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KW Group

Related Party Transactions Policy

Identification, approval, disclosure and review of related-party transactions, under Section 188 of the Companies Act 2013 and SEBI LODR Regulation 23.

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Definition

A related-party transaction means any transaction between the Company and a related party — directly or indirectly — including sale, purchase or supply of goods or services, leasing of property, appointment of agents or any other transaction defined under the Act and the applicable regulations.

Approval matrix

Material transactions require prior approval of the Audit Committee. Transactions in excess of the thresholds under Section 188 require approval of the Board and, where applicable, the shareholders by ordinary resolution. Omnibus approval is granted for recurring transactions in line with SEBI guidelines.

Arm's-length test

Every related-party transaction is reviewed for compliance with the ordinary-course-of-business and arm's-length-price tests. Where either test is not met, the transaction is escalated to the Board with a justification.

Disclosure

Material transactions are disclosed in the Directors' Report, the financial statements (Notes to Accounts under AS-18 / Ind-AS 24) and, where applicable, to the stock exchanges within the timelines prescribed by SEBI.

About this policy

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