Integrated Annual Report 2024-25 110 ANNEXURE IV Secretarial compliance report of Mahindra and Mahindra Limited for the financial year ended March 31, 2025 To, The Board of Directors Mahindra and Mahindra Limited Gateway Building, Apollo Bunder, Mumbai 400001 I, CS Sachin Bhagwat, Practicing Company Secretary, have examined: a) All the documents and records made available to me and explanation provided by Mahindra and Mahindra Limited (“the listed entity”), b) The filings/ submissions made by the listed entity to the stock exchanges, c) W ebsite of the listed entity, d) A ny other document/ filing, as may be relevant, which has been relied upon to make this certification, for the financial year ended on March 31, 2025 (“Review Period”) in respect of compliance with the provisions of: a) the Securities and Exchange Board of India Act, 1992 (“SEBI Act”) and the Regulations, circulars, guidelines issued thereunder; and b) t he Securities Contracts (Regulation) Act, 1956 (“SCRA”), rules made thereunder and the Regulations, circulars, guidelines issued thereunder by the Securities and Exchange Board of India (“SEBI”); The specific Regulations, whose provisions and the circulars/ guidelines issued thereunder, have been examined, include:- a) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015; b) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 (Not applicable to the listed entity during the Review Period); c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011; d) Securities and Exchange Board of India (Buy-back of Securities) Regulations, 2018 (Not applicable to the listed entity during the Review Period); e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021; f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021; g) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015; h) Securities and Exchange Board of India (Depositories and Participants) Regulations, 2018 to the extent applicable. and circulars/ guidelines issued thereunder; and based on the above examination, I hereby report that during the Review Period: (a) The listed entity has complied with the provisions of the above Regulations and circulars/ guidelines issued thereunder except in respect of matters specified below: Not applicable (b) The listed entity has taken the following actions to comply with the observations made in previous reports: Not applicable (c) I hereby report that, during the review period, the compliance status of the listed entity with the following requirements: Sr. No. Particulars Compliance Status (Yes/No/NA) Observations remarks by PCS 1. Secretarial Standards: The compliances of the listed entity are in accordance with the applicable Secretarial Standards (SS) issued by the Institute of Company Secretaries India (ICSI). Yes — 2. Adoption and timely updating of the Policies: All applicable policies under SEBI Regulations are adopted with the approval of board of directors of the listed entity. Yes — All the policies are in conformity with SEBI Regulations and have been reviewed and timely updated, as per the regulations/circulars/guidelines issued by SEBI. Yes —
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