KOTAK COMMITTEE REPORT on CORPORATE...

Pantomath Advisors LLP – A Group entity of Pantomath

KOTAK COMMITTEE REPORT on

CORPORATE GOVERNANCE

‘A pivotal move for Indian Market’


The SEBI Committee on Corporate Governance led by

Mr. Uday Kotak formed on June 2, 2017, recommended sweeping changes in current regulations on October 5, 2017. The recommendations aimed at improving standards of Corporate Governance of listed entities in India, including splitting the posts of chairman and managing director besides amending rules on independent directors, disclosures, and accounting and auditing practices. The suggestions assume greater relevance in the background of high-profile boardroom battles that have rocked corporate India over the past years. The report is a sincere attempt to support and enable sustainable growth of enterprise, while safeguarding interests of various stakeholders. It is an endeavor to facilitate the true spirit of governance. the overall confidence in Indian markets and in India.

Background


Coverage

The Report of the Kotak Committtee on Corporate Governance sets out several recommendations which suggests certain amendments to the existing provisions as currently practices by Companies and certain new provisions with regard to Listing Obligations and Disclosure Requirements (LODR) . Further, the committee considering the role of stakeholders in Corporate Governance provides for certain recommendations for Auditors, Directors. Apart from other recommendations, in order to bring about transparency to investors, the committee suggests changes in Stock Exchange submissions, website disclosures. This precursor provides an insight on the Key Impacting Areas where the changes are recommended by the Committee.

What?

When?

Who?

Key Impacting Areas (KIAs)


Board

Director

Committees

General Meetings

Auditors

Related Party Transactions

Subsidiaries

Annual Report

Stock Exchange Submission

Website Disclosures

Insider Trading

Miscellaneous

1

2

3

4

5

6

7

8

9

10

11

12


C At least half of the Board shall comprise of Independent Directors w.e.f April 1, 2019, for the top 500 listed entities, and w.e.f. April 1, 2020, for all listed entities.

Board Part - 1

Composition

1. w.e.f. April 1, 2019 / 2020

C

Board shall comprise of not less than Six Directors Min. Directors

2. w.e.f. October 1, 2018

C The Chairperson of the Board shall be Non – Executive Director (w.e.f. April 1, 2020 - all listed entities with public shareholding of 40% or more. and w.e.f. April 1, 2022 – all listed Entities))

Chairperson

3. w.e.f. April 1, 2020 / 2022

C

Board shall have atleast one Woman as an Independent Director Woman Director


Ref: Chapter II, Page - 24

Ref: Chapter I, Page - 13




C Company to hold minimum 5 Board meetings in a financial year for conduct of business and additionally at least one meeting specifically to discuss strategic matters.

Board Part - 1

Frequency

5. w.e.f. April 1, 2018

C The quorum for Board meeting shall be one-third of its total strength or three directors, whichever is higher, including at least one independent director.


C A Certificate from a Company Secretary in Practice that none of Directors on Board of the Company have been debarred/disqualified from being appointed/continuing as directors of companies by the SEBI/MCA or any such statutory authority.

Certificate from PCS

7. w.e.f. April 1, 2018

C Company Secretary and Chief Financial Officer shall be considered as part of senior management.

Senior Management

8. w.e.f. April 1, 2018

Quorum



Ref: Chapter III, Page - 38

Ref: Chapter VI, Page - 71


C For the purpose of determination of Chairpersonship and Membership Limit, Chairpersonship and Membership of the Audit Committee, Nomination and Remuneration Committee and the Stakeholders' Relationship Committee shall be considered.

Board Part - 1

Limits

9. w.e.f. April 1, 2018

C The resolution placed before the shareholders should be recommended by the board of directors. Placing a resolution before the shareholders without a board recommendation should be used sparingly and on rare occasions.

10. w.e.f. April 1, 2018

Shareholder’s Resolution

C The Evaluation of Independent Directors (‘ID’) shall be done by the entire board, which should cover their performance and fulfilment of Independence Criteria as specified in the regulations and their Independence from Management.

