Aptech Ltd. — Regulatory Filings 2022

Aug 9, 2022

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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COMPLIANCE CERTIFICATE FOR THE QUARTER ENDED JUNE 30, 2022

(Pursuant to Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015)

I, Akshar Biyani , Compliance Officer of the company, have examined the following compliance requirement of Aptech Limited (Company) and certify that the Company has maintained a Structured Digital Database (SDD) pursuant to provisions of Regulation 3(5) and 3(6) of Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 (PIT Regulations):

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Sr. Compliance Requirement Yes/No Observation/ Remark
No
1. Whether the Company has a Structured Yes
Digital Database in place?
2. Whether control exists as to who can access Yes
the SDD for read/ write alongwith the names
and PAN of such person?
3. Whether all the UPSI have been captured in Yes
the Database. If not details of events
that have not been captured and the reason
for the same?
4. Whether the recipient were upfront informed Yes
that the information which they will be
receiving shortly is UPSI and the entry has
been captured in the Database prior to
forwarding the UPSI data. If not details of
events that have not been captured and the
reason for the same?
5. Whether nature of UPSI have been captured Yes
alongwith date and time?
6. Whether name of persons who have shared Yes
the information has been captured along with
PAN or any other identifier?
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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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7. Whether name of persons with whom information is shared has been captured along with PAN or any other identifier?	7. Whether name of persons with whom information is shared has been captured along with PAN or any other identifier?	Yes
8. Whether the database has been maintained internally?		Yes
9. Whether audit trail is maintained?		Yes
10. Whether time stamping is maintained?		Yes
11. Whether the database is non-tamperable?		Yes
12.	Any other measures to ensure non- tamperability of the Database?	Yes	Further, we endeavour to improvise the digital initiative in the SDD.

Note: The information of the audit should cover the period when such information was inserted in the SDD upto the date of disclosure.

The number of days for which non-compliance was observed:

Further I also confirm that the Company was required to capture 2 number of events during the quarter/half year ended and has captured 2 number of the said required events.

For Aptech Limited

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Akshar Biyani Compliance Officer of the company Date: 09-08-2022 Place: Mumbai

Note: The attached certificate should cover events which have been disclosed by the listed entity to the stock exchange so that the secretarial auditor will not be exposed to UPSI.

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