Policy for determining materiality of events
In terms of clause 30 of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (Regulations) the Board of Directors (the “Board”) of the Western India Cottons Ltd. (the “Company”) has adopted this policy for determination of materiality of events/information (“Material Information”) so that such information can be promptly disclosed to the stock exchanges as well on the website of the Company, as per the prescribed Regulations.
a) An Operating Committee, comprising of the Managing Director and, the Chief Financial Officer of the Company shall be the authority to determine the materiality of any event/ information, classify it as a Material Information, decide the appropriate time, in compliance with the provisions of the Regulations, at which disclosure is to be submitted to the stock exchanges and the details that may be disclosed in the best interest of present and potential investors.
b) Certain information would be per se Material Information as per Para. A of Part A of Schedule III of the Regulations.
c) Besides per se Material Information, an event/information, would be deemed as Material Information if the same is likely to have an impact of more than 10% on the gross turnover or revenues or total income or 20% of the net worth, whichever is lower, as per the last audited annual consolidated accounts of the Company or
d) In some cases, inter-alia including disclosure of events specified in Para B of Part A of Schedule III of the Regulations, if the materiality thresholds as prescribed in clause 2(c) of this policy cannot be applied, the Operating Committee, in such cases, shall frame their opinion on a case to case basis, based on specific facts and circumstances relating to the information/event and while doing so, it may consider, among other factors, the following factors:
Whether the omission of an event or information, which is likely to result in discontinuity or alteration of event or information already available publicly, or
* Whether 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, or
* Whether there would any direct or indirect impact on the reputation of the Company, or
* Whether non-disclosure can lead to creation of a false market in the securities of the Company, or
* Whether there would be a significant impact on the operations or performance of the Company.
Provided that any confidential information which if disclosed is likely to put at risk the business interest of the Company shall not be disclosed. The Company to that extent shall make qualified disclosure to the stock exchanges.
The names and contact details of the KMPs authorized to determine materiality of events/information are attached at Annexure ‘A’.
a) In any circumstance where the terms of this policy differ from any existing or newly enacted law, rule, regulation or standard governing the Company, the law, rule, regulation or standard will take precedence over these policies and procedures until such time as this policy is changed to conform to the law, rule, regulation or standard.
b) The Company shall disclose such Material Information, including any updations on material developments on regular basis till such time such event is resolved / closed, with relevant explanation.
c) The Company shall disclose on its website all such events or information which has been disclosed to Stock Exchanges(s) under this Regulation, and such disclosures shall be hosted on the website of the Company for a minimum period of five years and thereafter as per the archival policy of the Company, as disclosed on Company’s website.
d) The Company shall disclose all events or information with respect to subsidiaries which are material for the Company
Annexure 'A' to Policy for Determining Materiality of Events /Information
Names and Contact Details of Key Managerial Personnel (KMPs) authorised to determine materiality of an event/s or information and for the purpose of making disclosures to Stock Exchanges
Pursuant to Regulation 30(5) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 below are the Key Managerial Personnel(s) of the Company, authorised to determine the materiality of an event(s) / information and for the purpose of making disclosures to Stock Exchange are as under
Name of KMPs
1. Mr. P.K.Shameem, Managing Director
2. Mr.Suneed Hashir, Chief Financial Officer & Compliance officer
The Western India Cottons Limited
Kannur Dist – 670561
Tel no.: +91 497 2761353
Fax No: +91 497 2702977