Evaluation Of IDs

11. w.e.f. April 1, 2018



Ref: Chapter VIII, Page - 94

C In case a listed entity holds its own shares in its name or in the name of any trust either on its behalf or on behalf of any of its subsidiaries or associates (i.e. treasury stock), no voting rights attached to such shares shall be exercisable.

Treasury Stock


w.e.f. April 1, 2021 12.


C Continuation of term of Director, shall be subject to approval of members, if Director fails to attend atleast half of the total number of board meetings held over a period of 2 consecutive FY on a rolling basis.

Directors Part - 2

Attendance

1. w.e.f. April 1, 2018

C Special Resolution for Appointment/continuation for the relevant term of NEDs on attaining the age of 75 years.

Appointment


C Undertake a formal updation programme atleast once in a year for Directors on changes in applicable laws, regulations and compliance requirements.

Updation Programme

3. w.e.f. April 1, 2018

C Undertake a formal interaction between non-executive directors and senior management, at least once every year.

Interaction

4. w.e.f. April 1, 2018






C Director shall hold office in not more than 8 listed entities at same time (of which independent directorships shall not exceed 7) w.e.f. April 1, 2019 and not more than 7 listed entities w.e.f. April 1, 2020, provided person serving as WTD/MD in any listed entity shall serve as independent director in not more than 3 listed entities.

Directors Part - 2

Directorships

5. w.e.f. April 1, 2019 / 2020

C Independent Director shall not be member of the promoter group of listed entity and non-independent director of a company on board of which any non-independent director of listed entity is an independent director

6. w.e.f. April 1, 2018

C Independent Directors shall give a declaration on meeting the independence criteria at the first meeting of Board where he participates/ first meeting of Board for each FY/whenever there is a change and the Board shall note the same.

Declaration

7. w.e.f. April 1, 2018

C Top 500 Listed Entities shall undertake ‘Directors and Officers’ insurance for all the Independent Directors for such quantum and for such risks as Board may determine.

Insurance


Eligibility




Ref: Chapter II, Page – 30


C Each Independent Director to undergo formal training on their roles and responsibilities with particular emphasis on governance aspects once every five years and shall certify compliance with the same to the Company every year.

Directors Part - 2

Training

9. w.e.f. April 1, 2018

C No person shall be appointed as an alternate director for an Independent Director

10. w.e.f. April 1, 2018

C Any casual vacancy arising in the office of Independent Director shall be filled by a new independent director not later than the immediate next Board meeting or three months from the date of such vacancy, whichever is later.

Casual Vacancy

11. w.e.f. April 1, 2018

C Appointment to fill casual vacancy in office of independent director shall be subject to approval by the shareholders at next general meeting, and such director shall cease to hold office if not so approved at the said meeting or on last date on which meeting ought to have been held; whichever is earlier.

Appointment

12. w.e.f. April 1, 2018

Alternate Director






C The top 500 listed entities, having adequate profits shall pay minimum total remuneration of Rs. 5 lakh p.a. to ID.

Directors Part - 2

Compensation To ID

13. w.e.f. April 1, 2018

C Companies with Non - Independent Chairperson shall designate an Independent Director as Lead Independent Director, who shall: Lead meetings of Independent Directors and provide feedback to

Chairperson / Board; Act as liaison between Chairperson and Independent Directors; Preside over meetings of where Chairperson is absent; Have authority to call meetings of Independent Directors; On request of significant Shareholders, ensure his presence for

communication.

14. w.e.f. October 1, 2018

Casual Vacancy

15.

Lead Independent

Director

Applicability Board Meeting Audit Committee

Other Committees

Top 100 listed entities

Rs. 50,000/- Rs. 40,000/-

Rs. 20,000/-

Next 400 listed entities

Rs. 25,000/- Rs. 20,000/-

Rs. 10,000/-




C

Directors Part - 2

Remuneration To Executive

Promoter Director

15. w.e.f. April 1, 2018

C The approval of shareholders shall be obtained every year in which the annual remuneration payable to a single non-executive director exceeds 50% of the total annual remuneration payable to all non-executive directors, giving details of the remuneration thereof.

16.

Casual Vacancy 15.

