Icici Prudential Asset Management Company Limited

Allegations: ICICI BANK LIMITED ("ICICI BANK") HAD ENTERED INTO A REFERRAL ARRANGEMENT WITH JONES LANG LASALLE MEGHRAJ(JLLM) , AN ENTITY ENGAGED IN THE BUSINESS OF PROVIDING REAL ESTATE CONSULTANCY SERVICES, FOR THE PURPOSE OF REFERRING INTERESTED CLIENTS TO AVAIL THE SERVICES OF JLLM. UNDER THE SAID ARRANGEMENT, ICICI BANK HAD REFERRED MR. RAKESH KUMAR GOEL AND MRS. REKHA GOEL (THE "COMPLAINANT") TO JLLM FOR DAMDEN PROPERTY IN MYSORE. SUBSEQUENT TO THE REFERRAL, THE COMPLAINANT HAD INVESTED IN ONE OF THE SCHEMES PROVIDED BY JLLM AND HAD PAID A BROKERAGE AMOUNT TO JLLM TO SECURE PROPERTY CERTIFICATE IN THE DAMDEN PROPERTY. HOWEVER, DAMDEN HAS, TILL DATE, FAILED TO PAY THE BUYBACK AMOUNT IN ACCORDANCE WITH THE TERMS OF THE PROPERTY CERTIFICATE AND AS PER THE AGREED SCHEME TO ITS CLIENT. IN THIS REGARD, THE COMPLAINANT FILED A CIVIL SUIT AGAINST JLLM, DAMDEN PROPERTIES AND ICICI BANK TO CLAIM THE DAMAGES SUFFERED BY THE COMPLAINANT. Status: Final Summary: ICICI BANK HAD ENTERED INTO A REFERRAL AGREEMENT WITH JLLM. UNDER THE REFERRAL ARRANGEMENT, ICICI BANK HAD REFERRED THE COMPLAINANT TO JLLM FOR THE DAMDEN PROPERTY. PRIOR TO MAKING SUCH A REFERRAL, ICICI BANK HAD SHARED WITH THE COMPLAINANT, THE BRIEF PARTICULARS ABOUT THE REAL ESTATE PROJECT IN MYSORE, WHICH WAS RESTRICTED TO INFORMATION AS RECEIVED FROM JLLM ABOUT THE DAMDEN PROPERTY AND THE INVESTMENT PROPOSAL IN ITS MYSORE PROJECT. PLEASE NOTE THAT ICICI BANK WAS ONLY FORWARDING THESE DOCUMENTS IN ITS CAPACITY AS A REFERRER. ANY FURTHER DOCUMENTATION WITH RESPECT TO DAMDEN PROPERTY HAVE BEEN SHARED/EXECUTED BETWEEN THE COMPLAINANT, JLLM AND DAMDEN EXCLUSIVELY AND TO THE COMPLETE EXCLUSION OF ICICI BANK AS A SIGNATORY AT ALL POINTS OF TIME. IT WAS ALLEGED THAT ICICI BANK DID NOT UNDERTAKE ANY DUE DILIGENCE, CHECKS OR SUCH SIMILAR ANALYSIS IN RELATION TO THE PROPOSED TRANSACTIONS AS THE ROLE OF ICICI BANK WAS THAT OF A REFERRAL PARTNER WITH LIMITED OBLIGATION AS STATED ABOVE. THE COMPLAINANT HAD THE SOLE DISCRETION TO DEAL WITH JLLM WITHOUT ANY INVOLVEMENT OF ICICI BANK. WITHOUT ANY FAULT OR SERVICE DEFICIENCY ON THE PART OF ICICI BANK, ICICI BANK WAS BEING MADE PARTY TO THE DISPUTE BETWEEN COMPLAINANT, JLLM AND DAMDEN PROPERTIES. MMGC AND CO. HAS BEEN THE BANK'S COUNSEL AT THE KARNATAKA STATE CONSUMER COMMISSION PROCEEDINGS VIDE ORDER DATED APRIL 5, 2024, THE MATTER WAS DISPOSED OFF BY THE KARNATAKA STATE DISPUTE REDRESSAL FORUM. THERE IS NO ADVERSE ORDER AGAINST ICICI BANK.

