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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.