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Corporate

governance for
listed entities -
Are you ready
for the change?

June 2018

KPMG.com/in
1

An introduction About this publication


To improve standards of corporate governance of listed This publication incorporates the new requirements to
entities in India, on 5 October 2017, the Securities and be complied by the listed entities along with effective
Exchange Board of India (SEBI) released for comments dates based on the amendments made to the Listing
the report of its committee on corporate governance Regulations.
(the Kotak Committee)1.
The publication has been designed in a questionnaire-
The recommendations in the report covered several based  format. Listed entities could assess their
areas, including the composition, role and functioning preparedness towards the change by responding to
of the board and its committees, oversight of group each stated question.
entities and related party transactions, promoter
The questions are structured in a manner that a ‘yes’
related arrangements, enhancing transparency and
response generally indicates compliance, and a
disclosures, strengthening the financial reporting
‘no’ would generally indicate non-compliance. If the
and audit oversight functions, investor engagement
guidance or nature of a particular requirement does not
and participation, and governance in public sector
apply to an entity, an ‘NA’ response should be inserted.
enterprises.
On 28 March 2018, SEBI considered the
recommendations of the Kotak Committee and
the public comments on them. Accordingly, they
accepted certain recommendations without
modifications, few with modifications and referred
certain recommendations to various agencies (i.e.
government, other regulators, professional bodies,
etc.) since the matters involved those agencies2.
On 9 May 2018, SEBI issued amendments to the SEBI
(Listing Obligations and Disclosure Requirements)
Regulations, 2015 (Listing Regulations) to give effect 1. The committee was formed on 2 June 2017 under the chairmanship of Uday Kotak.
to many of the approved recommendations3. Certain 2. SEBI press release no. PR No. 09/2018 dated 28 March 2018 and SEBI memorandum
recommendations required SEBI to issue guidelines issued in April 2018.

in the form of a circular. Accordingly, on 10 May 2018, 3. SEBI notification no. SEBI/LAD-NRO/GN2018/10 dated 9 May 2018.

SEBI issued a circular and provided the required 4. SEBI circular no. SEBI/HO/CFD/CMD/CIR/P/2018/79 dated 10 May 2018.

guidance4.

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2

© 2018 KPMG, an Indian Registered Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
3

Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
Change applicable from 9 May 2018
Website
Has the listed entity ensured compliance with the following disclosure
1. 36(4)
requirements?
a. For disclosures on its website: In a format that allows users to find
M5
relevant information easily through a searching tool
(Note: The requirement to make disclosures in searchable formats shall
not apply in case there is a statutory requirement to make such disclosures
in formats which may not be searchable, such as copies of scanned
documents.)
b. For disclosures to stock exchange: In XBRL format in accordance
with the guidelines specified by the stock exchanges from time to M
time.

Changes applicable from 10 May 2018


Disclosures on board evaluation
2. a. Has the listed entity provided disclosures on board evaluation? SEBI
circular6
V7
b. Has it considered following disclosures relating to board evaluation?
i. Observations of board evaluation carried out for the year V
ii. Previous year’s observations and actions taken V
iii. Proposed actions based on current year observations. V
Group governance
3. Where a listed entity has multiple unlisted subsidiaries, has the listed
entity considered the following?
a. Monitors their governance through a dedicated group governance
unit or Governance Committee which comprises the members of its V
board of directors
b. Established a strong and effective group governance policy. V
(Note: The decision of setting up of such a unit/committee or to have such a
policy would lie with the board of directors of the listed entity.)
4. Has the listed entity provided its medium-term and long-term strategy SEBI
(based on a time frame as determined by its board of directors) within circular
the limits set by its competitive position? V
(Note: This disclosure will form part of the management, discussion and analysis
in a listed entity’s annual report. Additionally, the listed entity may articulate a
clear set of long-term metrics specific to the company’s long term strategy to
allow for appropriate measurement of progress.)

