BASF INDIA LIMITED

POLICY FOR DETERMINATION OF MATERIALITY

The Board of Directors of BASF India Limited (BIL) has adopted the following policy for
determination of Materiality of events or information for the purpose of disclosure to the Stock
Exchanges.

Definitions:

“Board” means Board of Directors of the Company.

“Company” means BASF India Limited or BIL.

“Key Managerial Personnel or KMP” means Key Managerial Personnel as defined under the
Companies Act, 2013 and includes:

a) Managing Director or Chief Executive Officer or manager and in their absence, a Whole-time
Director
b) Chief Financial Officer; and
c) Company Secretary;

“Materiality in relation to an event or information of the Company means:-

- Event or information provided in Para A of Part A of Schedule III of SEBI (Listing
Obligations and Disclosure Requirements) Regulations, 2015 including any statutory
modifications(s) or amendment(s) thereof, from time to time; and
- omission of which is likely to result in discontinuity or alteration of event or information
already available publicly; or
- omission of which is likely to result in significant market reaction if the said omission
came to light at a later date; or
- an event/information which in the opinion of the Board is considered material.”

Purpose:

This policy provides guidance to the Board, KMP and Management of BIL on the assessment of
materiality in events / information for the purpose of making a timely and accurate disclosure of
all material matters including financial situation, performance, ownership and governance of the
Company.

Guidance Factors

a) Quantitative Factors

Any event or aggregate of events is considered material if the impact of transaction(s) during the
financial year exceeds or likely to exceed 10% of the annual turnover of the Company as per the
last audited financial statement of the Company.
b) Qualitative Factors

• The nature of Company’s business;

• Statutory requirements under the Companies Act, 2013 and rules made thereunder and
the SEBI (Listing Obligations and Disclosure Requirement) Regulations, 2015
• Inherent and control risks associated with the Company’s business.
• Transactions which are not in the ordinary course of business.

The Managing Director, Chief Financial Officer and Director-Legal, General Counsel & Company
Secretary shall have the authority to assess the materiality of the event considering the above
qualitative and quantitative factors or any other parameters that they deemed fit for the purpose
of making disclosure of such event / information to the Stock Exchanges.

Equal treatment of Disclosure:

The material events/information shall not be disclosed to selected investors or other

interested parties before it is released to the public. Certain narrow exceptions may be
permitted in this regard to allow communications with advisers or, in the ordinary course of
business, communications with persons with whom the Company is negotiating, or intends to
negotiate, a commercial, financial or investment transaction or representatives of its
employees acting on their behalf. In all these cases, the recipients shall have a duty to keep
the information confidential.

Procedure for Annual Review

The Managing Director, Chief Financial Officer and Director-Legal, General Counsel (South Asia)
& Company Secretary will be responsible for conducting an annual review and making a
recommendation to the Board, regarding any changes in the policy.

Contact details of KMPs are as under:

Names & Designations Contact details

Mr. Narayan Krishnamohan, Managing narayan.krishnamohan@basf.com

Director, BASF India Limited

Mr.Narendranath J.Baliga, Vice President- narendranath.baliga@basf.com

Finance & Corporate Processes, South Asia

Mr.Pradeep Chandan, Director-Legal, pradeep.chandan@basf.com

General Counsel (South Asia) & Company
Secretary

The Policy as amended from time to time shall be published / posted in the website of the
Company i.e. www.basf.com/in