Remuneration to Non Executive

Directors

Applicability Remuneration shall be subject to Approval of Shareholders by Special Resolution, if

Company having 1 Executive Promoter Director

Remuneration exceeds Rs. 5 Crore or 2.5% of Net Profit, whichever is higher

Company having more than 1 Executive Promoter Director

Aggregate Remuneration exceeds 5% of Net Profit.

Ref: Chapter V, Page - 60


w.e.f. April 1, 2018


C Audit Committee: Minimum 5 meetings in a year with maximum gap of 120 days between two meetings. Other committees: Minimum 1 meeting in a year.

Committees Part - 3

Frequency

1. w.e.f. April 1, 2018

C At least two-third of the members of Nomination and Remuneration Committee (‘NRC’) shall be Independent Directors.

Composition Of NRC

2. w.e.f. April 1, 2019

C The Audit Committee (‘AC’) shall review utilization of loans and/ or advances from/investment by the holding company in the subsidiary exceeding Rs. 100 crore or 10% of the asset size of the subsidiary, whichever is lower.

Role of AC

3. w.e.f. April 1, 2018

C Nomination and Remuneration Committee (‘NRC’) shall recommend to the board all remuneration, in whatever form, payable to senior management.

Role of NRC







C Stakeholder Relationship Committee (‘SRC’) shall comprise of minimum 3 directors, with atleast 1 Independent Director.

Committees Part - 3

Composition of SRC

5. w.e.f. April 1, 2018

C The quorum for meeting of Stakeholders Relationship and Nomination and Remuneration Committee shall be either two members or one third of the members of the committee, whichever is greater, with at least one Independent Director.

6. w.e.f. April 1, 2018

C Risk management committee (‘RMC’) shall be applicable on top 500 listed entities and function of such committee shall specifically cover cyber security.

RMC

7. w.e.f. April 1, 2018

Quorum of SRC & NRC





Top 100 listed entities shall hold their Annual General Meeting within a period of 5 months from the date of closing of the Financial Year.

General Meetings Part - 4

Frequency

1. w.e.f. April 1, 2018

C Top 100 listed entities shall provide One - Way Live Webcast of the proceedings of all Shareholders Meetings. Webcast

2. w.e.f. April 1, 2018

C The Chairperson of the Stakeholders Relationship Committee (‘SRC’) shall be present at AGM to answer queries of the security holders.)

Chairperson of SRC

3. w.e.f. April 1, 2018

Explanatory Statement in relation to the item on appointment / re-appointment of auditor(s) in the relevant notice calling an annual general meeting, should include basis of recommendation for appointment including the details in relation to and credentials of the auditor(s) proposed to be appointed; and Proposed fees payable to the auditor(s) along with terms of appointment and in case of a new auditor, any material change in the fee payable to such auditor from that paid to the outgoing auditor and the rationale for such change.

Appointment of Auditor

4. w.e.f. April 1, 2018


Ref: Chapter VII, Page - 84




Auditor Part - 5

1.

C Mandatory Quantification of Audit Qualifications in the Audit Report, with the exception being only for matters like going concern or sub-judice matters. In such an instance, the management will be required to provide reasons, which will be reviewed by the Auditors and reported accordingly.

Audit Qualification

1.

C In case Statutory Auditors are not satisfied with the views or opinions of the management or of an expert whose services have been availed by the management, the Auditors have a right to obtain independent external opinions as deemed fit, at the cost of the listed entity.

External opinion by Auditors

2. w.e.f. April 1, 2018

Appointment of Auditor

4.




C Detailed reason for Resignation of Auditor before the expiry of the term shall be disclosed to the Stock Exchange.

Resignation of Auditor


w.e.f. April 1, 2018 3.


C All promoters/promoter group entities that hold 20% or above in a listed Company to be considered “related parties” for the purposes of the SEBI LODR Regulations.

Related Party Transactions Part - 6

Definition

1. w.e.f. April 1, 2018

C No related party shall vote to approve resolution for all material Related Party Transactions, whether the entity is a related party to the transaction or not.

Voting

2. with immediate effect

C A transaction involving payments made to related party with respect to brand usage or royalty shall be considered material, if transaction(s) to be entered during a financial year exceeds 5% of the annual consolidated turnover of the listed entity.