Changes applicable from 1 October 2018


Eligibility criteria for independent directors
5. Do the independent directors of the listed entity fulfil the following
16(1)(b)
additional criteria?
a. He/she is or was not a member of the promoter group of the listed
M
entity
5. Mandatory requirement
6. SEBI circular no. SEBI/HO/CFD/CMD/CIR/P/2018/79 dated 10 May 2018
7. Voluntary requirement

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Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
b. He/she is not a non-independent director of another company on the
board of which any non-independent director of the listed entity is an M
independent director (board inter-lock).
Alternate directors for independent directors
6. Has the listed entity ensured that an alternate director has not been 25(1)
appointed for an independent director? M
Directors and Officers Insurance (D&O) for independent directors
7. Has the listed entity undertaken a D&O insurance for all its independent 25(10)
directors? M
(Note:
i. This is applicable to top8 500 listed entities.
ii. The quantum and the risk to be covered under D&O insurance would be as
determined by its board of directors.)
Website
8. a. Has the listed entity disclosed credit ratings obtained for all its 46(2)(r)
outstanding instruments on its website? M
b. In case of any revision in such credit ratings, has the entity updated
M
them immediately on the website?
Prior intimation of board meeting to discuss bonus issue
9. Has the listed entity provided prior intimation to stock exchange
about the meeting of the board of directors in which the proposal
29(1)(f)
for declaration of bonus securities (communicated to the board of
M
directors of the listed entity as part of the agenda papers) is due to be
considered?

Changes applicable from half-year ending 31 March 2019


Related party transactions
10. Has the listed entity submitted disclosures of related party transactions
on a consolidated basis within 30 days of publication of its stand-
23(9)
alone and consolidated financial results for the half year in the format
M
prescribed in the relevant AS/Ind AS for annual results, to the stock
exchanges?
(Note:
i. This is applicable from the half year ending 31 March 2019.
ii. In case of non-compliance, strict penalties may be imposed by SEBI.)

Changes applicable from the year ended 31 March 2019


Secretarial audit
11. a. Has the listed entity and its material unlisted subsidiaries
24A
(incorporated in India) ensured that a secretarial audit been
M
undertaken?
b. If answer to Q 11(a) is yes, does the annual report of the listed entity
include a secretarial audit report given by a company secretary in M
practice (in such form as may be specified)?

8. Relevant top entities to be determined on the basis of market capitalisation as at the end of immediate previous financial year.

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Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
Annual report
12. Has the listed entity disclosed transactions of the listed entity with Schedule
any person or entity belonging to the promoter/promoter group which V – Part A -
hold(s) 10 per cent or more shareholding in the listed entity in the 2A
format prescribed in the relevant AS for annual results? M
(Note: This disclosure would be given in related party transactions section of the
annual report.)
13. Has the listed entity also provided the following disclosures in the Schedule V
management, discussion and analysis section of the annual report? – Part B – 1
a. Details of significant changes (i.e. change of 25 per cent or more as
compared to the immediately previous financial year) in key financial M
ratios, along with detailed explanations therefor, including:
i. Debtors turnover
ii. Inventory turnover
iii. Interest coverage ratio
iv. Current ratio
v. Debt equity ratio
vi. Operating profit margin (%)
vii. Net profit margin (%)
b. Details of any change in return on net worth as compared to the
immediately previous financial year along with a detailed explanation M
thereof.
14. Has the listed entity also provided following disclosures in the corporate
governance section of the annual report?
Board of directors
a. Details of names of the listed entities where the person is a director Schedule
and the category of directorship. V – Part C –
2(c)
M
b. List of core skills/expertise/competence identified by the board of Schedule
directors in the context of the business(es) and sector(s) and those V – Part C –
actually available with the board. 2(h)
M
c. Confirmation that in the opinion of the board, the independent Schedule
directors fulfil the conditions specified in the Listing Regulations and V – Part C –
are independent of the management. 2(i)
M
d. Detailed reasons for resignation of an independent director before Schedule
the expiry of his/her tenure along with a confirmation by such V – Part C –
director that there are no other material reasons other than those 2(j)
provided. M
General shareholders’ information - credit ratings
a. List of all credit ratings obtained by the listed entity along with
Schedule
any revisions thereto during the relevant financial year, for all debt
V – Part C –
instruments of such entity or any fixed deposit programme or any
9(q)
scheme or proposal of the listed entity involving mobilisation of
M
funds, whether in India or abroad.

