Archiving Policy

1. Introduction

This policy outlines the procedures for archiving and reviewing Corporate Governance and Audit (CGA) documents and records. Effective archiving ensures proper record retention, facilitates access for authorized personnel, and supports regulatory compliance. This policy applies to all departments and personnel responsible for generating, managing, and accessing CGA documents.

2. Scope

This policy covers the following CGA documents and records:

• Board minutes and resolutions
• Audit reports and management responses
• Internal control policies and procedures
• Risk assessment reports
• Regulatory filings and compliance documentation
• Corporate governance charters and manuals
• Whistleblower reports and investigations
• Meeting agendas, presentations, and supporting materials
• Any other documents related to the organization's corporate governance and audit functions

3. Archiving Procedure

• Document Classification: All CGA documents must be classified based on their level of sensitivity and retention period. A document retention schedule should be established, outlining the minimum retention period for each document type based on legal, regulatory, and operational requirements.
• Physical Archiving: Physical CGA documents should be archived in a secure location with controlled access. The location should be protected from fire, flood, theft, and other potential damage.
• Electronic Archiving: Electronic CGA documents should be stored in a secure electronic repository with appropriate access controls and audit trails. The system should be backed up regularly to prevent data loss.
• Metadata: All archived documents, both physical and electronic, should be properly labeled and indexed with relevant metadata such as document type, date, author, department, and keywords. This metadata facilitates efficient document retrieval.

4. Review Procedure

• Periodic Review: Archived CGA documents should be reviewed periodically, at least annually, to ensure they are still relevant and accurate. Documents that are no longer required should be disposed of according to the document retention schedule and relevant data security regulations.
• Special Reviews: CGA documents may also be subject to special reviews triggered by specific events such as internal investigations, regulatory inquiries, or changes in ownership or leadership.
• Access Control: Access to archived CGA documents should be restricted to authorized personnel who have a legitimate business need to access them. A clear access control policy should be established and enforced.

5. Technology Considerations

• Archiving Software: Consider using specialized archiving software to manage the storage, retrieval, and review of CGA documents. This software can automate many tasks and improve the overall efficiency of the archiving process.
• Security: Implement appropriate security measures to protect archived CGA documents from unauthorized access, modification, or deletion. This may include encryption, access controls, and audit logging.