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Aptech Ltd. — Regulatory Filings 2021
Aug 10, 2021
60838_rns_2021-08-10_2280b535-0bed-4040-a4c7-e4e98ce5edc1.pdf
Regulatory Filings
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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
10th August, 2021
To, BSE Limited 25th 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 23rd 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
A.K Biyani Company Secretary & Compliance Officer Place: Mumbai

| Sr. No. | Particulars | Details |
|---|---|---|
| 1 | NameoftheListedCompany/Intermediary/Fiduciary | Aptech Limited |
| 2 | Please tick appropriate checkbox Reporting incapacity of : | Listed Company |
| √ Listed Company | ||
| Intermediary | ||
| Fiduciary | ||
| 3 | A.Details of Designated Person (DP) | |
| i.Name of the DP | Murli Mohan Malla | |
| ii.PAN of the DP | ALUPM1019L | |
| iii. Designation of DP | Vice President | |
| iv. Functional Role of DP | National Sales Head | |
| v.Whether DP is Promoter or belongs toPromoter Group | No | |
| B.If Reporting is for immediate relativeof DP | ||
| i.Name of the immediate relative of DP | NA | |
| ii.PAN of the immediate relative of DP | NA | |
| C.Details of transaction(s) | ||
| i.Name of the scrip | Aptech Limited | |
| ii.No of shares traded and value (Rs.)(Date- wise) | Date: 28th July, 2021No. of shares: 600 equity shares | |
| Value: Rs. 1,66,068/- | ||
| D.In case value of trade(s) is more thanRs.10 lacs in a calendar quarter | ||
| i.Dateofintimationoftrade(s)byconcernedDP/director/promoter/promoter group toCompany under regulation 7 of SEBI(PIT) Regulations, 2015 | Not Applicable, as the value of trade does notexceed Rs. 10 lacs in a calendar quarter | |
| ii.Dateofintimationoftrade(s)byCompany to stock exchanges underregulation 7 of SEBI (PIT) Regulations,2015 | Not Applicable, as the value of trade does notexceed Rs. 10 lacs in a calendar quarter | |
| 4 | Details of violations observed under Code ofConduct | Shares sold during trading window closure period. |
| 5 | Action taken by Listed company/ Intermediary/Fiduciary | Warning letter has been issued to the DesignatedPerson that he 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. 21,828/- |

| (Rupees Twenty One Thousand Eight HundredTwenty Eight Only) out of the profits so earned byhim on the said shares, 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. He hasbeenfurtheradvisedsubsequent violation stricter action(s) would betaken by the Company. | thatincaseofany | ||
| 6 | Reasons recorded in writing for taking actionstated above | Matter was discussed with the Chairman of theaudit Committee immediately upon receipt ofinformation about violation and it was suggested bythe 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, ifany, since last financial year | NIL | |
| 8 | If any amount collected for Code of Conductviolation(s) | Rs. 21,828/- was collected from Murli Malla aspenalty towards the violation of CoC. | |
| i.ModeoftransfertoSEBI-IPEF(Online/Demand Draft) | Online Payment | ||
| ii.Details of transfer/payment | |||
| Particulars | Details | ||
| Name of the transferor | Aptech Limited | ||
| BankName,branch | HDFC Bank Limited, | ||
| and Account number | NarimanPointbranch. | ||
| Accountno.:00010110000364 | |||
| UTR/Transactionreference Number | 000250584014 | ||
| Transaction date | 10-08-2021 | ||
| Transaction Amount (inRs.) | 21,828 | ||

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
| In case of Demand Draft (DD): | NA | |
|---|---|---|
| Particulars | Details | |
| Bank Name and branch | ||
| DD Number | ||
| DD date | ||
| DD amount (in Rs.) | ||
| Any other relevant information | NIL |
For Aptech Limited
A.K. Biyani Company Secretary and Compliance officer Membership no.: F 8378

| Sr. No. | Particulars | Details |
|---|---|---|
| 1 | Name of the Listed Company/ | Aptech Limited |
| Intermediary/Fiduciary | ||
| 2 | Please tick appropriate checkbox Reporting in | Listed Company |
| capacity of : | ||
| √ Listed Company | ||
| Intermediary | ||
| Fiduciary | ||
| 3 | Details of Designated Person (DP) | |
| Name of the DP | Saikat Banerjee | |
| PAN of the DP | AGNPB0599A | |
| Designation of DP | Manager | |
| Functional Role of DP | MIS, Corporate, Income, FA, Common Costs | |
| Whether DP is Promoter or belongs to Promoter | No | |
| Group | ||
| If Reporting is for immediate relative of DP | ||
| Name of the immediate relative of DP | NA | |
| PAN of the immediate relative of DP | NA | |
| Details of transaction(s) | ||
| Name of thescrip | Aptech Limited | |
| No of shares traded and value (Rs.) (Date-wise) | Date: 13thJuly, 2021 | |
| No. of shares: 250 equity shares | ||
| Value: Rs. 62,500/- | ||
| In case value of trade(s) is more than Rs.10 lacs | ||
| in a calendar quarter | ||
| Date of intimation of trade(s) by concerned | Not Applicable, as the value of trade does not | |
| DP/director/promoter/promoter group to | exceed Rs. 10 lacs in a calendar quarter | |
| Company under regulation 7 of SEBI (PIT) | ||
| Regulations, 2015 | ||
| Date of intimation of trade(s) by Company to | Not Applicable, as the value of trade does not | |
| stock exchanges under regulation 7 of SEBI (PIT) | exceed Rs. 10 lacs in a calendar quarter | |
| Regulations, 2015 | ||
| 4 | Details of violations observed under Code of | Shares sold during trading window closure period. |
| Conduct | ||