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Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
Other disclosures
a. Details of utilisation of funds raised through preferential allotment or Schedule
qualified institutions placement as specified under Regulation 32(7A) V – Part C –
of the Listing Regulations. 10(h)
M
b. A certificate from a company secretary in practice that none of
Schedule
the directors on the board of the company have been debarred
V – Part C –
or disqualified from being appointed or continuing as directors of
10(i)
companies by the SEBI/Ministry of Corporate Affairs (MCA) or any
M
such statutory authority.
c. Details of recommendations mandatorily required by any committee Schedule
of the board in the relevant financial year that have not been V – Part C –
accepted by the board, along with reasons thereof. 10(j)
M
(Note: This would apply where recommendation of/submission by the
committee is required for the approval of the board of directors and shall
not apply where prior approval of the relevant committee is required for
undertaking any transaction under the Listing Regulations.)
d. The total fees for all services paid by listed entity and its subsidiaries Schedule
(i.e. on a consolidated basis) to the statutory auditor and all entities V – Part C –
in the network firm/network entity of which the auditor is a member. 10(k)
M
15. a. Has the listed entity sent a copy of the annual report to the
shareholders along with the notice of the Annual General Meeting 34(1)(a)
(AGM) not later than the day of commencement of dispatch to its M
shareholders?
b. In case shareholders approve any amendments to any portion of the
annual report, has a revised copy (with details of and explanation for 34(1)(b)
the changes so approved) been sent not later than 48 hours after the M
AGM?
c. While sending the copy of annual report, has the listed entity sent
36(1)(a)
soft copies of full annual report to all those shareholder(s) who have
M
registered their email address(es) even with any depository?
Timeline for AGMs
16. Does the listed entity comply with the following requirements relating
to AGMs?
a. To hold AGMs within five months from the date of closing of the 44(5)
financial year M
b. One-way live webcast of the proceedings of the AGMs. 44(6)
M
(Note: This is applicable to top 100 listed entities from 1 April 2019)

Changes applicable from 1 April 2019


Minimum number of directors on board
17. Are there at least six directors on the board of directors of the listed 17(1)(b)
entity? M
(Note: This is applicable to top 1,000 listed entities.)
Gender diversity on the board
18. Does the composition of the board of directors of the listed entity 17(1)(a)
consist of at least one independent woman director? M
(Note: This is applicable to top 500 listed entities.)
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Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
Approval for non-executive directors on attaining a certain age
19. If the listed entity has appointed a person who has attained the age of
75 years as a non-executive director, then has it complied with the two 17(1A)
conditions given below?
a. A special resolution has been passed M
b. An explanatory statement has been annexed to the notice for such
M
motion indicating the justification for appointing such a person.
Quorum for board meetings
20. Has the listed entity ensured that the quorum for every meeting of the
17(2A)
board of directors is one-third of its total strength or three directors,
M
whichever is higher including at least one independent director?
(Note:
i. Participation of the directors by video conferencing or by other audio-visual
means would also be counted for the purposes of such quorum.
ii. This is applicable to top 1,000 listed entities.)
Maximum number of directorships
21. Has the listed entity ensured that a person does not hold office of a
director (including any alternate directorship) at the same time in more 17A
than:
a. Eight listed entities M
b. Out of eight listed entities, a person does not serve as an
M
independent director in more than seven listed entities.
(Note:
i. Any person who is serving as a whole-time director/managing director in any
listed entity would serve as an independent director in not more than three
listed entities.
ii. The count of listed entities on which a person is a director/independent
director would be only those whose equity shares are listed on a stock
exchange.)
Obligations with respect to independent directors
22. Do the independent directors of the listed entity submit a declaration at
25(8)
following occasions?
a. The first meeting of the board of directors in which he/she
M
participates as a director
b. The first meeting of the board of directors in every financial year or M
c. Whenever there is any change in the circumstances which may
M
affect his/her status as an independent director.
d. Have the board of directors of the listed entity taken on record the
above mentioned declaration and confirmation submitted by the 25(9)
independent director(s) after undertaking due assessment of the M
veracity of the same?
(Note: The declaration would contain the following:
i. He/she meets the criteria of independence as provided in Regulation 16(1)(b)
of the Listing Regulations
ii. He/she is not aware of any circumstance or situation, which exist or may be
reasonably anticipated, that could impair or impact his/her ability to discharge
his/her duties with an objective independent judgement and without any
external influence.)

