Aptech Ltd. — Regulatory Filings 2022

May 2, 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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02[nd] May, 2022

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 Compan y/ 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 Kallol MukherjeePAN of the DP AJQPM7160Aii. Designation of DPiii. Functional Role of DPiv. Whether DP is Promoter or belongs to NoPromoter GroupB. If Reporting is for immediate relativeof 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: 01 [st] April, 2022- 15 [th] April, 2022(Date- wise) No. of shares: 27 equity shares were beenpurchasedValue: 9740/-D. In case value of trade(s) is more thanRs.10 lacs 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 group toCompany 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,20154 Details of violations observed under Code of Shares bought during trading window closureConduct period.----- 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 ----- 5 Action taken by Listed compan y/ Intermediary/ Warning letter has been issued to the DesignatedFiduciary Person 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. 9740/-(Rupees Nine thousand seven hundred and fortyOnly), has been imposed having value of trade.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 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 suggested bythe Audit committee Chairman based on counseladvise to issue warning letter and levy penaltybased on value of trade.7 Details of the previous instances of violations, if NILany, since last financial year8 If any amount collected for Code of Conduct Rs. 9740/- was collected/ received from Kallolviolation(s) Mukherjee on 02-05-2022 as penalty towards theviolation of CoC.i. Mode of transfer to SEBI - IPEF Online Payment(Online/Demand Draft)ii. Details of transfer/paymentParticulars DetailsName of the transferor Aptech LimitedBank Name, branch HDFC Bank Limited,and Account number Nariman Pointbranch.Account no.:00600330009091UTR/Transaction N122221940506929reference NumberTransaction date 02-05-2022Transaction Amount (in 9740/-Rs.)----- 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 ----- 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 : May 02,2022 Place : Mumbai

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