CIRCULAR SEBI/HO/CFD/CFD-PoD-2/P/CIR/2025/35 March 20, 2025 To, All listed entities All the Recognized Stock Exchanges All the Depositories Madam / Sir, Subject: Disclosure of holding of specified securities in dematerialized form

1. Regulation 31 of Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“Listing Regulations”), deals with the disclosure of shareholding pattern and manner of maintaining shareholding in dematerialized format.
2. Accordingly, SEBI vide Master Circular No. SEBI/HO/CFD/PoD2/CIR/P/0155 dated November 11, 2024 (as amended) (“the Circular”), prescribed formats for disclosure of holding of specified securities and shareholding pattern under Annexure 2 of section II-A of chapter II to the Circular.
3. Based on the requests received from Depositories, Stock Exchanges and in the interest of providing further clarity & transparency in the disclosure of shareholding pattern to the investors in the securities market, the Annexure 2 of section II-A of chapter II to the Circular is being partially modified as under: a. Table I-IV of the shareholding pattern has been amended as under: i. details of Non-Disposal Undertaking (‘NDU’), Other encumbrances, if any and total number of shares pledged or otherwise encumbered including NDU shall be disclosed by the listed entities. ii. It is clarified that underlying outstanding convertible securities also includes ESOPs i.e. the existing header of column X as “No. of Shares Underlying Outstanding convertible securities (including Warrants, ESOP etc.) iii. adding one additional column in the existing shareholding pattern format to capture the details of total number of shares on fully diluted basis (including warrants, ESOP, Convertible Securities etc.) b. Table II of the shareholding pattern has been amended as under: i. A footnote has been added to the table II that provides the details of promoter and promoter group with shareholding “NIL”.

The revised formats of the aforementioned are placed at Annexure A. 4. Accordingly, the Master Circular No. SEBI/HO/CFD/PoD2/CIR/P/0155 dated November 11, 2024 stands modified to the extent as stated at paragraph no. 3 above. 5. The Stock Exchanges are accordingly advised to: a. bring the provisions of this circular to the notice of all the companies whose securities are listed in the exchange and also to disseminate the same on the website of the stock exchange. b. make amendments to the relevant bye-laws, rules and regulations for the implementation of the terms of this circular, if necessary. 6. The Depositories are also directed to update their systems to capture the abovementioned changes. 7. This Circular shall come into force with effect from the quarter ending June 30, 2025. 8. This Circular is issued in exercise of powers conferred under Section 11(1) of the Securities and Exchange Board of India Act, 1992 read with Regulation 31 and 101(2) of Listing Regulations. 9. A copy of this Circular is available at www.sebi.gov.in under the categories “Legal FrameworkCirculars”. Yours faithfully, Raj Kumar Das Deputy General Manager Corporation Finance Department Policy and Development-2 +91-22-26449253 rajkd@sebi.gov.in

Annexure A Table I - Summary Statement showing holding of specified securities of the listed entity Category (I) Category of shareholder (II) No. of shareh older (III) No. of fully paid up equity shares held (IV) Partly paid￾up equity shares held (V) No. of shares underlyi ng Deposit ory Receipts (VI) Total no. shares held (VII) = (IV)+(V) +(VI) Shareholdi ng as a % of total no. of shares (calculated as per SCRR, 1957) As a % of (A+B+C2) (VIII) Number of Voting Rights held in each class of securities (IX) No. of Shares Underly ing Outstan ding converti ble securiti es (includi ng Warrant s, ESOP etc.) (X) Total No of shares on fully diluted basis (including warrants, ESOP, Convertibl e Securities etc.) (XI)=(VII+X) Shareholdi ng, as a % assuming full conversion of convertible securities (as a percentage of diluted share capital) (XII) = (VII)+(X) As a % of (A+B+C2) Number of Locked in shares (XIII) Number of Shares pledged (XIV) Non￾Disposal Undertaking (XV) Other encumbrances, if any (XVI) Total Number of Shares encumbered (XVII) = (XIV+XV+XVI) Number of equity shares held in dematerialized form (XVIII) No of Voting Rights Total as a % of (A+B +C) Class eg: X Class eg: Y To tal No. (a) As a % of total Share s held (b) No. (a) As a % of total share s held (b) No . (a) As a % of total shar es held (b) No . (a) As a % of total shares held (b) N o . ( a ) As a % of total shares held (b) (A) Promoter & Promoter Group (B) Public NA (C) Non Promoter￾Non Public NA (C1) Shares underlying DRs NA NA (C2) Shares held by Employee Trusts NA Total