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Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
Evaluation of independent directors
23. Whether performance evaluation of independent directors includes the
following criteria?
a. Performance of the directors M
b. Fulfillment of the independence criteria as specified in the Listing
M
Regulations
c. Their independence from the management. M
Disclosures on resignation of independent directors
24. a. Has the listed entity disclosed the detailed reasons for resignation Schedule
of an independent director before the expiry of his/her tenure within III – Part A –
seven days of resignation to the stock exchange? A(7B)
M
b. Do the independent directors provide confirmation stating that there
M
are no other material reasons other than those provided by him/her?
Audit committee
25. Whether review of utilisation of loans and/or advances from/investment Schedule
by the holding company in the subsidiary exceeding INR100 crore or 10 II - Part C -
per cent of the asset size of the subsidiary, whichever is lower, included A(21)
as a role of an audit committee? M
(Note: The thresholds would include loans/advances/investments existing as on
1 April 2019.)
Nomination and remuneration committee
26. Does the nomination and remuneration committee also recommends Schedule
to the board of directors, all remuneration, in whatever form, payable to II – Part D
senior management? A (6)
M
(Note: Senior management would include all members of management one
level below the CEO/MD/whole time director/manager (including CEO/manager, 16(1)(d)
in case CEO/manager is not part of the board) and specifically include the
company secretary and the chief financial officer.)
27. a. Do the members of the nomination and remuneration committee 19(3A)
meet at least once in a year? M
b. Has the listed entity ensured that the quorum of the meeting of
nomination and remuneration committee is either two members or 19(2A)
one third of the members of the committee, whichever is greater, M
including at least one independent director in attendance?
Stakeholders’ relationship committee

28. Whether the members of the stakeholders’ relationship committee of


20(2A)
the listed entity comprise at least three directors with one being an
M
independent director?
Is the chairperson of the stakeholders’ relationship committee present 20(3)
29.
at the AGM to answer queries of the security holders? M
30. Does the role of the stakeholder’s relationship committee also include Schedule
the following? II – Part D
B(1) – (4)
a. Resolve the grievances of the security holders of the listed entity
M
including issue of new/duplicate certificates, general meetings, etc.
b. Review of measures taken for effective exercise of voting rights by
M
shareholders

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Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
c. Review of adherence to the service standards adopted by the listed
entity in respect of various services being rendered by the registrar M
and share transfer agent
d. Review of the various measures and initiatives taken by the listed
entity for reducing the quantum of unclaimed dividends and ensuring
M
timely receipt of dividend warrants/annual reports/statutory notices
by the shareholders of the company.
(Note: The SRC of every listed entity would specifically look into various aspects
of interests of shareholders, debentureholders and other security holders.)
Do the members of the stakeholders’ relationship committee meet at 20(3A)
31.
least once in a year? M
Risk management committee
32. Has the listed entity constituted a risk management committee? 20(5)
M
(Note: This is applicable to top 500 listed entities.)
33. Does the role of the risk management committee specifically cover 21(4)
cyber security? M
34. Do the members of the risk management committee meet at least 21(3A)
once in a year? M
Obligation on the board of the listed entity with respect to subsidiaries
35. Does the listed entity consider any of its subsidiary to be material? 16(1)(c)
M
(Note: Material subsidiary means a subsidiary whose income or net worth
exceeds 10 per cent of the consolidated income or net worth respectively, of the
listed entity and its subsidiaries in the immediately preceding accounting year.)
36. Has the listed entity appointed at least one of its independent directors
24(1)
on the board of directors of unlisted material subsidiary, for both
M
incorporated in India or outside India?
(Note: Material subsidiary means a subsidiary whose income or net worth
exceeds 20 per cent of the consolidated income or net worth respectively, of
the listed entity and its subsidiaries in the immediately preceding accounting
year.)
37. Do the board of directors of the listed parent also review significant Explanation
transactions and arrangements entered into by all unlisted subsidiaries? to 24(1)
M
Related party transactions
38. Has the listed entity identified as a related party ‘any person or entity
2(1)(zb)
belonging to its promoter or promoter group and holding 20 per cent or
M
more of shareholding in the listed entity’?
39. While obtaining shareholders’ approval for all material related party
transactions, has the listed entity (whether related party to the particular 23(4)
transaction or not) ensured that no related party votes to approve such a M
resolution?
40. Has the listed entity ensured that all the entities falling under the
definition of related parties do not vote to approve the relevant 23(7)
transaction whether the listed entity is a party to the particular M
transaction or not?