Brand / Royalty payment

3. w.e.f. April 1, 2018

C Clear threshold limits, as considered appropriate by the Board of Directors required to be disclosed in the materiality policy and such policy shall be reviewed by Board atleast one in every 3 yrs.

Materiality Policy

4. w.e.f. April 1, 2018






C “Material Subsidiary” shall mean a subsidiary, whose income or net worth exceeds 10% of the consolidated income or net worth respectively, of the listed entity and its subsidiaries in the immediately preceding accounting year.

Subsidiaries Part - 7

Definition

1. w.e.f. April 1, 2018

C At least one independent director on the board of directors of the listed entity shall be a director on the board of directors of an unlisted subsidiary, whether incorporated in India or not, whose income or net worth exceeds 20% of the consolidated income or net worth respectively, of the listed entity and its subsidiaries in the immediately preceding accounting year.

Independent Director

2. w.e.f. April 1, 2018

C Material Unlisted Subsidiaries Incorporated in India shall undertake Secretarial Audit

Secretarial Audit

3. w.e.f. April 1, 2018

4.

C A statement of all individual transaction or arrangement that exceeds or is likely to exceed 10% of the total revenues or total expenses or total assets or total liabilities of the unlisted subsidiary shall be brought into notice of the Board of Listed Entity.

Statement of Transaction

4. w.e.f. April 1, 2018

Ref: Chapter IV, Page - 45





C Confirmation by the Directors on the business affairs and reporting structure of Company and that reporting structures are consistent with the above, shall be disclosed in the Corporate Governance Section in the Annual Report.

Annual Report Part - 8

Matrix Reporting Structure

1. w.e.f. March 31, 2019

C Confirmation that Independent Directors fulfill the conditions specified in these regulations and are Independent of the Management , shall be disclosed in the Corporate Governance Section in the Annual Report.

Confirmation of Independence

2. w.e.f. April 1, 2018

C Detailed reasons for resignation of independent directors who resigns before the expiry of his tenure, shall be disclosed in the Corporate Governance Section in the Annual Report.

Resignation Of ID

3. w.e.f. April 1, 2018

C A matrix setting out the skills of the Directors as required in context of its business/sector, shall be disclosed in the Corporate Governance Section in the Annual Report.

Skills of Directors

4. w.e.f. March 31, 2019/ 2020






C Details of directorships of a Director should include details of directorships (e.g. Independent/executive) in other listed entities, to be disclosed in the Corporate Governance Section in the Annual Report.


Details of Directorships

5. w.e.f. April 1, 2018

C Utilisation of proceeds of Preferential Issues (‘PI)’ and Qualified Institutional Placements (‘QIPs) till the time such proceeds are utilised, shall be disclosed in the Corporate Governance Section in the Annual Report.

Utilization of PI & QIPs

6. w.e.f. April 1, 2018

Key Financial Ratios viz. Debtor Turnover, Inventory Turnover, Interest Coverage Ratio, Current Ratio etc., wherever there is a change of 25% or more in a particular financial year, along with detailed explanations thereof shall be disclosed in the Management Discussion & Analysis Section in the Annual Report.

Financial Indicators

7. w.e.f. April 1, 2018

C The Company may disclose, within the limits set by its competitive position, its medium-term and long-term strategy based on a time frame as determined by its board of directors, in the Management Discussion & Analysis Section in the Annual Report.

Strategy 8.

w.e.f. March 31, 20118






C Where the board had not accepted any recommendation of any committee of the board which is mandatorily required, in the relevant financial year, the same to be disclosed in the Corporate Governance Section of the Annual Report along with reasons thereof.


Views of Committees

9. w.e.f. April 1, 2018

C Total Fees for all services paid by the listed entity and its subsidiaries (i.e. on a consolidated basis) to the statutory auditor and all entities in the network firm/ network entity of which the auditor is a part, shall be disclosed in the Corporate Governance Section of the Annual Report .

Audit Fees

10. w.e.f. April 1, 2018



Disclosure of transactions with any person or entity belonging to the promoter / promoter group which hold(s) 10% or more shareholding in the listed entity.

Transactions 11.