Allegations: THE PLAINTIFFS, BEING INVESTORS OF DIF III (A POOLED INVESTMENT VEHICLE IN MAURITIUS), FILED A COMPLAINT AGAINST DIF III, IFSL (ADMINISTRATOR OF DIF III IN MAURITIUS), ICICI VENTURE (MANAGER OF IAF III - A REAL ESTATE FUND IN WHICH DIF III HAD INVESTED), ICICI BANK LIMITED (ARRANGER TO DIF III) AND THE TRUSTEES (IDBI TRUSTEESHIP), ALLEGING- INADEQUACY OF DISCLOSURES AT THE TIME OF INVITING INVESTMENTS, NEGLIGENCE AND MISREPRESENTATION IN THE MANAGEMENT OF THE FUNDS AND INVESTMENTS IN THE PORTFOLIO COMPANIES. THE PLAINTIFFS HAVE CLAIMED $103.6 MILLION AS DAMAGES. Status: On Appeal Summary: THE PLAINTIFFS ARE SHAREHOLDERS OF DIF III AND HAVE ALLEGED - INADEQUACY OF DISCLOSURES AT THE TIME OF INVITING INVESTMENTS, NEGLIGENCE AND MISREPRESENTATION IN THE MANAGEMENT OF THE FUNDS AND INVESTMENTS IN THE PORTFOLIO COMPANIES. ALL THE DEFENDANTS INCLUDING ICICI BANK AND ICICI VENTURE HAVE RAISED PRELIMINARY OBJECTIONS TO THE SUIT ON THE GROUND OF PRIVITY OF CONTRACT AND JURISDICTION OF MAURITIUS COURTS. DIF III HAS ALSO RAISED THE SEVERAL PRELIMINARY OBJECTIONS INCLUDING THE SUIT BEING A DISGUISED DERIVATIVE ACTION AND THE APPROPRIATE COURT TO HEAR IT IS THE COMMERCIAL COURT AND NOT THE CIVIL COURT AND THERE IS A CONNECTED STAY APPLICATION FILED BY DIF III BEFORE THE SAID COMMERCIAL COURT. BY AN ORDER DATED JUNE 9, 2020 THE SUPREME COURT OF MAURITIUS HAS STAYED THE PROCEEDINGS AS AGAINST ICICI BANK AND ICICI VENTURE ON THE GROUNDS THAT NONE OF THE ALLEGATIONS MADE AGAINST ICICI BANK AND ICICI VENTURE OCCURRED IN MAURITIUS AND HENCE THE COURTS IN MAURITIUS LACK JURISDICTION TO ADJUDICATE SUCH ALLEGATIONS. IN THE SUBSEQUENT HEARING ON JULY 1, 2020, THE PLAINTIFFS INFORMED THE COURT OF THEIR DECISION NOT TO APPEAL AGAINST THE ORDER STAYING THE PROCEEDINGS AS AGAINST ICICI VENTURE AND ICICI BANK. ICICI VENTURE AND ICICI BANK THEREAFTER MOVED A MOTION BEFORE THE MASTERS COURT TO GET THEIR RESPECTIVE NAMES ENTIRELY STRUCK OFF FROM THE SUIT, AND ON MAY 27, 2021, THE MASTERS COURT HAS PASSED THE RULING THAT- SINCE THE STAY ORDER PASSED BY THE SUPREME COURT ALREADY HAS AN EFFECT OF PREVENTING CONTINUATION OF ANY PROCEEDINGS IN RELATION TO DEFENDANTS 3 AND 4, THE SAID DEFENDANTS CANNOT FILE ANY PROCEEDINGS OR APPEAR BEFORE THE COURT. THUS, EVEN THE MOTION FILED BY DEFENDANTS 3 AND 4 BEFORE THE MASTER AND REGISTRAR, HAS NO REASON TO BE FILED, AND THAT, IT IS CLEAR THAT THE MATTER CANNOT PROCEED ANY FURTHER IN RELATION TO DEFENDANTS 3 AND 4 (ICICI VENTURES AND ICICI BANK), AND THE PLAINTIFFS ARE TO PROCEED WITH THE PLAINT AGAINST THE DEFENDANTS NOS 1, 2 AND 5 ONLY. THE MATTER WAS THEREAFTER LISTED BEFORE THE SUPREME COURT FOR CONTINUATION OF PROCEEDINGS AND THE DEFENDANTS 3 & 4 TOOK A STAND TO HAVE ALL PARAGRAPHS OF THE PLAINT THAT ARE RELATED TO THEM BE STRUCK OUT, DUE TO THE LACK OF JURISDICTION OF THE SUPREME COURT OF MAURITIUS TO ENTERTAIN THE PLAINT IN LINE WITH THE RULING OF THE JUDGE DATED 9 JUNE 2020 WHICH HAS BEEN CONFIRMED BY THE RULING OF THE MASTER AND REGISTRAR DATED 27 MAY 2021. THE CASE IS BEING HEARD AGAINST THE OTHER DEFENDANTS. ON JUNE 03, 2022, AN INTERLOCUTORY JUDGEMENT CONFIRMED AND GRANTED THE MOTION TO STRIKE OUT THOSE PARAGRAPHS OF THE PLAINT MAKING REFERENCE TO DEFENDANTS 3 AND 4. THE PLAINTIFFS HAVE PREFERRED AN APPEAL AGAINST THIS ORDER AND THE APPEAL PROCESS IS ONGOING. CONSIDERING THAT ICICI BANK NOT ADMITTED AS PARTIES TO THE CASE POST THE STAY ORDER DATED JUNE 09, 2020 AND BASED ON THE PRESENT STATE OF THE MATTER, THE ASSESSMENT OF LIABILITY AGAINST ICICI VENTURE AND ICICI BANK HAS BEEN CLASSIFIED AS REMOTE. THE NEXT HEARING OF THE MATTER IS ON JUNE 27, 2024.

