Ganpati Plastfab Limited

Policy On Materiality Of Related Party Transactions And Dealing With Related Party Transactions

Introduction and Background

Ganpati Plastfab Limited recognizes that related party transactions can present potential or actual conflicts of interest and may raise questions about whether such transactions are consistent with the company's and its stakeholder's best interests.

Scope & Inclusion

This policy sets definition of materiality of related party transactions and dealing with related party transactions.

Terms and References

1. Materiality of related party transactions
   Contracts / arrangements with the related party shall be considered as material related party contracts/ arrangements if the transactions to be entered individually or taken together with the previous transactions during a financial year under such contracts/ arrangements exceed ten percent of the annual consolidated turnover of the company as per the latest audited financial statement or such sum as may be prescribed under Securities and Exchange Board of India (Listing obligations and Disclosures Requirements) Regulations, 2015 ("Listing Regulations") and as amended from time to time.
   
   A transaction involving payment made to related party with respect to brand usage or royalty shall be considered material if the transactions to be entered into individually or taken together with previous transactions during a financial year exceeds two percent of the annual consolidated turnover of the company as per the last audited financial statements of the company.

Policy

1. All related party contracts/ arrangements shall be entered on arm's length basis.
2. In exceptional circumstances, where permitted by law, related party contracts/ arrangements may deviate from the principle of the arm's length, after approval from audit committee and the Board of Directors, as the case may be.
3. All the related party contracts/ arrangements shall be in compliance with the provision of the Companies Act, 2013, (the "Act") Listing Regulations and applicable Accounting Standards, as amended from time to time.
4. All domestic related party contracts/ arrangements shall, wherever applicable, comply with the Domestic Transfer Pricing Requirement under section 92BA of Income Tax Act, 1961 including certification from independent accountants under the Transfer Pricing Regulations.
5. All international related party contracts/ arrangements shall comply with International Transfer Pricing Requirement under section 92B of Income Tax Act, 1961 including certification from independent accountants under the Transfer Pricing Regulations.
6. All related party contracts/ arrangements shall require prior approval of the audit committee or Board of Directors or Shareholders of the company, as the case may be, as required under and subject to the Act and the Listing Regulations.

(This document was approved by the Board of Directors at its meeting held on 13th August, 2014 and first modification approved at its meeting held on 20th june, 2018)