Pfizer Ltd. — Regulatory Filings 2021

May 27, 2021

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Pfizer Limited

The Capital, 1802/1901, Plot No. C - 70, G Block, Bandra Kurla Complex, Bandra (East), Mumbai 400 051. Tel : +91 22 6693 2000 Fax : +91 22 2654 0274

May 27, 2021

The Corporate Relationship Dept. The Manager, Listing Dept. BSE Limited The National Stock Exchange of India Ltd. 1[st] Floor, P.J.Towers Exchange Plaza, 5[th] Floor, Dalal Street, Fort Plot No. C/1, G Block Mumbai - 400 001 Bandra-Kurla Complex, Bandra (E) Scrip Code: 500680 Mumbai - 400 051 Scrip Symbol: PFIZER

Dear Sirs,

Sub: Compliance under Regulation 24(A) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015

In terms of Regulation 24(A) of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015, please find enclosed, Secretarial Compliance Report for the year ended March 31, 2021, issued by Mr. K. G. Saraf, Practicing Company Secretary.

We request you to kindly take the above on record.

Thanking you,

Yours truly,

For Pfizer Limited

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Prajeet Nair Company Secretary

CIN: L24231MH1950PLC008311 Email ID: contactus.india@pfizer.com Website: www.pfizerindia.com

Secretarial Compliance Report of Pfizer Limited For the Financial Year Ended 31[st] March 2021 (Pursuant to SEBI- CIR/CFD/CMD/1/27/2019 Dated February 8, 2019)

I Mr. K.G. Saraf, Practicing Company Secretary (FCS No. 1596, Certificate of Practice No. 642) have examined:

• (a) all the documents and records made available to us and explanation provided by Pfizer 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[st] March 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 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) Regulations, 2014; (Not applicable for the period under review)

1 Saraf and Associates (Company Secretaries)

SECRETARIAL COMPLIANCE REPORT – PFIZER LIMITED 2021

• (f) Securities and Exchange Board of India (Issue and Listing of Debt Securities) Regulations, 2008; (Not applicable for the period under review)

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

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

• (i) The Securities and Exchange Board of India (Registrars to an Issue and Share Transfer Agents) Regulations, 1993 regarding the Companies Act and dealing with client;

• (j) The Securities and Exchange Board of India (Depositories and Participant) Regulations, 2018;

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 :-

Sr.No	Compliance Requirement		Deviations			Observations/Remarks of the
	(Regulations/ circulars / guidelines					Practicing Company Secretary
	including specific clause)
	NIL

• (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 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:

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Sr.No Action taken by Details of Details of action Observations/
Violation taken E.g. fines, remarks of the
warning letter, Practicing
debarment, etc. Company
Secretary, if any
Not Applicable
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• (d) The listed entity has taken the following actions to comply with the observations made in previous reports:

2 Saraf and Associates (Company Secretaries)

SECRETARIAL COMPLIANCE REPORT – PFIZER LIMITED 2021

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Sr.No Observations of the Observations Actions taken Comments of the
Practicing Company made in the by the listed Practicing
Secretary in the secretarial entity, if any Company
previous reports compliance Secretary on the
report for the actions taken by
year ended the listed entity
2019-20
Not Applicable
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For Saraf & Associates Place : Mumbai Practising Company Secretaries KAMALAX Digitally signed by KAMALAX Date : 26.05.2021 GANAPAYYA GANAPAYYA SARAF Date: 2021.05.26 20:58:16 SARAF +05'30' UDIN : F001596C000375717

K.G. SARAF Proprietor FCS: 1596 | CP: 642 FRN. S1988MH004801 PR. 1003/2020

3 Saraf and Associates (Company Secretaries)