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10

Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
41. Has the listed entity considered a transaction involving payments
made to a related party with respect to brand usage or royalty as
material, if the transaction(s) individually or taken together with previous 23(1A)
transactions during a financial year, exceed two per cent of the annual M
consolidated turnover of the listed entity as per the last audited financial
statements of the listed entity?
42. a. While formulating the materiality policy, has the listed entity included 23(1)
clear threshold limits duly approved by its board of directors? M
b. Does the board of directors of the listed entity review its materiality
M
policy at least once every three years and update it accordingly?
Remuneration to executive directors
43. Has the listed entity obtained approval of shareholders through a special
resolution for payment of remuneration to executive directors who are
17(6)(d)
promoters or members of the promoter group, if the payment exceeds
the following threshold:
a. In case of one executive director: annual remuneration payable to
such executive director exceeds INR5 crore or 2.5 per cent of the M
net profits of the listed entity, whichever is higher
b. In case of more than one executive director: aggregate annual
remuneration to such directors exceeds 5 per cent of the net profits M
of the listed entity.
(Note:
i. The approval of the shareholders would be valid only till expiry of term of
such director.
ii. Net profits would be calculated as per Section 198 of the Companies Act,
2013.)
Remuneration to non-executive directors
44. Has the listed entity obtained approval of shareholders by way of special
resolution every year in which the annual remuneration payable to a
17(6)(ca)
single non-executive director exceeds 50 per cent of the total annual
M
remuneration payable to all non-executive directors, giving details of
remuneration thereof?
Audit qualifications
45. In case an auditor has expressed a modified opinion(s) in respect of
Schedule
audited financial results and the impact of such qualification is not
IV – Part A
quantifiable, has the management of the listed entity complied with the
– BB(i)
following?
a. Make an estimate of the qualification M
b. Review the estimate M
c. Reports the estimate. M
46. a. Has the listed entity taken the exception of not quantifying audit Schedule
qualification relating to going concern or sub-judice matters? IV – Part A
– BB(ii)
M
b. If answer to Q 46(a) is yes, then has the management provided
M
reasons for not quantifying those qualifications?
(Note: The auditor would review such reasons and report accordingly.)

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11

Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
Group audits
47. Has the statutory auditor of the listed parent undertaken a limited
review of all the entities/companies whose accounts are to be
consolidated with it as per Accounting Standard (AS) 21, Consolidated 33(8)
Financial Statements, or Indian Accounting Standard (Ind AS) 110, M
Consolidated Financial Statements in accordance with guidelines issued
by the SEBI on this matter?
Quarterly financial disclosures
48. a. In case the listed entity has subsidiaries, in addition to the stand-
33(3)(b)
alone financial results, does the listed entity also submit quarterly
M
and year-to-date consolidated financial results?
b. In case of quarterly consolidated financial results, has the listed
entity ensured that at least 80 per cent of each of the consolidated 33(3)(h)
revenue, assets and profits, respectively, have been subject to audit M
or in case of unaudited results, subjected to limited review?
c. Has the listed entity also submitted a cash flow statement as part of 33(3)(g)
its stand-alone and consolidated financial results for the half-year? M
d. While submitting the last quarter’s results along with the results for
33(3)(e)
the entire financial year, has the listed entity ensured that the last
M
quarter results are either limited reviewed or audited?
e. Has the listed entity disclosed by way of note aggregate effect
33(3)(i)
of material adjustments made in the results of the last quarter
M
pertaining to earlier periods?
Disclosure on reasons of resignation of auditors
49. Has the listed entity disclosed detailed reasons for resignation of an Schedule
auditor as given by the said auditor to the stock exchange immediately III – Part A –
and not later than 24 hours of receipt of such reasons from the auditor? A(7A)
M
Disclosure on audit fees and auditor’s credentials
50. Has the listed entity provided following disclosures in the notice of
the AGM where the auditor(s) is/are proposed to be appointed/re- 36(5)
appointed?
a. Basis of recommendation for appointment including the details in
M
relation to and credentials of the auditor(s) proposed to be appointed
b. Proposed fees payable to the auditor(s) along with terms of M
appointment
c. In case of a new auditor, any material change in the fee payable to
such auditor from that paid to the outgoing auditor along with the M
rationale for such change.
Resolutions to be sent to shareholders with board’s recommendation
51. Does the statement to be annexed to the notice of general meeting (as
referred in Section 102(1) of the Companies Act, 2013) for each item
17(11)
of special business to be transacted at a general meeting also contain
M
the recommendations of the board to the shareholders on each of the
specific items?
Website
52. Has the listed entity maintained a separate section for investors on its
46(2)
website for all the information mandated under Regulation 46(2) of the
M
Listing Regulations?

