Ceat Ltd. — Audit Report / Information 2021

May 26, 2021

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May 26, 2021

BSE Limited

Phiroze Jeejeebhoy Towers, Dalal Street, Mumbai 400 001 Security Code: 500878

National Stock Exchange of India Limited

Exchange Plaza, Bandra Kurla Complex, Bandra (East), Mumbai 400 051

Symbol: CEATLTD NCD symbol: CL23, CL25 CP Listed ISIN: INE482A14AD9 INE482A14AE7 INE482A14AF4 INE482A14AG2

Sub: Annual Secretarial Compliance Report for FY 2020-21

Dear Sir/Madam,

Pursuant to Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, please find enclosed, the Annual Secretarial Compliance Report of CEAT Limited for the year ended March 31, 2021 issued by M/s Parikh & Associates, Practicing Company Secretaries.

We request you to kindly take the same on record.

Thanking you,

Yours faithfully, For CEAT Limited

Vallari Gupte Company Secretary and Compliance Officer

Encl. A/a

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PARIKH & ASSOCIATES Office:

COMPANY SECRETARIES 111, 11[th ] Floor, Sai-Dwar CHS Ltd

Sab TV Lane, Opp. Laxmi Industrial Estate, Off Link Road, Above Shabari Restaurant, Andheri (W), Mumbai : 400053 Tel No 26301232 / 26301233 / 26301240 Email: cs@parikhassociates.com parikh.associates@rediffmail.com

Secretarial Compliance Report of CEAT Limited for the year ended March 31, 2021

To, CEAT Limited 463, Dr. Annie Besant Road, Worli, Mumbai 400030

We Parikh & Associates have examined:

• a) all the documents and records made available to us and explanation provided by CEAT 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 March 31, 2021 (“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 to the company 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 (Buyback of Securities) Regulations, 2018;(Not applicable to the company during the review period)

• e) Securities and Exchange Board of India (Share Based Employee Benefits) Regulations, 2014; (Not applicable to the company during the review period)

Continuation Sheet

• f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008;

• g) Securities and Exchange Board of India (Issue and Listing of Non-Convertible and Redeemable Preference Shares) Regulations, 2013; (Not applicable to the company during the review period)

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

• i) Securities and Exchange Board of India(Depositories and Participant) Regulations, 2018; and circulars/ guidelines issued thereunder;

and based on the above examination, and considering the relaxations granted by the Ministry of Corporate Affairs and Securities and Exchange Board of India warranted due to the spread of the COVID-19 pandemic, We 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:-

Sr. No.	Compliance Requirement (Regulations / circulars/ guidelines including specific clause)	Deviations	Observations/ Remarks of the Practicing Company Secretary
Not Applicable

• b) The listed entity has maintained proper records under the provisions of the above Regulations and circulars/ guidelines issued thereunder in so far as it appears from 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 taken by	Details of violation	Details of action taken E.g. fines, warning letter, debarment, etc.	Observations/ remarks of the Practicing Company **Secretary, if any. **
Not Applicable

Continuation Sheet

• d) The listed entity has taken the following actions to comply with the observations made in previous reports:

Sr. No.	Observations of the Practicing Company Secretary in the previous reports	Observations made in the secretarial compliance report for the year ended ………. (The years are to be mentioned)	Actions taken by the listed entity, if any	Comments of the Practicing Company Secretary on the actions taken by the listed entity
Not Applicable

For Parikh & Associates Digitally signed by P N Parikh DN: c=IN, o=Personal, postalCode=400104, st=Maharashtra, 2.5.4.20=02a59473a64d87ecbddfe0a8e3ad7 0b06b16d5d30bb138b26dcc8c4b693f8ed1, serialNumber=e6a5dfe9f9f1e9732378e1984 serialNumber=e6a5dfe9f9f1e9732378e1984 97c9be1a9a5543aafae294fe7c98b0c5e69c2f c, cn=P N Parikh Date: 2021.05.05 19:53:31 +05'30'

2.5.4.20=02a59473a64d87ecbddfe0a8e3ad7 Place: Mumbai P N Parikh 0b06b16d5d30bb138b26dcc8c4b693f8ed1, serialNumber=e6a5dfe9f9f1e9732378e1984 97c9be1a9a5543aafae294fe7c98b0c5e69c2f c, cn=P N Parikh Signature: Date: 2021.05.05 19:53:31 +05'30' Date: May 05, 2021 Name of the Practicing Company Secretary: P.N. Parikh FCS No.:327 C P No.:1228 UDIN: F000327C000242437