| 5 | Action taken by Listed company/ Intermediary/Fiduciary | Warning letter has been issued to the DesignatedPerson that he 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. 2,400/-(Rupees Two Thousand Four Hundred Only) out ofthe profits so earned by him on the said shares,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. He has beenfurther advised that in case of any subsequentviolation stricter action(s) would be taken by theCompany. | ||
| 6 | Reasons recorded in writing for taking actionstated above | Matter was discussed with the Chairman of theaudit 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, ifany, since last financial year | NIL |
| 8 | If any amount collected for Code of Conductviolation(s)Mode of transfer to SEBI -IPEF (Online/DemandDraft) | Rs. 2,400/-was collected from Saikat Banerjee aspenalty towards the violation of CoC.Online Payment |

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
| Details of transfer/payment | ||||
|---|---|---|---|---|
| Particulars | Details | |||
| Name of the transferor | Aptech Limited | |||
| Bank Name, branchand Account numberUTR/Transactionreference NumberTransaction date | HDFC Bank Limited,Nariman Pointbranch.Account no.:0001011000036412211739604709-08-2021 | |||
| Transaction Amount (inRs.) | 2,400/- | |||
| In case of Demand Draft (DD): | NA | |||
| Particulars | Details | |||
| Bank Name and branch | ||||
| DD Number | ||||
| DD date | ||||
| DD amount (in Rs.) | ||||
| 9 | Any other relevant information | NIL |
For Aptech Limited
A.K. Biyani Company Secretary and Compliance officer Membership no.: F 8378

| Sr. No. | Particulars | Details |
|---|---|---|
| 1 | Name of the Listed Company/ | Aptech Limited |
| Intermediary/Fiduciary | ||
| 2 | Please tick appropriate checkbox Reporting in | Listed Company |
| capacity of : | ||
| √ Listed Company | ||
| Intermediary | ||
| Fiduciary | ||
| 3 | Details of Designated Person (DP) | |
| Name of the DP | Sarwan Singh | |
| PAN of the DP | AAZPS0103R | |
| Designation of DP | Vice President | |
| Functional Role of DP | LF Centers & Audits | |
| Whether DP is Promoter or belongs to Promoter | No | |
| Group | ||
| If Reporting is for immediate relative of DP | ||
| Name of the immediate relative of DP | NA | |
| PAN of the immediate relative of DP | NA | |
| Details of transaction(s) | ||
| Name of the scrip | AptechLimited | |
| No of shares traded and value (Rs.) (Date-wise) | thDate: 28July, 2021 | |
| No. of shares: 399 equity shares | ||
| Value: Rs. 1,10,753/- | ||
| In case value of trade(s) is more than Rs.10 lacs | ||
| in a calendar quarter | ||
| Date of intimation of trade(s) by concerned | Not Applicable, as the value of trade does not | |
| DP/director/promoter/promoter group to | exceed Rs. 10 lacs in a calendar quarter | |
| Company under regulation 7 of SEBI (PIT) | ||
| Regulations, 2015 | ||
| Date of intimation of trade(s) by Company to | Not Applicable, as the value of trade does not | |
| stock exchanges under regulation 7 of SEBI (PIT) | exceed Rs. 10 lacs in a calendar quarter | |
| Regulations, 2015 | ||
| 4 | Details of violations observed under Code of | Shares sold during trading window closure period. |
| Conduct |

| 5 | Action taken by Listed company/ Intermediary/Fiduciary | Warning letter has been issued to the DesignatedPerson that he 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. 14,833/- |
|---|---|---|
| (Rupees Fourteen Thousand Eight Hundred ThirtyThree Only) out of the profits so earned by him onthe said shares, 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. He has beenfurther advised that in case of any subsequentviolation stricter action(s) would be taken by theCompany. | ||
| 6 | Reasons recorded in writing for taking actionstated above | Matter was discussed with the Chairman of theaudit 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, ifany, since last financial year | NIL |
| 8 | If any amount collected for Code of Conductviolation(s)Mode of transfer to SEBI -IPEF (Online/DemandDraft) | Rs. 14,833/-was collected from Sarwan Singh aspenalty towards the violation of CoC.Online Payment |