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12

Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
53. Has the listed entity uploaded separate audited financial statements of
each of its subsidiary in respect of a relevant financial year, at least 21
46(2)(r)
days prior to the date of the AGM which has been called to, inter alia,
M
consider accounts of that financial year the following additional details
on its website?

Changes applicable from 1 April 2020


Minimum number of directors on board
54. Are there at least six directors on the board of directors of the listed 17(1)(b)
entity? M
(Note: This is applicable to top 2,000 listed entities from 1 April 2020.)
Gender diversity on the board
55. Does the composition of the board of directors of the listed entity 17(1)(a)
consists of at least one independent woman director? M
(Note: This is applicable to top 1,000 listed entities from 1 April 2020.)
Separation of the roles of chairperson and Managing Director
(MD)/Chief Executive Officer (CEO)
56. a. Does the listed entity have any identifiable promoters as per the 17(1B)
shareholding pattern filed with stock exchanges? M
b. If answer to Q 56(a) is yes, does the chairperson of such an entity
M
meet both the given conditions?
i. He/she is a non-executive director M
ii. He/she is not related to the MD or the CEO as per the definition
M
of the term ‘relative’ under the Companies Act, 2013.
(Note: This is applicable to top 500 listed entities from 1 April 2020.)
Quorum for board meetings
57. Has the listed entity ensured that the quorum for every meeting of the
17(2A)
board of directors is one-third of its total strength or three directors,
M
whichever is higher including at least one independent director?
(Note:
i. Participation of the directors by video conferencing or by other audio-visual
means shall also be counted for the purposes of such quorum.
ii. This is applicable to top 2,000 listed entities from 1 April 2020.)
Maximum number of directorships
58. Has the listed entity ensured that no person holds office of a director
17A
(including any alternate directorship) at the same time in more than:
a. Seven listed entities M
b. Out of eight listed entities, a person does not serve as an
M
independent director in more than seven listed entities.
(Note:
i. Any person who is serving as a whole-time director/managing director in any
listed entity serves as an independent director in not more than three listed
entities.
ii. The count for the number of listed entities on which a person is a director/
independent director shall be only those whose equity shares are listed on a
stock exchange.)

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13

Regulation Compliance
Sr. No. Particulars
para ref [Yes/No/NA]
Disclosure of expertise/skills of directors
59. Has the listed entity disclosed the skills/expertise/competence of
the board of directors (in the form of a chart or a matrix) along with Schedule
the names of directors who have the skills/expertise/competence V – Part C –
(as listed out by the board of directors as required in the context of 2(h)
its business(es) and sector(s) for it to function effectively and those M
actually available with the board)?
(Note: This is applicable for the annual report for financial year ending 31 March
2020.)

© 2018 KPMG, an Indian Registered Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
14

© 2018 KPMG, an Indian Registered Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
KPMG in India contacts:
Mritunjay Kapur
National Head
Markets and Strategy
Head
Technology, Media and Telecom
T: +91 124 307 4797
E: mritunjay@kpmg.com

Sai Venkateshwaran
Partner and Head
Accounting Advisory Services
T: +91 20 3090 2020
E: saiv@kpmg.com

Pankaj Arora
Partner
Governance Risk and Compliance Services
T: +91 124 336 9462
E: pankaja@kpmg.com

Ruchi Rastogi
Partner
Assurance
T: +91 124 334 5205
E: ruchirastogi@kpmg.com

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The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide
accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one
should act on such information without appropriate professional advice after a thorough examination of the particular situation.

© 2018 KPMG, an Indian Registered Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG
International”), a Swiss entity. All rights reserved.

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