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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