.
|
3.
|
Capacity addition
|
Capacity addition by not less than 25% of the Company’s investment in each unit/division.
|
4.
|
Product launch or Variation in product mix
|
Resulting in a change of at least 25% in the turnover of the division in which new product is
launched or the product mix is changed as compared to the turnover of that division in the
previous financial year.
|
5.
|
Awarding, bagging/receiving, amendment or termination of awarded/bagged orders/ contracts not
in normal course of business
|
Resulting in an impact exceeding 25% of the turnover of the concerned division of the Company
during the previous financial year.
|
6.
|
Agreements (Loan Agreements as borrower) or any other agreements which are binding and not in
the normal course of business and amendment or termination thereof
|
Loan agreements which are not in the normal course of business and exceeding Rs.100 crores.
|
7.
|
Disruption of operations of any one or more units or division due to natural calamity (like
earthquake, flood, fire, etc.), force majeure or events such as strikes, lockouts, etc.
|
Closure of operation beyond seven days, except intermittent stoppage normal to sugar
industry.
|
8.
|
Effect(s) arising out of change in the regulatory framework applicable to the Company
|
Changes having impact on the turnover of the company exceeding 25% of the previous year’s
turnover.
|
9.
|
Litigation(s) / dispute(s) / regulatory action(s) with impact
|
Outcome of litigation, dispute and regulatory action is likely to have a financial impact of
more than 25% of the previous year’s turnover of the Company.
|
10.
|
Fraud/defaults, etc. by Directors (other than key managerial personnel) or employees of the
Company
|
Involving a sum or value exceeding Rs.1 crore.
|
11.
|
Options to purchase securities including any ESOP/ESPS Scheme
|
Not applicable as the Company does not have any such Scheme.
|
12.
|
Giving guarantees or indemnity or surety for any third party
|
For an amount in excess of 25% of the turnover of the Company for the previous financial
year.
|
13.
|
Granting, withdrawal, surrender, cancellation or suspension of key licenses or regulatory
approvals
|
Impact exceeding 25% of the turnover for the previous financial year.
|
14.
|
Any major development that is likely to affect the business of the Company.
|
As may be determined by the authorised Key Managerial Personnel.
|