EIH Associated Hotels Limited ‘Dei Office 7 Sham Nath Marg, Delhi-10 054 “iigphone 911 205 08 ota Ofc Margoe Lane Kota 70001 “Whephone 91-380 71 73 Fase 8248 NS EAHIMAN (829 ‘iit: worn Fanvary, 2016 National tock Exchange of India Limited Exchange Plaza, S* flor, Plot # Ci, °G” Block ‘Bandra Kusla Complex, Bandra (Eas), Mumbai ~400 051 Penal enlis@nvceain; se nex@neacol SSE Limited Corpor Heltions Deparment 1! Floor, New Trading Ring, Rotunda Building PhirazeJejecbhoy Towers, Dall Steet, For, Mumbai ~ 400 001 Emailing centobseindia.com ; corprelaions@bseindia.com lising’@bseindia.com Dear Sirs, Sub: intimation pursuant to Regulation 30(5) of SEBI (Listing Obligation and Disclosure Requirement) Regulation, 2015 (*SEBILODR”) Serip Cede/Symbol: 823127 / EIHAHOTELS Pursuant to Regulation 30 of SEBI LODR, we are enclosing » copy of Policy for Determination and Disclosure of Material Events and furish below details of persons authorized forthe purpose of determining materiality of an event or information and forthe Durpose of making disclosure to Stock Exchange(s): ‘Si_[Name. Designation ‘Contact Detail ‘@)_[Me. PES.Oberoi | Chairman prs oberoi@ioberoigroup com Gij_[Mr. $8 Mukheri— | Viee Chairman | ssukheni@oberoigroup.com (Gi). [Mr.Vikram Oberot_[ Managing Digector — | vikram oberoi@oberoigroup.com | (Gv) TMs. Indrani Ray [Company Secretary | indranjray@oberoigroup.com ‘The Policy document i being uploaded in NEAPS and Listing Centre, BSE Limited and alo ‘nour Company website ‘We thank you for taking this into your records ‘Yours fitful, Ase ot Limited pera Indrani Ray ‘Company Secretary Enclsalt Amit © Tie Oke Gap Reger e124 GS Rod ata, Cos ‘ope oe 4 acl SaEIH ASSOCIATED HK )R DETERMINATION AND DISC Statutory Mandate The Board of Directors (The “Board) of EIH “Associated Hotels Limited ("the Company”? “EIHA”) has adopted the following policy and procedures with regard to disclosure of material events which are necessary to be disclosed to the Stock Exchanges based on criteria as may be ‘deemed necessary and has been adopted as pat ofthis policy. The Board may review this plicy fom timeto time. ‘This polcy willbe applicable to the Company with effect from 1* December, 2015 in terms of Regulation 30 of Chapter IV of Securities and Exchange Board of India (Listing Obligations end Disclosure Requirements) Regulations, 2015 (“Listing Regulations). Policy Objective and Scope To detente the events and information which is inthe opinion of the Board are Material end ‘needs to be disclosed tothe Stock Exchanges as per the time span hitherto defined, ‘The policy is intended to define EIHA’s policy on disclosure of events / information and to provide guidance tothe Board of Directors, KMPs and other executives working in the Compeny jn making decisions and undertaking regarding its responsibilty about making public such events information which may materially affect the performance of the Company and thereby the share rice ofthe Company. ‘The policy is framed for the purpose of systematic identification, categorization, review, disclosure and updstion of website the details of informationfevents which are considered material or not but which may have a bearing on the performance of the Company and which ‘may mately affect the sare price ofthe company, All the words and expressions used in this Policy, unless defined hereinafter, shall have the meaning respectively assigned to them under the Listing Regulations and in the absence ofits definition or explanation therein, as per the Companies Act, 2013 and the Rules, Notifications and Circulars made/issued thereunder, as amended from time o time. Policy ‘This Policy for determination of materiality of events and information for disclosure to the Stock Exchanges (hereinafter refered to ‘the Disclosure Policy or thisthe Policy’) is framed in terms of the Securities and Exchange Board of India (Listing Obligations and Discloswe Requirements) Regulations, 2015 (herinafer refered to as the “Listing Regulations”) Page LtA. e fillowirg wil be disclond to the Stock Exchanges any time afer the deison i ken or B er renasenmed tno Inter than 30 minstes of the conelsion ofthe mecting of he ene of Diretors ofthe Company (hereinafter refered to asthe Boud) © Approval of financial results; Gi ieiemenition of dividend to the sharcolders or declation of itrin dividend, including the date of payment of dividend recommended! declared, (Gi) Decision not to recommend a dividend; (© sezrralissommeniation to the shrcholdes