C Disclosure that a Certificate from a Company Secretary in Practice that none of Directors on Board of the Company have been debarred/disqualified from being appointed/continuing as directors of companies by the SEBI/MCA or any such statutory authority , in the Corporate Governance Section of the Annual Report ..

Certificate from PCS

12. w.e.f. April 1, 2018



C Submission of quarterly/year-to-date consolidated financial results of all their Subsidiary Companies.

Stock Exchange Submissions Part - 9

Financial Results

1. w.e.f. April 1, 2018

C Submission, by way of a note, of the statement of cash flows for the half-year as part of its standalone and consolidated financial results.

Cash Flow Statements

2. w.e.f. April 1, 2018

C Submission of Copy of the Annual Report sent to the shareholders along with the notice of the annual general meeting not later than the day of commencement of dispatch to its shareholders.

Annual Report

3. w.e.f. April 1, 2018

C In the event shareholders approve any amendments to any portion of the annual report, then the revised copy (with details of and explanation for the changes so approved) to be sent to the Stock Exchange not later than 48 hours after the Annual General Meeting.

Revised Annual Report

4.







C Shareholding Pattern shall also specify details of names of holders of global depository receipts issued, if any, holding more than 1% of the total shareholding of the entity.

Stock Exchange Submissions Part - 9

Shareholding Pattern

5. w.e.f. April 1, 2018

C

All the disclosures made in Soft Copy shall be in XBRL Format.

Format of Disclosure

6. w.e.f. April 1, 2018

C Prior Intimation of Board Meeting for consideration of Bonus Issue by the Board of Directors.

Prior Intimation

7. With immediate effect

C Half yearly disclosure of Related Party Transactions (‘RPTs’) on a consolidated basis to be submitted to the stock exchange(s) within 30 days of publication of the half yearly financial results.

Consolidated RPTs

8.







C Half yearly disclosure of Related Party Transactions (‘RPTs’) on a consolidated basis within 30 days of publication of the half yearly financial results.

Website Disclosures Part - 10

Consolidated RPTs

1. w.e.f. April 1, 2018

C Copy of the Annual Report sent to the shareholders along with the notice of the annual general meeting not later than the day of commencement of dispatch to its shareholders

Annual Report

2. w.e.f. April 1, 2018

C In the event shareholders approve any amendments to any portion of the annual report, then the revised copy (with details of and explanation for the changes so approved) to be published on Website not later than 48 hours after the Annual General Meeting.

Revised Annual Report

3. w.e.f. April 1, 2018

C All credit ratings obtained by the entity for all its outstanding instruments and should be updated immediately as and when there is any revision in any of the ratings.

Credit Rating

4.







C Provide all the information mandated under Regulation 46 of SEBI LODR Regulations in a separate section, to ensure ease of availability and access of pertinent information in one place to investors and regulators alike.

Website Disclosures Part - 10

Separate Section

5. w.e.f. April 1, 2018

C Audited Financial Statements for the relevant financial year of each of its subsidiaries at least 21 days before the date of the Annual General Meeting.

Subsidiary Financials

6. w.e.f. April 1, 2018

C All the disclosures on the website should be in a searchable format that allows users to find relevant information easily.

Format of Disclosure

7. w.e.f. April 1, 2018





C A listed entity may enter into the agreement in relation to providing access to material information (including unpublished price sensitive information) to the counterparty as per new Chapter IV-A.

Insider Trading Part - 11

Information Agreement

1. w.e.f. April 1, 2018

C A listed entity may enter into the agreement as per new Chapter IV-A only after amending its Articles of Association (‘AoA’) by including an enabling provision authorizing the listed entity to enter into such agreements in accordance with new Chapter IV-A.

Authority in AoA

2. w.e.f. April 1, 2018

C The fact of entering into or termination of the agreement under new Chapter IV-A along with the name of the counterparty shall be disclosed to Stock Exchange(s) as per Regulation 30.

Disclosure

3. w.e.f. April 1, 2018

Ref: Chapter V , Page - 49

Ref: Chapter V ,Page - 49


C “Counterparty” means any person who qualifies as promoter of the listed entity and holds more than 25% OR is in direct or indirect control of such promoter OR has nominated a director on the board.

