Pfizer Ltd. — Regulatory Filings 2025

May 23, 2025

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 23, 2025

The Corporate Relationship Dept. BSE Limited 1 st Floor, P.J.Towers Dalal Street, Fort Mumbai – 400 001 Scrip Code: 500680

The Listing Dept. The National Stock Exchange of India Ltd. Exchange Plaza, 5th Floor, Plot No. C/1, G Block Bandra-Kurla Complex, Bandra (E) Mumbai – 400 051 Scrip Symbol: PFIZER

Dear Sir/Madam,

Sub: Annual Secretarial Compliance Report for the financial year ended March 31, 2025.

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

Pursuant to Regulation 24(A) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, we submit herewith the Annual Secretarial Compliance Report for financial year ended March 31, 2025, issued by M/s. Parikh & Associates, Practicing Company Secretaries.

Kindly take the same on record.

Yours truly, For Pfizer Limited

Prajeet Nair Digitally signed by Prajeet Nair Date: 2025.05.23 12:55:08 +05'30'

Prajeet Nair Director – Corporate Services & Company Secretary

Encl.: A/a

Secretarial Compliance Report of Pfizer Limited for the year ended March 31, 2025

To, Pfizer Limited The Capital, 1802 / 1901, Plot No. C-70, G Block, Bandra Kurla Complex, Bandra (East), Mumbai 400051

We, Parikh & Associates have examined:

• a) all the documents and records to the extent made available to us and explanations and representations provided by Pfizer Limited ("the listed entity"/ "Company"),
• 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, 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) the Securities Contracts (Regulation) Act, 1956 ("SCRA"), rules made thereunder and the Regulations, circuhu-s, guidelines issued thereunder by the Securities and Exchange Board of India ("SEBI");

The specific Regulations (including amendments, modifications from time to time), whose provisions and the circulars/ guidelines issued thereunder, have been examined, include:-

• a) The Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 and amendments from time to time;
• b) The Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 and amendments from time to time; (Not applicable to the company during the review period)
• c) The Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
• d) The Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (Not applicable to the company during the review period)
• e) The Securities and Exchange Board of India (Share Based Employee Benefits and Sw~ 'i>ASso0 Equity) Regulations, 2021; (Not applicable to the company during the review period)~+ ~.A ^~*t1* ⁰

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Office: 111, 11th Floor, Sai-Dwar CHS Ltd,SAB 1V Lane, Opp Laxmi Industrial Estate, Off Link Road, Above Shabari Restaurant, Andheri (West). Mumbai : 400 053.

Tel. : 26301232 / 26301233 Email : cs@parikhassociates.comWebsite: www.parikhassociates.com Firm Unqiue Code: P1988MH009800

• f) The Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021; (Not applicable to the company during the review period)
• g) The Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015;
• h) The 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,

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.	nee Require ment (Regulati ons/ circulars/ guideline s including specific clause)	Complia Regulati on/ Circular No.	Deviatio Actio Type ns	n	Action Take (Advisory/ Violatio n by ~ larificatio In/ Fine /Show Cause Notice/ Warning, etc.)	ol Details of n	Fine Amou nt	Observatio Manageme Remar ns/ Remarks of the Practicing Company Secretary	nt Response	ks
					NIL

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

No. Remarks of the Practicing Company Secretary in reports	Sr. Observation5i Observations made in the secretarial compliance report for the the previous vearended (the years are to be mentioned)	Compliance Requirement (Regulatiom;/circulars / guidelines including specific clause)	Details of violation/ deviations and actions taken/ taken by penalty imposed, if any, on the listed entity	if any, entity	iRemedia Comments actions, of the PCS on the actions the listed taken by the listed entity
		NIL