Table II - Statement showing holding of specified securities by the Promoter and Promoter Group Category & Name of the Shareholders (I) Entity type Promoter or Promoter group (Promoter group would exclude promoter s) (II) PAN (III) No. of share holder (IV) No. of fully paid up equity shares held (V) Partly paid￾up equit y share s held (VI) No. of shares underlyin g Depositor y Receipts (VII) Total no. shares held (VIII = V+VI+ VII) Sharehold ing % calculate d as per SCRR, 1957 As a % of (A+B+C2) (IX) Number of Voting Rights held in each class of securities (X) No. of Shares Underlyin g Outstandi ng convertib le securities (includin g Warrants, ESOP etc.) (XI) Total No of shares on fully diluted basis (including warrants, ESOP, Convertibl e Securities etc.) (XII)=(VIII+ XI) Total shareholdi ng, as a % assuming full conversio n of convertibl e securities (as a percentag e of diluted share capital) (XIII) = (VIII)+(XI) as a % of A+B+C2 Number of Locked in shares (XIV) Number of Shares pledged (XV) Non￾Disposal Undertakin g (XVI) Other encumbra nces, if any (XVII) Total Number of Shares encumbered (XVIII) = (XV+XVI+XVII) Number of equity shares held in demateri alized form No of Voting (XIX) Rights Total as a % of Total Votin g right s Clas s X Clas s Y Tota l No. (a) As a % of total Share s held (b) No. (a) As a % of total share s held (b) N o . ( a ) As a % of total shar es held (b) N o. (a ) As a % of tot al sh ar es he ld (b) No . (a) As a % of total shares held (b) (1) Indian (a) Individuals/H indu undivided Family Name (xyz…) (b) Central Government/ State Government( s) Name (xyz…) (c) Financial Institutions/ Banks Name (xyz…) (d) Any Other (specify) Name (xyz…)

Sub-Total (A)(1) (2) Foreign (a) Individuals (Non￾Resident Individuals/ Foreign Individuals) Name (xyz…) (b) Government Name (xyz…) (c) Institutions Name (xyz…) (d) Foreign Portfolio Investors Name (xyz…) (e) Any Other (specify) Name (xyz…) Sub-Total (A)(2) Total Shareholdin g of Promoter and Promoter Group (A)= (A)(1)+(A)(2) Details of Shares which remain unclaimed may be given here along with details such as number of shareholders, outstanding shares held in demat/unclaimed suspense account, voting rights which are frozen etc.

Note:
1) PAN would not be displayed on website of Stock Exchange(s).
2) The term “Encumbrance” has the same meaning as assigned under SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011, as amended from time to time.
3) Details of promoter and promoter group with shareholding “NIL” can be accessed from here.

Table III - Statement showing holding of specified securities by the Public shareholders Category & Name of the Shareholders (I) PAN (II) No. of shareh older (III) No. of fully paid up equity shares held (IV) Partly paid-up equity shares held (V) No. of shares underly ing Deposit ory Receipt s (VI) Total no. shares held (VII =IV+V+ VI) Shareholdi ng % calculated as per SCRR, 1957 As a % of (A+B+C2) (VIII) Number of Voting Rights held in each class of securities (IX) No. of Shares Underlyi ng Outstand ing converti ble securitie s (includin g Warrants , ESOP etc.) (X) Total No of shares on fully diluted basis (includin g warrants , ESOP, Converti ble Securitie s etc.) (XI)=(VII+ X) Total sharehold ing, as a % assuming full conversio n of convertibl e securities (as a percentag e of diluted share capital) (XII) Number of Locked in shares (XIII) Number of Shares pledged (XIV) Non￾Disposal Undertak ing (XV) Other encumbr ances, if any (XVI) Total Number of Shares encumbere d (XVII) = (XIV+XV+X VI) Number of equity shares held in dematerialize d form (XVIII) Sub-categorization of shares (XIX) No of Voting Rights Total as a % of Total Votin g right s Shareholding (No. of shares) under Cla ss X Cl as s Y To tal No . (a) As a % of total Shar es held (b) No . (a) As a % of total shar es held (b) N o. (a ) A s a % o f t o t a l s h a r e s h e l d ( b ) N o . ( a ) As a % of tot al sh ar es hel d (b) N o . ( a ) As a % of total shar es held (b) Sub￾cate gory (i) Sub￾cate gory (ii) Sub￾cate gory (iii) (1) Institutions (Domestic) NA (a) Mutual Funds NA Name (Xyz) NA (b) Venture Capital Funds NA Name (Xyz) NA (c) Alternate Investment Funds NA Name (Xyz) NA (d) Banks NA Name (Xyz) NA (e) Insurance Companies NA Name (Xyz) NA (f) Provident / Pension Funds NA