Definition

4. w.e.f. April 1, 2018

Ref: Chapter V , Page - 49


C Disclosure on Board Evaluation may include previous years’ Observations and action taken, Observations of the Board Evaluation carried out for the year and proposed action on current year observations.

Miscellaneous Part - 12

Board Evaluation

1.

Where Company has multiple unlisted subsidiaries, it may on the decision of the Board set up a dedicated Governance Committee and have a strong and effective group governance policy to monitor governance of all Subsidiaries

Group Governance

2.

Ref: Chapter I , Page - 23

Ref: Chapter IV , Page - 47

C E-Voting should be kept open till midnight (11.59 PM) on the day of the General Meeting (SEBI to take up recommendation with MCA for amendment in Companies (Management and Administrations) Rules, 2014)

E- Voting

4.


Voluntary

Voluntary

C The Company may constitute an Information Technology Committee (‘ITC’) which will focus on digital and technological aspects.

ITC

3.


Voluntary


C


Re Classification of Promoters

5.


With immediate effect

A- Where there are multiple promoters and a specific promoter wishes to undergo re-classification, on request being received by the Company, re-classification can be done provided following conditions are met: (i) promoters and PACs cumulatively hold 10% or more of the aggregate shareholding; (ii) a specific person and PACs cumulatively hold less than 5% of the aggregate shareholding; (iii) the specific promoter or PAC are neither on the board nor in the management and are not acting in concert with other persons forming part of the promoter group; and (iv) Ordinary Resolution is passed at the General Meeting B- Where there is only one specific promoter and who wishes to undergo re-classification, on request being received by the Company, re-classification can be done provided following conditions are met: (i) such promoter or PAC for that promoter is/are neither on the Listed Entity Board nor in management of the company nor has a nominee director; (ii) cumulative shareholding and voting rights of such promoter and its promoter group and PACs goes below 10%; (iii) there are no other persons qualifying as promoters of the company; and (iv) Ordinary Resolution is passed at the General Meeting


C

Harmonization of Disclosures made to Stock Exchange and MCA Circular on Specific disclosures on assets, liabilities and turnover of the

entities involved should be disclosed in the valuation reports on schemes of arrangement.

Circular on disclosure of risk management activities by the Companies, including their commodity hedging positions in a more transparent, detailed and uniform manner for easy understanding and appreciation by the shareholders.

Circular stating that the auditor of the holding company should be made responsible for the audit opinion of all material unlisted subsidiaries.

IFC reporting requirements be made applicable to the entire operations of the group (Indian and Foreign operations) for listed entities with Net Worth of Rs. 1,000 crore and above.

Making public Audit Quality Indicators available with ICAI, which will enable transparency and comparison of the audit quality of different auditors.

Strengthening the role of ICAI and Independent functioning of Quality Review Board.

Introduction of Stewardship code Introduction of Leniency Program


Further Actions to be taken by SEBI

6.


The Report of the Committee represents an important milestone in Indian Corporate Governance by

presenting ‘The Next Phase Of Corporate Governance Reforms’. Unlike corporate governance reviews of the past that sought to look elsewhere and adopt Governance mechanisms prevalent in other jurisdictions such as the united kingdom and The United States, the Kotak Committee has conducted an introspective exercise and attempted to devise customized solutions for local problems. The Committee’s process - oriented approach is grounded on the logic that Corporate Governance “is an integral part of the broader governance of the country”, and that corporate India plays a significant role in nation-building. The recommendations focus on the composition of the board, its independence and functioning, the role of auditors, shareholder participation and the enhancement of corporate disclosures. This is indeed a welcome step!!!!!......... Although the committee has demonstrated care in facilitating “the true spirit of governance”, the tenor of the recommendations may have the effect of form prevailing over substance. Moreover, the penetration of unyielding corporate regulation into the boardroom may have unintended adverse consequences. In all, while the committee’s efforts are laudable, it remains to be seen whether, and the extent to which, they are implemented by the regulators and accepted by corporate India.

Our Insight

Disclaimer All data and information is provided for informational purposes only and is not intended for any factual use. It should not be considered as binding / statutory provisions. Neither Pantomath Capital Advisors nor any of its group company, directors, or employs shall be liable for any of the data or content provided for any actions taken in reliance thereon.

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