MAHINDRA & MAHINDRA LTD. | Integrated Annual Report 2021-22

173 MAHINDRA & MAHINDRA LTD. Integrated Annual Report 2021-22 In addition to the above, as per the Listing Regulations, your Company has also submitted disclosures of Related Party Transactions to the Stock Exchanges in the prescribed format and also published it on the website of the Company. D. Disclosure of Accounting Treatment in preparation of Financial Statements The financial statements have been prepared in accordance with Indian Accounting Standards (“Ind AS“) per the Companies (Indian Accounting Standards) Rules, 2015 as amended and notified under section 133 of the Act and other relevant provisions of the Act. E. Code for Prevention of Insider Trading Practices The Company has formulated and adopted the ‘Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information’ which, inter alia , includes Policy for determination of ‘Legitimate Purpose’ and ‘Code of Conduct for Prevention of Insider Trading in Securities of Mahindra & Mahindra Limited’ (“M&M Code of Conduct”) in compliance with the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (“Insider Trading Regulations”). M&M Code of Conduct has been formulated to regulate, monitor and ensure reporting of trading by the Designated Persons and their immediate relatives towards achieving compliance with the Insider Trading Regulations and is designed to maintain the highest ethical standards of trading in Securities of the Company by persons to whom it is applicable. The Code lays down Guidelines, which advise them on procedures to be followed and disclosures to be made, while dealing with securities of the Company and caution them of the consequences of violations. F. Policy and procedure for inquiry in case of leak/suspected leak of Unpublished Price Sensitive Information The Company has formulated the ‘Policy and procedure for inquiry in case of leak / suspected leak of Unpublished Price Sensitive Information’ (’UPSI’). The Policy is formulated to maintain ethical standards in dealing with sensitive information of the Company by persons who have access to UPSI. The rationale of the Policy is to strengthen the internal control systems to ensure that the UPSI is not communicated to any person except in accordance with the Insider Trading Regulations. The Policy also provides an investigation procedure in case of leak/suspected leak of UPSI. G. Whistleblower Policy The Vigil Mechanism as envisaged in the Act and the Rules prescribed thereunder and the Listing Regulations is implemented through the Code of Conduct, Whistle- blower and other Governance Policies and the Vigil Mechanism frameworks. The Company has taken adequate measures to create awareness amongst its employees on the Code of Conduct and Governance Policies through regular face to face/ virtual learning sessions and roll out of e-module learning and compliance modules. The Company has provided a third-party helpline as well as web portal to all stakeholders to raise any Ethics complaints. The helpline is provided by Convercent, a Global service provider. • Helpline No: 000 800 100 4175 The toll- free helpline number is available in English and 12 prominent languages. • Url: https://ethics.mahindra.com/ Direct complaints can also be raised to the Chairman of the Audit Committee through the third party web portal at the link mentioned above or by sending an email to [email protected] or by sending a letter to the below address: Chairperson of the Audit Committee Mahindra & Mahindra Limited, Mahindra Towers, Dr. G. M. Bhosale Marg, P. K. Kurne Chowk, Worli, Mumbai – 400 018. The Whistle-blower Policy provides for reporting of insider trading violations and reporting of instances of leak of Unpublished Price Sensitive Information by the employees. Under the Vigil Mechanism, all stakeholders have been provided access to the Audit Committee through the Chairperson. No personnel have been denied access to the Audit Committee. The Policy provides for adequate safeguards against victimization of persons who use the mechanism. Whistle Blower Policy was updated during the year, the details of which may be referred to in the Board’s Report. During the course of the year Vigil framework and systems for timely and conclusive resolution of compliance concerns have been standardized and further strengthened. The Whistle-blower Policy of the Company is available on the website of the Company and can be accessed in the Governance section at the Web-link https://www.mahindra.com/investors/reports-and-filings.