Page Name (Xyz) NA (g) Asset Reconstruction Companies NA Name (Xyz) NA (h) Sovereign Wealth Funds NA Name (Xyz) NA (i) NBFCs registered with RBI NA Name (Xyz) NA (j) Other Financial Institutions NA Name (Xyz) NA (k) Any Other (specify) NA Name (Xyz) NA Sub -Total B(1) NA (2) Institutions (Foreign) NA (a) Foreign Direct Investment NA Name (Xyz) NA (b) Foreign Venture Capital Investors NA Name (Xyz) NA (c) Sovereign Wealth Funds NA Name (Xyz) NA (d) Foreign Portfolio Investors Category I NA Name (Xyz) NA (e) Foreign Portfolio Investors Category II NA Name (Xyz) NA (f) Overseas Depositories (holding DRs) (balancing figure) NA Name (Xyz) NA

Page (g) Any Other (specify) NA Name (Xyz) NA Sub -Total B(2) NA (3) Central Government / State Government(s ) NA (a) Central Government / President of India NA Name (Xyz) NA (b) State Government / Governor NA Name (Xyz) NA (c) Shareholding by Companies or Bodies Corporate where Central / State Government is a promoter NA Name (Xyz) NA Sub -Total B(3) NA (4) Non - institutions NA (a) Associate companies / Subsidiaries NA Name (Xyz) NA (b) Directors and their relatives (excluding independent directors and nominee directors) NA Name (Xyz) NA (c) Key Managerial Personnel NA Name (Xyz) NA (d) Relatives of promoters (other than ‘immediate relatives’ of NA

promoters disclosed under ‘Promoter and Promoter Group’ category) Name (Xyz) NA (e) Trusts where any person belonging to 'Promoter and Promoter Group' category is 'trustee', 'beneficiary', or 'author of the trust' NA Name (Xyz) NA (f) Investor Education and Protection Fund (IEPF) NA Name (Xyz) NA (g) Resident Individuals holding nominal share capital up to Rs. 2 lakhs NA Name (Xyz) NA (h) Resident Individuals holding nominal share capital in excess of Rs. 2 lakhs NA Name (Xyz) NA (i) Non Resident Indians (NRIs) NA Name (Xyz) NA (j) Foreign Nationals NA Name (Xyz) NA (k) Foreign Companies NA Name (Xyz) NA (l) Bodies Corporate NA Name (Xyz) NA

(m) Any Other (specify) NA Name (Xyz) NA Sub-Total (B)(4) NA Total Public Shareholding (B) = (B)(1) + (B)(2) + (B)(3)