roaring fd raising pops thaugh lnsue of securities or acceptance of deposits fom the membersfpubtigs (© Resontmenistion othe surcholes fr issue of bons shares and related information (© Approvalreommeniation the shareholders for buyback of secures; (i) Approval of forfeiture of secur on securities; reissue of fofeited securities or alteration of cali) (il) Recommendaton to the shareholders for alteration of share capital; =) Sppovalcommenaton othe sharhoies for voluntary delisting of the Companys sccuities fom one ar more Stock Exchange(s} reacring eveatsiomution wil be disclosed tothe Stck Exchages as son es posse but not ltr than 24 hours of the occ n in © Aaproval ofthe Board cegrtng soqiston, dirty or indies, of contol of @ ‘company, or entering into agreement for this purposes © Aetuting or sgresing t acquire, dieey or indirectly, shurs/voting right of « company: such that the shireholding/voting rights aggregate, 59%" of mot of tha company’s total shareholdingvoting rights; (3 Chunges in sharcholding in a company fom the last disclosure made othe Stock tout ara indee Clause (i) above, when sich change exoeds 2%" of that compusy's total sharcholding/voting rights, (=) Recommendation by th Boul tothe sarcholdrs eguding a Scheme of Anangement foramelgamation, merge, demerger or oher such restructurings Page 20f6(©) Approval of the Board recommendation by the Board tothe shareholders forsale or ‘disposal of a Hotel/Division of the Conpaay or sale or disposal of a Subsidiary of the Company, if any: (i) lesue of securities by way of rights, bonus shares or in any other manner, alteration of capital and sub-tvision of consolidation of shares; (oii) Forfeiture of securities, reissue of fortted securities or alteration of call(s) on sweurtes; (ity Redcniption of sorties ofthe Companys (Gx) Buyback of securities ofthe Company; (%) Recommendation by the Board to the sharcholders for alteration in the terms of seourites ofthe Companys (xi) Imposition of restriction on transferability of securities of the Company by any authority: # (i) Change in Dirootors, Key Managerial Personnel (KMP), Statutory Auditors and Compliance Officer appointed under the Listing Regulations; (il) Notices, call lees, resolutions and circular sent to and advertisements issued forthe information of al shareholder/creditors/debenture holders, or any class thereof; (xiv) Brief details of General Meetings held; (ev) Recommendation by the Board tothe shareholders for amendment to the Memorandum tnd Articles of Association ofthe Compsny, (vi) Schedule of analysts or institutional investors’ meet, if any, organized by the Company ‘and. presentations on financial reuls, if any, made by the Company to analyst or instittonal investors at such meets; ‘The Company: will ensure that no information is disclosed selectively to any one or troup of research analysts or investors tothe disadvantage of otber stakeholders. Inthe Unlikely event of any material information being disclosed selectively, inadvertent oF bihervise, at a meeting with analysts or at any investor relations conference, such ‘nformation would be promptly disclosed tothe Stock Exchanges; (evil). Knowledge of fraud by a KMP or by the Company or arrest of a KMP;# Pages of 6(vil) Occurrence of default by « KMP or dhe Company (and not merely procedural defeul # (xix). Entering into shareholder agreement or joint venture agreement, tothe extent thet it Impacts management and contol of the Company, or entering into agreement with ‘media companies which is binding and notin the normal course of business, including amendment thereto or termination thereof, (x) Corporate det restructuring (CDR) and one time setlement with banks; (xi) Reference to BIFR and winding-up petition fled by any purty /erditors; # (oxi) Rating of securities ofthe Company by a credit rating agency, including revision fay; (oxi) Approval of the Board for appointment or discontinuation of Share ‘Transfer Agents; ‘The following events/nformation wil be disclosed tothe Stock Exchanges as soon as possible ‘but not ter than 24 hours ofthe sccurrence of the event/ information if the impact of sich evenvingormation on the Company exceeds 10% of its gros turover or 10% of its net worth, whichever is higher, such tumover/net worth tobe based on the latest audited annual financial statements of the Company. (@ Commencement or postponement in the date of commencement of commensal ‘production or commercial operations ofa HotelDivision ofthe Company ‘Change in the general charter or nature of business of the Company through strategic, technical, manufacturing or marketing tie-up with extemal party; ‘Adoption of new line of business or closure of operations of a Hote/ Division ofthe Company; (iv) Capacity addition; (9) Category oF Product launch; (i) Disruption of operations of a HoteV/Division of the Company due to natural calamity (once majeure evens) such as strikes, lockouts et; # (ii) Change inthe regulatory framework impacting the business of the Company; #. (vii) Litigation/isputeregulatory action against the Company or its KMP; # (Gx) Knowledge of fraud by Director or employees, other than KMP, of the Company: # Page dof(Occurrence of default by Directors or employees, other than KMP, ofthe Company(and sot merely procedural default); # (63) Recommendation by the Boar tothe shareholders regarding Scheme for grant of Sick Cptions under the SEBI (Share Based Employee Benefits) Regulations, 2014; (i) Details of grant, vesting and exercise of Stock Options under the Company's Employees ‘Stock Option Schemes, if any, where such grant, vesting or exercise encceds 1% ofthe ‘paid-up share capital of the Company, based on the Inest audited annual financil ‘Satements ofthe Company; Giving of guarantee or indemnity or become a surety fora third party: (iv) Granting, withdrawal, surrender, cancellation or suspension of key license or regulatory approval: # (v) _Awanding/eceiving orders or contracts notin the normal course of busines, including ‘anendment thereto or termination thereof, # (vi) Entering into agreement for borrowing money or any other agreement which is binding snd.not in the normal course of business, including amendment thereto or tenminaton tbereof, (evil) Any other significant developmenvevent ‘information that is likely 0 impact ‘he (Company”s business, tothe extent indicted above; (evil) Any other material evenvinformation which is exclusively known to the Company end ‘needs disclosure to enable the shareholders to appraise the Company's position, In case the materisity threshold indicated shove cannot be applied 10 @ particular cvenvinformation, the Company will disclose such evenvinformation; (1) wren non-disclosure of the eventnformation is likely 4o result in discontinuity or akeration of evenvinformation already available inthe public domain, or (@) itis expected that if the evea/information subsequently comes inthe public domain, i wil impact the macket price ofthe Company's shares to the extent of 10% or moe, woolly atibutable to such evenvinformation, or @) ifthe evenvinformation is material in the opinion of te Bosrd, 5. Where the Company makes disclosures t the Stock Exchanges under Clause (A), (B) or (C) above, the Company will ls disclose material development(s) onthe suid evenvinformation, Page S0666. The Company wil also disclose tothe Stock Exchanges, with respect to its Subsidiaries, if any, events and information which ae material forthe Company. 7. The Directors viz: Mr. PRS. Oberoi, Chairman, Mr. $.8, Mukbesj, Vice Chairman and Me. Vikram Oberoi, Managing Director are authorise, singly, to determine the materiality of an cveny information in terms of this Policy. Based on such determination of material events / information and where material events! information are deemed material in terms of the listing equations and prescribed in this policy, the Company Secretary is authorized to. make appropriate disclosures 10 the Stock Exchanges and’ to take all actions as required under Regulation 30 ofthe Listing Regulations ‘The Contact details ofthe above officials ofthe Company are as under }) MPS. Oberoi, Chairman = pcberoi@eberoigrou.com i) -Mz.S.S. Mukhes, Vice Chairman ss mukheri@oberoigroup.com ; fit) Mr-Viksam Oberoi, Managing Director ~ _yikram,oberoi@oberoisroup com: jv) Ms Indrani Ray, Company Secretary — _indranirayiGoberoigroup.com 8. The Disclosure Policy willbe posted on the Company's website www ihassosiatedotels.in und vents & information disclosed tothe Stock Exchanges in terms ofthis Policy wil also be bept posted on the website fr atleast five years* from the date such eventinformation is posted. * or suck other limit or time period as may be prescribed under the Listing Regulations fiom time totime. # events information will be disclosed to the Stock Exchanges as soon as possible but no later than 24 hours from the time any KMP of the Company becomes aware of sich cventnformation in the course of performance of his duties, Page 6of 6