(c) we 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 VRemarks 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.	Ado12tion and timelx u12dation of the Policies: ► All applicable policies under SEBI Regulations are adopted with the approval of board of directors of the listed entities. • All the policies are in conformity with SEBI Regulations and has been reviewed & timely updated as per the regulations/ circulars/ guidelines issued by SEBI	YES
3.	Maintenance and disclosures on Website: • The Listed entity is maintaining a functional website • Timely dissemination of the documents/ information under a separate section on the website • Web-links provided in annual corporate governance reports under Regulation 27(2) are accurate and specific which re- directs to the relevant document(s)/ section of the website	YES
4.	Disqualification of Director: None of the Directors of the Company are disqualified under Section 164 of Companies Act, 2013	YES
5.	Details related to Subsidiaries of listed entities: (a)ldentification of material subsidiary companies (b)Requirements with respect to disclosure of material as well as other subsidiaries	NA	The Company does tnot have a subsidiary

Continuation Sheet

6.	Preservation of Documents: The listed entity is preserving and maintaining records as prescribed under SEBI Regulations and disposal of records as per Policy of Preservation of Documents and Archival policy prescribed under SEBI LODR Regulations, 2015	YES
7.	Performance Evaluation: The listed entity has conducted performance evaluation of the Board, Independent Directors and the Committees at the start of every financial year/ during the financial year as prescribed in SEBI Regulations	YES
8.	Related Party Transactions: (a) The listed entity has obtained prior approval of Audit Committee for all Related party transactions b) In case no prior approval obtained, the listed entity shall provide detailed reasons along with confirmation whether the transactions were subsequently approved/ ratified/ rejected by the Audit committee	YES
9.	Disclosure of events or information: The listed entity has provided all the required disclosure(s) under Regulation 30 alongwith Schedule III of SEBI LODR Regulations, 2015 within the time limits prescribed thereunder	YES
10.	Prohibition of Insider Trading: The listed entity is in compliance with Regulation 3(5) & 3(6) of SEBI (Prohibition of Insider Tradin2:) Regulations, 2015	YES
11.	Actions taken by SEBI or Stock Exchange(s}, if any: No Actions taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under SEBI Regulations and circulars/ guidelines issued thereunder	YES

Continuation Sheet

12.	ResiOTiation of statutory auditors from the isted entitv or its material subsidiaries	NA	There was no !resignation of auditors lduring the year
	In case of resignation of statutory auditor from the listed entity or any of its material subsidiaries during the financial year, the
	listed entity and/ or its material subsidiary(ies) has/ have complied with paragraph 6.1 and 6.2 of section V-O of chapter V of the Master Circular on compliance with the provisions of the SEBI LODR Regulations, 2015 by listed entities
13.	No Additional Non-comnliances. if anv: No additional non-compliance observed for ~y of the SEBI 1regulations/ circular/ guidance note etc. ~xcept as reported above	YES

*Observations/Remarks by PCS are mandatory if the Compliance status is provided as 'No' or 'NA'

We further, report that the listed entity is in compliance/ not in compliance with the disclosure requirements of Employee Benefit Scheme Documents in terms of regulation 46(2) (za) of the LODR Regulations. Not Applicable

Assumptions & Limitation of scope and Review:

• 1. Compliance of the applicable laws and ensuring the authenticity of documents and information furnished, are the responsibilities of the management of the listed entity.
• 1. Our responsibility is to certify based upon our examination of relevant documents and information. This is neither an audit nor an expression of opinion.
• 1. We have not verified the correcb1ess and appropriateness of financial Records and Books of Accounts of the listed entity.
• 1. This Report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 and is neither an assurance as to the future viability of the listed entity nor of the efficacy or effectiveness with which the management has conducted the affairs of the listed entity.
• 1. It is the responsibility of the Company's management to maintain records and establish appropriate systems for ensuring compliance with applicable SEBI Regulations, circulars, and guidelines issued from time to time and to ensure the adequacy and operational effectiveness of such systems.
• 1. The a udit was conducted in accordance with the Guidance Note on Annual Secretarial Compliance Report issued by the Institute of Company Secretaries of India (ICSI), involving such examinations and verifications as deemed necessary and adequate for the purpose.

Place: Mumbai

Date: 19.05.2025

• tu ~ / 1gna re: f the Practicing Company Secretary: igyasa N. Ved

For Parikh & Associates

FCS No.: 6488 CPNo.: 6018 UDIN: F006488G000372691 PR No.: 6556/2025