• B(4) NA Details of the shareholders acting as persons in Concert including their Shareholding (No. and %): Details of Shares which remain unclaimed may be given here along with details such as number of shareholders, outstanding shares held in demat/unclaimed suspense account, voting rights which are frozen etc. Note: (1) PAN would not be displayed on website of Stock Exchange(s). (2) The above format needs to be disclosed along with the names of the shareholders holding 1% or more than 1% of shares of the listed entity. Columns no. (XIV) to (XVII) are not applicable in the above format. (3) W.r.t. the information pertaining to Depository Receipts, the same may be disclosed in the respective columns to the extent information available and the balance to be disclosed as held by custodian. (4) Categorization and disclosure of each shareholder category should be carried out in the order prescribed in the above format. If a shareholder is falling under more than one category, then the same shall be classified in the category falling first in the order prescribed in the above format. Shareholding under any of the categories shall be unique and will not be duplicated under multiple categories. (5) Sub-categorization of shares under column no. (XIX) will be based on shareholding (no. of shares) under the following sub-categories: (i) Shareholders who are represented by a nominee Director on the board of the listed entity or have the right to nominate a representative (i.e. Director) on the board of the listed entity. (ii) Shareholders who have entered into shareholder agreement with the listed entity. (iii) Shareholders acting as persons in concert with promoters.

Table IV - Statement showing holding of specified securities by the Non-Promoter Non-Public shareholders Category & Name of the Shareholders (I) PAN (II) No. of shar ehol der (III) No. of fully paid up equity share s held (IV) Partly paid￾up equity share s held (V) No. of shares underlyi ng Deposit ory Receipt s (VI) Total no. shares held (VII = IV+V+VI) Shareholding % calculate d as per SCRR, 1957 As a % of (A+B+C2) (VIII) Number of Voting Rights held in each class of securities (IX) No. of Shares Underlyi ng Outstan ding converti ble securitie s (includi ng Warrant s, ESOP, etc.) (X) Total No of shares on fully diluted basis (including warrants, ESOP, Convertible Securities etc.) (XI)=(VII+X) Total shareholding, as a % assuming full conversion of convertible securities (as a percentage of diluted share capital) (XII) Number of Locked in shares (XIII) Number of Shares pledged (XIV) Non-Disposal Undertaking (XV) Other encumbrance s, if any (XVI) Total Number of Shares encumber ed (XVII) = (XIV+XV+X VI) Numb er of equity share s held in demat erializ ed form (XVIII) No of Voting Rights Total as a % of Total Voting Class rights X Class Y Total No. (a) As a % of total Shar es held (b) No. (a) As a % of tot al sh are s hel d (b) No. (a) As a % of tota l sha res hel d (b) No. (a) As a % of tot al sh ar es he ld (b) No . (a) As a % of tot al sh ar es he ld (b) (1) Custodian/DR Holder NA (a) Name of DR Holder (If available) NA (i) abc… NA (ii) efg… NA Sub-Total (C1) (2) Employee Benefit Trust / Employee Welfare Trust under SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 NA (a) Name (abc… NA Sub-Total (C2) Total Non Promoter - Non Public NA

Shareholding (C) = (C1) + (C2) Note: (1) PAN would not be displayed on website of Stock Exchange(s). (2) The above format needs to be disclosed along with the names of the shareholders holding 1% or more than 1% of shares of the listed entity. Columns no. (XIV) to (XVII) are not applicable in the above format. (3) W.r.t. the information pertaining to Depository Receipts, the same may be disclosed in the respective columns to the extent information available.

Table V- Statement showing details of significant beneficial owners Sr. No Details of the SBO (I) Details of the registered owner (II) Details of holding/ exercise of right of the SBO in the reporting company, whether direct or indirect*: (III) Date of creation / acquisition of significant beneficial interest# (IV) Name PAN/ Passport No. in case of a foreign national$ Nationality Name PAN / Passport No. in case of a foreign national Nationality Whether by virtue of: (a) Shares % (b) Voting rights % (c) Rights on distributable dividend or any other distribution % (d) Exercise of control (e) Exercise of significant influence

• In case the nature of the holding / exercise of the right of a SBO falls under multiple categories specified under (a) to (e) under Column (III), multiple rows for the same SBO shall be inserted accordingly for each of the categories.

This column shall have the details as specified by the listed entity under Form No. BEN-2 as submitted to the Registrar.

$ PAN/ Passport number not to be disclosed on the website of the Stock Exchange(s).

Table VI - Statement showing foreign ownership limits Board approved limits Limits utilized As on shareholding date As on the end of previous 1st quarter As on the end of previous 2nd quarter As on the end of previous 3rd quarter As on the end of previous 4th quarter