BASF India Ltd — Audit Report / Information 2022

May 10, 2022

BASF India Limited, Mumbai - 400 051, India

May 10, 2022

The Market Operations Department BSE Limited, Phiroze Jeejeebhoy Towers Dalal Street, Mumbai 400 001.

Name of the Company	:	BASF India Limited
Security Code No.	:	500042

Dear Sir/Madam,

Sub: Annual Secretarial Compliance Report for the year ended 31st March, 2022

Pursuant to the provisions of Regulation 24A of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 as amended and read with SEBI Circular No. CIR/CFD/CMD1/27/2019 dated 8th February, 2019, we enclose herewith the Annual Secretarial Compliance Report issued by Mr. Hemant Shetye, Partner of HSPN & Associates LLP, Practising Company Secretaries, for the year ended 31st March, 2022 for your information and record.

Thanking you,

Yours faithfully For BASF India Limited Manohar Shrikant

Digitally signed by Manohar Shrikant Kamath Date: 2022.05.10 11:34:47 +05'30'

Manohar Kamath Pankaj Bahl Director- Legal, General Counsel (India) Manager- Company Secretarial & Company Secretary

Encl: a.a.

Kamath

cc: The Assistant Manager – Listing National Stock Exchange of India Ltd. Exchange Plaza, 5th floor Plot No.C/1, G Block Bandra – Kurla Complex Bandra (East), Mumbai – 400 051

Registered Office BASF India Limited The Capital, 'A' Wing, 1204-C, 12th Floor, Plot No. C-70, 'G' Block, Bandra-Kurla Complex, Bandra (East), Mumbai - 400 051, India

Tel +91 22 6278 5600

CIN - L33112MH1943FLC003972

www.basf.com/in

PANKAJ RAJKUMAR BAHL Digitally signed by PANKAJ RAJKUMAR BAHL Date: 2022.05.10 11:34:12 +05'30'

LLPIN: AAZ-8456 | Unique Code: L2021MHE011400 Lower Parel (E), Mumbai - 400 011 Unique Code: P2007MH004300) Email: hs@hspnassociates.in

206, 2nd Floor, Tantia Jogani Industrial Estate. (Formerly known as HS ASSOCIATES Tel: 022 23088998/23008998/40026600/40061 100 Web.: www.hspnassociates.in

Secretarial Compliance Report of BASF India Limited for the year ended 31stMarch, 2022

To

Board of Directors BASF India Limited The Capital, A Wing,1204-C, 12th Floor, Plot No.C-70 'G' Block, Bandra Kurla Complex, Bandra (East) Mumbai 400051.

I Mr. Hemant Shetye, Designated Partner of HSPN & Associates LLP have examined:

• a) all the documents and records made available to me and explanation provided by BASF India Limited ("the listed entity"),
• b) the filings/ submissions made by the listed entity to the stock exchanges,
• c) website of the listed entity,
• d) any other document/ filing, as may be relevant, which has been relied upon to make this certification,

For the year ended 31% March, 2022 ("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) the 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 for the period under review.

(c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;

(d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; not applicable for the period under review.

(e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 erstwhile Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, & 2014 & SEBI (Issue of Sweat Equity) Regulations, 2002; -not applicable for the period under review.

(f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021 erstwhile Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008 & Securities and Exchange Board of India (Issue and Listing of Nonconvertible and Redeemable Preference Shares) Regulations, 2013; - not applicable for the period under review.

(g) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;

(h) SEBI (Depositories and Participants) Regulations, 2018 erstwhile SEBI (Depositories and Participants) Regulations, 1996;

(i) Annual Secretarial audit report and annual secretarial compliance report for listed entities as per SEBI circular CIR/CFD/CMD1/27/2019 dated February 08, 2019;

(Gj) Disclosure of reasons for delay in submission of financial results by listed entities as per SEBI circular CIR/CFD/CMD-1/142/2018 dated November19, 2018;

(k) Standardised norms for transfer of securities in physical mode SEBI/HO/MIRSD/DOS3/CIR/P/2018/139 dated November 6, 2018;

(1) Strengthening the Guidelines and Raising Industry standards for RTAs, Issuer Companies and Banker circular no. SEBI/HO/MIRSD/DOS3/CIR/P/2018/115 dated July16, 2018 read with SEBI circular No. SEBI/HO/MIRSD/DOP1/CIR/P/2018/73 dated April 20, 2018;

(m) Standard Operating Procedure for suspension and revocation of trading of specified securities circular no. SEBI/HO/CFD/CMD/CIR/P/2018/77 dated May 3, 2018;

(n) System-driven Disclosures in Securities Market as per SEBI circular SEBI/HO/CFD/DCR1/CIR/P/2018/85 dated May 28, 2018;

