Dynamatic Technologies Ltd. — Legal Proceedings Report 2020

Jun 17, 2020

DYNAMATIC TECHNOLOGIES LIMITED

....•.

17thJune 2020

• 1. The Secretary Bombay Stock Exchange Limited Phiroze Jeejeebhoy Towers Dalal Street, MUMBAI 400 001. Fax No. 022 - 22723121/3719/2037/2039/2041 12061
• 1. The Secretary National Stock Exchange of India Limited "Exchange Plaza", Bandra-Kurla Complex Bandra East, MUMBAI 400 051. Fax No.022 - 26598237 138/26598346

Sub: Impounding Order issued by SEBI for Insider Trading

Dear Sir/Madam,

This has reference to the Impounding Order No: WTM/GMIIVD/11/2020-21 dated 15thJune 2020, issued in the name of Dr. Udayant Malhoutra, CEO & Managing Director of our Company.

In this context, please find enclosed the clarification note received from our CEO and Managing Director in respect to the aforesaid subject.

We request you to take this on record.

Sincerely, :r~t:;:igieS Limited

Shivaram V Head- Le ai, Compliance Officer and Company Secretary

Dynamatic Park Peenya Bangalore 560 058 India Tel +91 8028394933/34/35 Fax +91 8028395823 www.dynamatics.com

UDAYANT MALHOUTRA

To,

17th June 2020

Mr. Shivaram V Head - Legal, Compliance and Company Secretary Dynamatic Technologies Limited Bangalore -560058

Sub: Impounding Order No: WTMlGMlIVD11112020-21 dated 15th June 2020, issued in my name by Securities and Exchange Board ofIndia (SEBI).

Dear Shivaram,

I received an email from SEBI yesterday relating to a small divestment I had made during October 2016. This was the first direct communication I have received from SEBI on this matter. It was therefore surprising to receive an ex-parte interim order cum show cause notice alleging that this transaction had violated Insider Trading Rules.

For the record I would like to clarify;

• 1. The share sale was executed through NSE and BSE while the trading window was open.
• 1. The transaction had pre-trading approval from the compliance officer, and all relevant disclosures were made to stock exchanges.
• 1. All relevant taxes were paid in connection with this transaction.
• 1. I was not in possession of any unpublished price sensitive information (UPSI). It appears that SEBI's prima-facie opinion is based on mere conjecture, and is not supported by any facts.

Lastly, given that the interim order is also accompanied by a show cause notice, the impounding order appears to be premature.

I have been legally advised, and am contesting this order based on the facts.

Yours Sincerely,

Udayant Malhoutra