Allegations: THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY ("FSAN") ALLEGED THAT AFTER PRUDENTIAL PLC ACQUIRED SHARES IN STOREBRAND ASA, IT CROSSED A 5% REPORTING THRESHOLD AND DID NOT IMMEDIATELY NOTIFY THE ISSUER AND THE FSAN, AS REQUIRED BY NORWEGIAN SECURITIES TRADING ACT SECTION 4-3. PRUDENTIAL PLC REPORTED THE ACQUISITION TWO DAYS LATER. Status: Final Sanction Detail: THE MATTER HAS BEEN CLOSED. PRUDENTIAL PLC PAID A VIOLATION CHARGE (PENALTY) OF $11,800 ON MAY 1, 2015. THERE WERE NO OTHER SANCTIONS AND PRUDENTIAL PLC WAS NOT OBLIGED TO COMPLY WITH ANY UNDERTAKINGS. Summary: THE MATTER HAS BEEN CLOSED. PRUDENTIAL PLC PAID A VIOLATION CHARGE (PENALTY) OF $11,800 ON MAY 1, 2015. THERE WERE NO OTHER SANCTIONS AND PRUDENTIAL PLC WAS NOT OBLIGED TO COMPLY WITH ANY UNDERTAKINGS

Allegations: CERTAIN ALLEGED VIOLATIONS WERE OBSERVED DURING THE INSPECTION OF ICICI PRUDENTIAL MUTUAL FUND UNDER SEBI (MUTUAL FUNDS) REGULATIONS, 1996 FOR THE PERIOD OF APRIL 01, 2014 TO MARCH 31, 2016. QUASI-JUDICIAL PROCEEDINGS HAD BEEN INITIATED BY SEBI, WITH RESPECT TO FOLLOWING MATTERS: A)INVESTMENT BY SCHEMES AS PER THE INVESTMENT OBJECTIVE; B)REBALANCING OF SCHEME PORTFOLIO IN CASE OF DOWNGRADE OF SECURITIES; AND C)DETERMINATION OF QUANTUM OF DIVIDEND AND FIXING OF RECORD DATE FOR DECLARATION OF DIVIDEND. IN REFERENCE TO THE ABOVE, THE AMC AND ICICI PRUDENTIAL TRUST LIMITED (THE TRUSTEE COMPANY) HAD RECEIVED A SHOW CAUSE NOTICE ON AUGUST 28, 2018. PURSUANT TO COMPLETION OF QUASI-JUDICIAL PROCEEDINGS, SEBI SENT ITS ORDER DATED DECEMBER 23, 2019 LEVIED A PENALTY OF RS. 300,000 (APPROX. $4,212.00 USD TOTAL)ON THE AMC AND RS. 200,000 ON THE TRUSTEE COMPANY ONLY IN RESPECT OF MATTERS LISTED UNDER (A) AND (C) ABOVE. Status: Final Sanction Detail: TOTAL FINANCIAL PENALTIES OF $4212 USD WERE LEVIED AGAINST THE AMC. THE PENALTY PAYMENT WAS MADE VIA DEMAND DRAFT DATED JANUARY 31, 2020 AND THE SAME WAS SUBMITTED TO SEBI VIA LETTER DATED FEBRUARY 03, 2020. Summary: THE MATTER IS CLOSED.

Allegations: RESERVE BANK OF INDIA (RBI) HAS THROUGH AN ORDER DATED MARCH 26, 2018, IMPOSED A MONETARY PENALTY OF 589.0 MILLION INR (APPROX 9 MILLION USD, CONSIDERING 1$ = 64.90 INR AS ON MARCH 26, 2018) ON ICICI BANK LIMITED (BANK) FOR NON-COMPLIANCE WITH DIRECTIONS/GUIDELINES ISSUED BY RBI. Status: Final Sanction Detail: RESERVE BANK OF INDIA (RBI) HAS THROUGH AN ORDER DATED MARCH 26, 2018, IMPOSED A MONETARY PENALTY OF 589.0 MILLION INR (APPROX 9 MILLION USD, CONSIDERING 1$ = 64.90 INR AS ON MARCH 26, 2018) ON ICICI BANK LIMITED FOR NON-COMPLIANCE WITH DIRECTIONS/GUIDELINES ISSUED BY RBI. THIS PENALTY HAS BEEN IMPOSED IN EXERCISE OF POWERS VESTED IN RBI UNDER THE PROVISIONS OF SECTION 47A(1)(C) READ WITH SECTION 46(4)(I) OF THE BANKING REGULATION ACT, 1949 (OF INDIA). Summary: ICICI BANK LIMITED HAS MADE THE PAYMENT OF THE PENALTY AS DIRECTED BY RESERVE BANK OF INDIA.

