Aptech Ltd. — Regulatory Filings 2021

Feb 3, 2021

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

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3[rd] February, 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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Jagruti Shah Company Secretary & Compliance Officer Membership no.: F10909 Place: Mumbai

Aptech Limited Regd. office: Aptech House A-65, MIDC, Moroi, 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

**Sr. No. **		Particulars	Particulars	Details
1		Name of the Listed Company~~/~~ ~~Intermediary/Fiduciary~~		Aptech Limited
2		Please tick appropriate checkbox Reporting in capacity of : √Listed Company Intermediary Fiduciary		Listed Company
3		A. Details of Designated Person (DP)
		i. Name of the DP		Shivom Nautiyal
		ii. PAN of the DP		ANCPN0353N
		iii. Designationof DP		Senior Executive- Finance &Accounts
		iv. Functional Role of DP		Senior Executive- Finance &Accounts
		v. Whether DP is Promoter or belongs to PromoterGroup		No
		B. If Reporting is for immediate relative of 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: 18thJanuary, 2021 No. of shares: 50 Value: Rs. 9160/- Date: 25thJanuary, 2021 No. of shares: 100 Value: Rs. 19,995/-
		D. In case value of trade(s) is more than **Rs.10 lacs ina calendar quarter **
		i. Date of intimation of trade(s) by concerned DP/director/promoter/promoter group to Company under regulation 7 of SEBI (PIT) Regulations, 2015		Not Applicable, as the value of trade does not exceed Rs. 10 lacs in a calendar quarter
		ii. Date of intimation of trade(s) by Company to stock exchanges under regulation 7 of SEBI(PIT)Regulations,2015		Not Applicable, as the value of trade does not exceed Rs. 10 lacs in a calendar quarter
4		Details of violations observed under Code of Conduct		Shares sold during trading window closure period.
5		Action taken by Listed compan~~y~~ ~~Fiduciary~~	~~/ Intermediary/~~	Warning letter has been issued to the Designated 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(Prohibitionof Insider Trading)Regulations,

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

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			2015 and a monetary penalty of Rs. 6000/- (Rupees Six Thousand 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 of SEBI. 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.	2015 and a monetary penalty of Rs. 6000/- (Rupees Six Thousand 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 of SEBI. 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 stated above		Matter was discussed with the Chairman of the 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 prior to closing of trading window.
7	Details of the previous instances of violations, if any, sincelastfinancialyear		NIL
8	If any amount collected for Code of Conduct violation(s)		Rs. 6000/- was collected from Shivom Nautiyal as penalty towards theviolationofCoC.
	i. Mode of transfer to SEBI - IPEF (Online/DemandDraft)		Online Payment
	ii. Details of transfer/payment
			Particulars	Details
			Name ofthe transferor	Aptech Limited
			Bank Name, branch and Account number	HDFC Bank Limited, Nariman Point branch. Account no.: 00010110000364
			UTR/Transaction referenceNumber	N033211392801812
			Transactiondate	2ndFebruary,2021
			Transaction Amount (in Rs.)	6000/-

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

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		In case of Demand Draft	(DD): Details	NA
		Particulars	Details
		Bank Name and branch
		DD Number
		DD date
		DDamount (in Rs.)
9		Any other relevantinformation		NIL

Yours faithfully,

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Jagruti Shah Company Secretary & Compliance Officer PAN: ADWPD1514B Email ID: jagruti.shah@aptech.ac.in

Date: 3[rd] February, 2021 Place: Mumbai