Aptech Ltd. — Regulatory Filings 2021

Aug 20, 2021

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Aptech Limited Regd. office: Aptech House A-65, MIDC, Marol, Andheri (E), Mumbai - 400 093. T: 91 22 2827 2300 F: 91 22 2827 2399 www Aptech-worldwide corn

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20[th] August, 2021

To, BSE Limited 25[th] Floor, P J Towers, Dalal Street, Mumbai – 400 001 Scrip Code: 532475

To,

National Stock Exchange of India Limited

Exchange Plaza, Plot no. C/1, G Block, Bandra-Kurla Complex Bandra (E), Mumbai - 400 051. Symbol: APTECHT

Dear Sir/Madam,

Sub.: Reporting to Stock Exchanges regarding violations under Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 relating to the Code of Conduct (CoC).

Ref.: SEBI/HO/ISD/ISD/CIR/P/2020/135 circular dated 23[rd] July, 2020

With reference to the above, enclosed herewith please find report on violations under SEBI (Prohibition of Insider Trading) Regulations, 2015 relating to the Code of Conduct by Designated person.

Kindly take the same on record.

Thanking you.

For Aptech Limited

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A.K Biyani Company Secretary & Compliance Officer Place: Mumbai

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Aptech Limited Regd. office: Aptech House A-65, MIDC, Marol, Andheri (E), Mumbai - 400 093. T: 91 22 2827 2300 F: 91 22 2827 2399 www Aptech-worldwide corn

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Report by Aptech Limited for violations related to Code of Conduct under the SEBI (Prohibition of Insider Trading) Regulations, 2015

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----- Start of picture text ----- Sr. No. Particulars Details1 Name of the Listed Company / Aptech LimitedIntermediary/Fiduciary2 Please tick appropriate checkbox Reporting in Listed Companycapacity of :√ Listed Company Intermediary Fiduciary3 A. Details of Designated Person (DP)I. Name of the DP Pooja MukandanII. PAN of the DP BLSPM0540FIII. Designation of DP Senior ManagerIV. Functional Role of DP Marketing HeadV. Whether DP is Promoter or belongs to NoPromoter GroupB. If Reporting is for immediate relative of DPI. Name of the immediate relative of DP NAII. PAN of the immediate relative of DP NAC. Details of transaction(s)I. Name of the scrip Aptech LimitedII. No of shares traded and value (Rs.) Date: 3 [rd] August, 2021(Date- wise) No. of shares: 45 equity sharesValue: Rs 12,726/-D. In case value of trade(s) is more than Rs.10lacs in a calendar quarterI. Date of intimation of trade(s) by Not Applicable, as the value of trade does notconcerned exceed Rs. 10 lacs in a calendar quarterDP/director/promoter/promoter groupto Company under regulation 7 of SEBI(PIT) Regulations, 2015II. Date of intimation of trade(s) by Not Applicable, as the value of trade does notCompany to stock exchanges under exceed Rs. 10 lacs in a calendar quarterregulation 7 of SEBI (PIT) Regulations,2015----- End of picture text -----

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Aptech Limited Regd. office: Aptech House A-65, MIDC, Marol, Andheri (E), Mumbai - 400 093. T: 91 22 2827 2300 F: 91 22 2827 2399 www Aptech-worldwide corn

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----- Start of picture text ----- 4 Details of violations observed under Code of Shares sold during trading window closure period.Conduct5 Action taken by Listed company / Intermediary/ Warning letter has been issued to the DesignatedFiduciary Person that she would not engage in any kind ofdealings in the Equity Shares of the Company inviolation of the Company’s Code of Conduct andSEBI (Prohibition of Insider Trading) Regulations,2015 and a monetary penalty of Rs. 1980/-(Rupees One thousand nine hundred and eighty)out of the profits so earned by her on the saidshares, has been imposed.The aforesaid penalty has been duly submitted tothe Investor Protection and Education Fund ofSEBI.The designated person has also been providedagain with a copy of Code of Conduct. She hasbeen further advised that in case of anysubsequent violation stricter action(s) would betaken by the Company.6 Reasons recorded in writing for taking action Matter was discussed with the Chairman of thestated above audit Committee immediately upon receipt ofinformation about violation and it was suggestedby the Audit committee Chairman to issue warningletter and levy penalty based on closing price ofshares on the last day before closing of tradingwindow.7 Details of the previous instances of violations, if NILany, since last financial year8 If any amount collected for Code of Conduct Rs. 1980/- was collected from Pooja Mukandan asviolation(s) penalty towards the violation of CoC.I. Mode of transfer to SEBI - IPEF Online Payment(Online/Demand Draft)----- End of picture text -----

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Aptech Limited Regd. office: Aptech House A-65, MIDC, Marol, Andheri (E), Mumbai - 400 093. T: 91 22 2827 2300 F: 91 22 2827 2399 www Aptech-worldwide corn

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----- Start of picture text ----- II. Details of transfer/paymentParticulars DetailsName of the transferor Aptech LimitedBank Name, branch HDFC Bank Limited,and Account number Nariman Pointbranch.Account no.:00010110000364UTR/Transaction 000121704572reference NumberTransaction date 19-08-2021Transaction Amount (in 1980/-Rs.)In case of Demand Draft (DD): NAParticulars DetailsBank Name and branchDD NumberDD dateDD amount (in Rs.)9 Any other relevant information NIL----- End of picture text -----

For Aptech Limited

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A.K. Biyani Company Secretary and Compliance officer Membership no.: F 8378

Date : August 20, 2021 Place : Mumbai

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