(0) Monitoring of Foreign Investment limits in listed Indian companies SEBI circular IMD/FPIC/CIR/P/2018/74 dated April 27, 2018 read with SEBI Circular No. IMD/FPIC/CIR/P/2018/61 dated April 5, 2018;

(p) Disclosures by listed entities of defaults on payment of interest/ repayment of principal amount on loans from banks / financial institutions, debt securities, as per SEBI circular CIR/CFD/CMD/93/2017 dated August 4, 2017;

(q) Database for Distinctive Number (DN) of Shares as per SEBI circular SEBI/HO/MRD/DOP2DSA2/CIR/P/2019/87 dated August 01,2019;

(r) Disclosure of significant beneficial ownership in the shareholding pattern as per SEBI circular SEBI/HO/CFD/CMD1/CIR/P/2019/36 dated March 12,2019;

(s) Framework for listing of Commercial paper as per SEBI circular SEBI/HO/DDHS/CIR/P/2019/115 dated 224 October 2019 read with Non-compliance

with provisions related to continuous disclosures as per SEBI Circular no. SEBI/HO/DDHS/DDHS/CIR/P/2020/231 dated November 13, 2020;

(t) Resignation of statutory auditors from listed entities and their material subsidiaries as per SEBI circular CIR/CFD/CMD1/114/2019 dated 18, 2019;

(u) Disclosures of standardizing reporting of violations related to code of conduct under SEBI (PIT), 2015 as per SEBI Circular HO/ISD/ISD/CIR/P/2019/82 dated 19' July 2019;

(v) Violation of Insider Trading SEBI Circular No. SEBI/HO/ISD/ISD/CIR/P/2020/135 dated July 23, 2020;

(w) E-VOTING Facility as per SEBI Circular No. SEBI/HO/CFD/CMD/CIR/P/2020/242 dated December 09, 2020;

(x) Operational guidelines for Transfer and Dematerialization of re-lodged physical shares as per SEBI Circular No. SEBI/HO/MIRSD/RTAMB/CIR/P/2020/166 dated September 07, 2020;

(y) Handling of Scores Complaints as per SEBI Circular No. SEBI/HO/OIAE/IGRD/CIR/P/2020/152 dated 13' August 2020;

(ae) Automation of disclosure requirements under SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011-System Driven Disclosures - Ease of doing business circular no. SEBI/HO/CFD/DCR-3/P/CIR/2022/27 dated March 7, 2022.

Automation of System Driven SEBI/HO/ISD/ISD/CIR/P/2020/168 dated September 09, 2020;	Disclosures as	per SEBI Circular No.
(aa) Common and Simplified Norms for processing investor's service requests by RTAs norms Nomination furnishing PAN, and dated KYC_ details, for SEBI/HO/MIRSD/MIRSD_RTAMB/P/CIR/2021/655 November 03, 2021;
(ab) Issuance of Securities in dematerialized form in case of Investor Service Requests dated SEBI/HO/MIRSD/MIRSD_RTAMB/P/CIR/2022/8 January 25, 2022;
(ac) Format of compliance report on Corporate Governance by Listed Entities dated SEBI/HO/CFD/CMD-2/P/CIR/2021/567 May 31, 2021;
(ad) disclosure obligations of listed entities in relation to Related Party Transactions. SEBI/HO/CFD/CMD1/CIR/P/2021/662 dated November 22, 2021;
Automation requirements under SEBI of disclosure (Substantial Acquisition (ae) of Shares and Takeovers) Regulations, 2011-System Driven Disclosures - Ease of doing business circular no. SEBI/HO/CFD/DCR-3/P/CIR/2022/27 dated March 7, 2022.
And based on the above examination, I hereby report that, during the Review Period:
The listed entity has complied with the provisions of the above Regulations and circulars/ guidelines issued thereunder, except in respect of matters specified below:
Requirement Deviations Compliance Sr		Observations/Remarks
No. (Regulations/ circulars/		Practicing the of
guidelines including specific clause)	:	Company Secretary !
numbered Certain SEBI circular 1		Company The has
SEBI/HO/MRD/DOP2DSA2	Distinctive	; updated Distinctive the
	Number Range :	Number Range with the

€

	/CIR/P/2019/87 August 01, 2019,	and	dated with respect to _Depositories physical share the capital of the Company is not ! Share updated the Depositories	based records available with their Registrar Transfer Agent, with however as _ informed except for 2445 (Two Thousand Four Hundred and Forty Five) Equity shares {constituting 0.01
				% of the paid up Equity Share Capital of the Company) where the data is not available with the Company's Registrar.
b) c) Sr No.	my/our examination of those records. under the aforesaid Action by	taken Details		The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder insofar as it appears from The following are the details of actions taken against the listed entity/ its promoters/ Directors/ material subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) Acts/ Regulations and circulars/ guidelines issued thereunder: of Details of action Observations/