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
| Details of transfer/payment | ||||
|---|---|---|---|---|
| Particulars | Details | |||
| Name of the transferor | AptechLimited | |||
| Bank Name, branchand Account numberUTR/Transactionreference NumberTransaction date | HDFC Bank Limited,Nariman Pointbranch.Account no.:0001011000036412211780360309-08-2021 | |||
| Transaction Amount (inRs.) | 14,833/- | |||
| In case of Demand Draft (DD): | NA | |||
| Particulars | Details | |||
| Bank Name and branch | ||||
| DD Number | ||||
| DD date | ||||
| DD amount (in Rs.) | ||||
| 9 | Any other relevant information | NIL |
For Aptech Limited
A.K. Biyani Company Secretary and Compliance officer Membership no.: F 8378

| Sr. No. | Particulars | Details |
|---|---|---|
| 1 | Name of the Listed Company/ | Aptech Limited |
| Intermediary/Fiduciary | ||
| 2 | Please tick appropriate checkbox Reporting in | Listed Company |
| capacity of : | ||
| √ Listed Company | ||
| Intermediary | ||
| Fiduciary | ||
| 3 | Details of Designated Person (DP) | |
| Name of the DP | Shajan Samuel | |
| PAN of the DP | AUVPS4664B | |
| Designation of DP | Vice President | |
| Functional Role of DP | National Sales Head | |
| Whether DP is Promoter or belongs to Promoter | No | |
| Group | ||
| If Reporting is for immediate relative of DP | ||
| Name of the immediate relative of DP | NA | |
| PAN of the immediate relative of DP | NA | |
| Details of transaction(s) | ||
| Name of the scrip | AptechLimited | |
| No of shares traded and value (Rs.) (Date-wise) | Date: 29thJuly, 2021 | |
| No. of shares: 500 equity shares | ||
| Value: Rs. 1,41,000/- | ||
| In case value of trade(s) is more than Rs.10 lacs | ||
| in a calendar quarter | ||
| Date of intimation of trade(s) by concerned | Not Applicable, as the value of trade does not | |
| DP/director/promoter/promoter group to | exceed Rs. 10 lacs in a calendar quarter | |
| Company under regulation 7 of SEBI (PIT) | ||
| Regulations, 2015 | ||
| Date of intimation of trade(s) by Company to | Not Applicable, as the value of trade does not | |
| stock exchanges under regulation 7 of SEBI (PIT) | exceed Rs. 10 lacs in a calendar quarter | |
| Regulations, 2015 | ||
| 4 | Details of violations observed under Code of | Shares sold during trading window closure period. |
| Conduct |

| 5 | Action taken by Listed company/ Intermediary/ | Warning letter has been issued to the Designated |
|---|---|---|
| Fiduciary | Person that he would not engage in any kind of | |
| dealings in the Equity Shares of the Company in | ||
| violation of the Company's Code of Conduct and | ||
| SEBI (Prohibition of Insider Trading) Regulations, | ||
| 2015 and a monetary penalty of Rs. 20,800/- | ||
| (Rupees Twenty Thousand Eight Hundred Only) | ||
| out of the profits so earned by him on the said | ||
| shares, has been imposed. | ||
| The aforesaid penalty has been duly submitted to | ||
| the Investor Protection and Education Fund ofSEBI. | ||
| The designated person has also been provided | ||
| again with a copy of Code of Conduct. He has been | ||
| further advised that in case of any subsequent | ||
| violation stricter action(s) would be taken by the | ||
| Company. | ||
| 6 | Reasons recorded in writing for taking action | Matter was discussed with the Chairman of the |
| stated above | audit Committee immediately upon receipt of | |
| information about violation and it was suggested | ||
| by the Audit committee Chairman to issue warning | ||
| letter and levy penalty based on closing price of | ||
| shares on the last day before closing of trading | ||
| window. | ||
| 7 | Details of the previous instances of violations, if | NIL |
| any, since last financial year | ||
| 8 | If any amount collected for Code of Conduct | Rs. 20,800/-was collected from Shajan Samuel as |
| violation(s) | penalty towards the violation of CoC. | |
| Mode of transfer to SEBI -IPEF (Online/Demand | Online Payment | |
| Draft) |

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
| Details of transfer/payment | ||||
|---|---|---|---|---|
| Particulars | Details | |||
| Name of the transferor | Aptech Limited | |||
| Bank Name,branchand Account number | HDFC Bank Limited,Nariman Pointbranch.Account no.:00010110000364 | |||
| UTR/Transaction | 000145123206 | |||
| reference Number | ||||
| Transaction date | 09-08-2021 | |||
| Transaction Amount (inRs.) | 20,800/- | |||
| In case of Demand Draft (DD): | NA | |||
| Particulars | Details | |||
| Bank Name and branch | ||||
| DD Number | ||||
| DD date | ||||
| DD amount (in Rs.) | ||||
| 9 | Any other relevant information | NIL |
For Aptech Limited
A.K. Biyani Company Secretary and Compliance officer Membership no.: F 8378