Integrated Annual Report 2024-25 198 D. Disclosure of Accounting Treatment in preparation of Financial Statements The financial statements have been prepared in accordance with Indian Accounting Standards (“IndAS“) 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Trading Practices The Company has formulated and adopted the ‘Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information’ which, inter alia, includes Policy for determination of ‘Legitimate Purpose’ and ‘Code of Conduct for Prevention of Insider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 (“PIT 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 PIT 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. The Company has amended M&M Code of Conduct incorporating therein provisions pertaining to Trading Plan in line with the recent amendments by SEBI (Prohibition of Insider Trading) (Second Amendment) Regulations, 2024. F. Policy and procedure for inquiry in case of leak/ suspected leak of Unpublished Price Sensitive Information The Company has formulated the ‘Policy and procedure for inquiry in case of leak / suspected leak of Unpublished Price Sensitive Information’ (’UPSI’).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 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. Whistle-blower 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 classroom / online and E‑learning sessions. The Company has a third-party whistleblowing helpline service through an external service provider. The Ethics helpline service includes toll free number, web portal access and e-mail facilities. This helpline serves as platform under vigil mechanism for all stakeholders and associates to raise any concerns on unethical behaviour and is provided by Convercent, a Global service provider. • Helpline No: 000 800 100 4175 The toll-free helpline number is available in English and Multiple Languages. • Web-link: https://ethics.mahindra.com/ is available in Multiple Languages. Direct complaints can also be raised with the Chairperson 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 has an established reporting mechanism for Stakeholders and associates to report concerns about unethical behaviour, actual or suspected fraud, or violation of the Code, including insider trading violations and reporting instances of leak of Unpublished Price Sensitive Information by the employees. Under the Vigil Mechanism, the employees are encouraged to voice their concerns. All stakeholders and associates have been provided access to the Audit Committee through the Chairperson. No person has been denied access to the Audit Committee. The Policy provides for adequate safeguards against victimization of persons who use the mechanism. The Whistle-blower Policy was updated during the year, the details of which may be referred to in the Board’s Report.
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