• b) The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder insofar as it appears from my/our examination of those records.
• c) The following are the details of actions taken against the listed entity/ its promoters/ Directors/ material subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under the aforesaid Acts/ Regulations and circulars/ guidelines issued thereunder:

Sr No.	Action by to	taken Details violation -		of Details of action Observations/ taken e.g. fines, remarks of warning letter, debarment, etc. Company 7	the Secretary, if any.	Practicing
			Not Applicable

Sr.	Observations No. the _ Practicing , Company Secretary inthe' 31.03.2021 previous reports	of Observations made in the secretarial compliance report any forthe yearended	Actions taken by the listed entity, if	Comments of the Practicing Company Secretary on the actions taken by the listed
				entity

1. Observations /mentioned Annual Secretarial Compliance Report for 31«March, 2020. Certain Distinctive Number with physical capital of the _updated the Depositories. :	in /	On Observations made by in Annual Secretarial Compliance Report Depositories for 31s March, on 2021. The Company has _ Updated Range Range with the respect to Depositories based share on the records Company is not Registrar & Share with Transfer however informed except for data is 2445 Thousand Hundred and Forty years, Five) Equity shares paid-up % of the Equity Capital of Company) where the data is available withthe order Company's Registrar.	the the not:	The Company updated Distinctive Number Range with the available with Registrar & Transfer Agent, the however as informed The Distinctive Number except for 2445 (Two has been able to Thousand Hundred and Five) Equity available with their (constituting 0.01 of the paid up Equity case Agent, Share Capital of as Company) where the Four not available and (Two with the Four Registrar. Over the has been able (Constituting 0.005 reduce the number of Share such records Share 5702 to 2445 andthe to the Company continue to _ necessary steps to update distinctive range with Depositories.	in	has On the the Observations made in the the Annual based Secretarial records Compliance their Report for 31+ Share March, 2021. Company Four reduce the Forty number of such shares records from % 5702 to 2445. In of 2445 the (Two Thousand Hundred Forty Company's Five) Equity the shares, the Company Company's to Registrar & Transfer from has been unable update the would same due to non- take availability of data at RTA's the end. due to non- number availability of the data at RTA's end. However, the Company is taking all necessary steps in order to update the remaining
Sr. Observations No. of the Practicing Company Secretary	in in for	Observations the secretarial compliance report	any	_ made Actions taken by the listed entity, if		number range with the Depositories. Comments of the Practicing Company Secretary on the actions taken by the listed
the previous reports		the year ended 31.03.2020				entity

Sr. Observations	Observations	made Actions taken by	Comments of the
No. of the	in	the listed entity, if	Practicing
Practicing	the secretarial	any	Company Secretary
Company	compliance report		on the actions
Secretary	in for		taken by the listed
the	the year ended		entity
previous	31.03.2020

1	Observations On mentioned in Observations Annual Secretarial Compliance Report for 31«March, 2020. 2019. Not Applicable since Company taken sufficient Steps addressed the Company raised observations. Depositories.	made by in Annual Secretarial Report for Compliance Report 2020. for 31s March, the Certain Distinctive has Number Range with respect to physical and capital of the is updated with the	the On the Observations made by in the Annual Observations the Secretarial Compliance made 31« March, Annual The Shares on which DNR is not updated is reduced from 5702 (Five thousand Seven Hundred and Two) To share 2445 (Two Thousand Four Hundred and not Forty Five)	On the by in the Secretarial Compliance Report for 31« March, 2020. The count of Distinctive Number Range not updated with the Depositories has reduced during the financial year ended 31.03.2021 from the previous financial year.

Note:

• 1. This report is based on the following:
• a) Compliances required to be done by the Company during the Financial Year ended 31s March, 2022 (i.e., the period covered for the purpose of this Report is from 01st April, 2021 to 31st March, 2022.
• 1. There was no event of appointment/re-appointment/resignation of statutory auditor of the Company during the review period and the Company has suitably modified the terms of appointment of its existing statutory auditor to comply with clause 6(A) and 6(B)} of Circular No. CIR/CFD/CMD1/114/2019 dated 18th October, 2019 issued by SEBI.

Date: 09/05/2022 Place: Mumbai ICSI UDIN: F002827D000283976 PEER REVIEW NO: P2007MH004300

Hemant S.Shetye | wuwe, 2°) Designated Partner \ 0 </ FCS No.: 2827 SSS " ZA COP No.: 1483

For HSPN & ASSOCIATES LLP

Company Secretaries / PE

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