Allegations: THE RESERVE BANK OF INDIA (RBI) HAS, BY AN ORDER DATED MAY 03, 2021, IMPOSED A MONETARY PENALTY OF 30 MILLION INR (APPROX.0.4 MILLION USD, CONSIDERING 1$ = 74.18 INR AS ON MAY 03, 2021) ON ICICI BANK LTD. THIS PENALTY HAS BEEN IMPOSED UNDER THE PROVISIONS OF SECTION 47 A (1) (C) READ WITH SECTIONS 46 (4) (I) OF THE BANKING REGULATION ACT, 1949 FOR SHIFTING CERTAIN INVESTMENTS FROM HTM CATEGORY TO AFS CATEGORY IN MAY 2017. THE BANK HAD TRANSFERRED TWO SEPARATE CATEGORIES OF SECURITIES ON TWO DIFFERENT DATES FROM HTM TO AFS IN APRIL AND MAY OF 2017, WHICH IT BELIEVED WAS PERMISSIBLE AS PER MASTER CIRCULAR ON PRUDENTIAL NORMS FOR CLASSIFICATION, VALUATION AND OPERATION OF INVESTMENT PORTFOLIO BY ICICI BANK LTD DATED JULY 01, 2015. RBI HAS HELD THAT THE SHIFTING OF SECURITIES THE SECOND TIME IN MAY 2017 WITHOUT EXPLICIT PERMISSION WAS IN CONTRAVENTION OF RBI DIRECTIONS. Status: Final Sanction Detail: FULL FINE AMOUNT OF RS. 30 MILLION (APPROX.0.4 MILLION USD, CONSIDERING 1$ = 74.18 INR AS ON MAY 03, 2021) WAS PAID ON MAY 14, 2021. Summary: ICICI BANK LTD HAS MADE THE PAYMENT OF THE PENALTY AS DIRECTED BY RESERVE BANK OF INDIA.

Allegations: THE FINANCIAL SERVICES AUTHORITY ("FSA") ALLEGED THAT PRUDENTIAL PLC BREACHED LISTING PRINCIPLE 6 BY NOT MORE RAPIDLY INFORMING THE FSA OF THE PROSPECTIVE (AND SUBSEQUENTLY ABORTED) ACQUISITION OF AIA GROUP LIMITED IN EARLY 2010. THE ALLEGATIONS DID NOT INVOLVE ANY ADVISORY ACTIVITIES OR FUNCTIONS, OR ANY PERSON INVOLVED IN SUCH ACTIVITIES OR FUNCTIONS OR THAT HAS A ROLE IN THE MANAGEMENT OR POLICIES OF ANY ADVISOR. ADDITIONAL INFORMATION CONCERNING THE MATTER MAY BE FOUND IN THE REPORT OF PRUDENTIAL PLC ON FORM 6-K FURNISHED TO THE SEC ON MARCH 27, 2013. Status: Final Sanction Detail: TOTAL FINANCIAL PENALTIES OF 14 MILLION POUNDS STERLING ($21 MILLION USD AS OF MARCH 27, 2013) WERE LEVIED AGAINST PRUDENTIAL PLC. THE SPECIFIED ADVISORY AFFILIATE MADE THIS PAYMENT IN MARCH 2013. Summary: A FINAL NOTICE PUBLISHED BY THE FSA RELATING TO THE SPECIFIED ADVISORY AFFILIATE ON MARCH 27, 2013 FOUND THAT, ALTHOUGH NEITHER RECKLESS NOR DELIBERATE, A BREACH OF LISTING PRINCIPLE 6 HAD OCCURRED, AND LEVIED THE FINANCIAL PENALTY REFERRED TO ABOVE. AS PART OF THE SETTLEMENT, THE SPECIFIED ADVISORY AFFILIATE HAS WITHDRAWN AN EARLIER REFERRAL TO THE UK UPPER TRIBUNAL (TAX AND CHANCERY CHAMBER) FOR AN INDEPENDENT DE NOVO DETERMINATION OF THE MATTER, AND THE FINAL NOTICE ACCORDINGLY REPRESENTS THE FINAL RESOLUTION OF THE MATTER. ADDITIONAL INFORMATION CONCERNING THE MATTER MAY BE FOUND IN THE REPORT OF PRUDENTIAL PLC ON FORM 6-K FURNISHED TO THE SEC ON MARCH 27, 2013.