Firstsource Solutions Ltd. — Regulatory Filings 2022

Jan 25, 2022

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25[th] January 2022

To:

National Stock Exchange of BSE Limited (stock code: India Limited (stock code: 532809) “FSL”) Phiroze Jeejeebhoy Towers, Exchange Plaza, Dalal Street, Plot no. C/1, G Block, Mumbai - 400 001 Bandra-Kurla Complex, Bandra (East) Mumbai - 400 051.

Dear Madam/ Sir,

Sub.: Reporting of violations under SEBI (Prohibition of Insider Trading) Regulations, 2015 and action taken by the Company

This is to inform you that in terms of the SEBI (Prohibition of Insider Trading) Regulations, 2015 (“the SEBI Regulations”), Firstsource Solutions Code of Conduct for Prohibition of Insider Trading (“the Code”), and SEBI Circular No. SEBI/HO/ISD/ISD/CIR/P/2020/135 dated 23[rd] July, 2020; the details of violation of the Code by the Designated Person along with the action taken by the Company thereon are enclosed as “Annexure A” to this letter.

You are kindly requested to take the above on record.

Thanking you,

For Firstsource Solutions Limited

Digitally signed by POOJA POOJA SURESH SURESH NAMBIAR NAMBIAR Date: 2022.01.25 19:49:24 +05'30'

Pooja Nambiar Company Secretary & Compliance Officer

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Annexure A

Report by Firstsource Solutions Limited for violations related to Code of Conduct under SEBI (Prohibition of Insider trading) Regulations, 2015

Sr. No.	Particulars			Details
1.	Name of the listed Company/	~~Intermediary/~~	~~Fiduciary~~	Firstsource Solutions Limited
2.	Please tick appropriate Checkbox. Reporting in capacity of: ✔Listed Company Intermediary Fiduciary			-
3.	A. Details of Designated Person (DP)
	i. Name of the Designated Person (DP)			Mr. Randall Shafer
	i. PAN of the DP			KECPS9381N
	iii. Designation of DP			EVP
	iv. Functional Role of DP			EVP & Global Head of Hospital Business, Eligibility Services.
	v. Whether DP is Promoter or belongs to Promoter			No
	B. If Reporting is for immediate relative of DP
	i. Name of the immediate relative of DP			N.A.
	ii. PAN of the immediate relative of DP			N.A.
	C. Details of transaction(s)
	i. Name of the scrip			FSL
	ii. No of shares traded and value (Rs.) (Date- wise)			81,000 shares sold at a price of 215.66 per share on 18thOctober 2021.
	D. In case value of trade(s) is more than Rs.10 lacs in a calendar quarter
	i. Date of intimation of trade(s) by concerned DP/director/promoter/promoter group to Company under Regulation 7ofSEBI(PIT)Regulations, 2015.			N.A.
	ii. Date of intimation of trade(s) by Company to Stock Exchanges under Regulation 7 of SEBI (PIT) Regulations, 2015.			N.A.
4.	Details of violations observed under Code of Conduct			Transaction done during closure of Trading Window Period.

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5.	Action taken by Listed Company/	~~Intermediary/~~	~~Fiduciary~~	The matter was referred to the Audit Committee of the Company and accordingly a stern warning letter has been issued to the Designated Person that he should 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 INR 1,632,960/- (Rupees Sixteen Lakhs Thirty Two Thousand Nine Hundred Sixty Only) as agreed by the Audit Committee of the Company, has been imposed. The aforesaid penalty shall be duly submitted to the Investor Protection and Education Fund of SEBI. 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			Based on our findings and the response received from the Designated Person, it was noted that this incidence was the first instance of violation on the part of the Designated Person wherein he liquidated the holdings during closure of trading window period. The penalty levied on the Designated Person is commensurate to the nature of violation and the quantum of shares involved. Further, the Designated Person has been warned to be extra cautious while executing transactions in future and ensure compliance of Code of Conduct and SEBI (Prohibition of Insider Trading) Regulations, 2015 for himself, immediate relatives and dependents and he has been advised to undergo a training for compliances to be adhered under SEBI (Prohibition of Insider Trading) Regulations, 2015.
7.	Details of previous instances of violations, if any, since last financial year			None
8.	If anyamount collected for Code of Conduct violation(s):
	i. Mode of transfer to SEBI - IPEF (Online/Demand Draft)			As stated above the Company has communicated to the concerned Designated Person about levy of penalty and as soon as it is collected by the Company and transferred to SEBI – IPEF the same shall be informed to the Stock Exchanges promptly.

	ii. Details of transfer/payment Incase of Online: Particulars Details Name of the transferor Bank Name, branch and Account number UTR/Transaction reference Transaction date Transaction Amount(in Rs.) Incase of Demand Draft (DD): Particulars Details Bank Name and branch DD Number DD date DD amount(in Rs.)	ii. Details of transfer/payment Incase of Online: Particulars Details Name of the transferor Bank Name, branch and Account number UTR/Transaction reference Transaction date Transaction Amount(in Rs.) Incase of Demand Draft (DD): Particulars Details Bank Name and branch DD Number DD date DD amount(in Rs.)	As stated above the Company has communicated to the concerned Designated Person about levy of penalty and as soon as it is collected by the Company and transferred to SEBI – IPEF the same shall be informed to the Stock Exchanges promptly.
	Particulars	Details
	Bank Name and branch
	DD Number
	DD date
	DD amount(in Rs.)
9.	Any other relevant information		None

Yours Faithfully,

Digitally signed by POOJA SURESH POOJA SURESH NAMBIAR NAMBIAR Date: 2022.01.25 19:49:44 +05'30'

Name and signature of Compliance Officer: Ms. Pooja Nambiar

Email id: Pooja.nambiar@firstsource.com Contact No.: 022 66660888 Date: 25[th] January 2022 Place: Mumbai

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