Policy on determination of Materiality



SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Regulations”) requires every   Listed Company to disclose   events   or information which, in the opinion of the Board of Directors of a Company are material.

In  this  context,   the  following  policy   has  been  framed by  the  Board   of  Directors (“Board”)  Prolife Industries Limited  (“Company”)  at  its meeting held on 07th September, 2016 with the objective of determining materiality of events.

  1. Regulation 30 of the Regulations mandates disclosure of all deemed material events to the Stock Exchanges. These events  have  been  specified in Para  A of Part  A of Schedule III of the  Regulations and  shall  be disclosed as applicable from  time-to- time.
  1. For disclosure of certain events (as specified in Para  B of Part  A of Schedule III) to the  Stock  Exchanges the  following criteria  shall  be  considered by  the  Board  for determining whether the events  are material or not:-

Where the omission of an event or information, is likely to result in:

a) Discontinuity or alteration of event or information already available publicly or

b) A significant market reaction if the said omission came to light at a later date.

In  cases  where  the  criteria   specified  in  point (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.

This Policy shall also apply to the events to which neither Para A or Para B of Part A of Schedule III applies but have a material effect on GICL.


  1. Any event purported to be reportable under Regulation 30 of the Regulations shall be informed to the Chairman & Managing Director/Chief Financial Officer/Company Secretary of the Company on an immediate basis with adequate supporting data/information to facilitate a prompt and appropriate disclosure. Any other  event,  even  if not  covered under the  Regulations but  is potentially of price  sensitive nature, must  also  be informed, for further evaluation to the  Chief Financial Officer & Company Secretary.
  1. The Chairman, the Managing Director and the Chief Financial Officer & Company Secretary of the Company shall severally be responsible and authorized for ascertaining the materiality of events considering its nature and its disclosure after taking into consideration the various provisions of the Regulations and this policy.
  1. After evaluation, any one of the above mentioned persons shall make disclosure to the Stock Exchanges.
  1. The Company shall use  the  electronic facilities  provided by the  Stock Exchanges for dissemination of the information and  may  subsequently disclose  the  same  via other  media, including the press  release, website, etc.
  1. Statutory time frames for disclosure shall be adhered to. Delay, if any, should be sufficiently explained along with the disclosure.
  1. Regular updates, where relevant, shall be made with relevant explanations.
  1. All disclosures shall be available on the website of the Company for a period of 5 years.


This Policy is framed based on the provisions of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 as notified on September 2, 2015. In case of any subsequent amendments to the Regulations which makes any of the provisions in the Policy inconsistent, the provisions of the Regulations shall prevail. The Policy shall be reviewed by the Audit Committee and on recommendations shall be modified by  the  Board  so  as  to  align  the  same  with  the  amendments or  to  incorporate the changes as may be felt appropriate by the Audit Committee.