GACM Technologies Limited — Regulatory Filings 2021

Aug 14, 2021

To. The Secretary. Listing Department BSE Limited P.J Towers, Dalal Street, Fort. Mumbai - 400 001

To. The Manager. Listing Department. National Stock Exchange of India Limited Exchange Plaza, 5thFloor, Plot No. C/1, G Block Bandra-Kurla Complex, Bandra (E), Mumbai-400051, Maharashtra. Symbol: STAMPEDE / SCAPDVR

Scrip Code: 531723 / 570005

Subject: Reporting Violation of Company's Code of Conduct under SEBI (Prohibition of Insider Trading) Regulations2015.

Reference: SEBI Circular No. SEBI/HO/ISD/CIR/P /2020/135 dated July 23, 2020

Dear Sir / Madam.

In furtherance to the captioned subject and reference, please find enclosed herewith the report in the prescribed form hereto marked and annexed as $Annexure = A under SEBI$ (Prohibition of Insider Trading) Regulations, 2015 by the Company containing details of violation by Designated Person by dealing in Equity Shares with Differential Voting Rights of the Company.

We request you to take the above on your record.

Thanking You, Yours faithfully,

For and on behalf of Stampede Capital Limited

Mr. Srimvas Maya Whole Time Director and Compliance Officer Date : August 13, 2021 Place : Hyderabad Encl $t$ a/a

Registered Office; KURA Towers, 10thFloor, D. No.1-11-254 and 1-11-255, S.P. Road. Begumpet, Secunderabad-500016, Telangana, India CIN: L67120TG1995PLC020170

Annexure -A

Report by Stampede Capital Limited (Company) for violations related to code of Conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015 (SEBI PIT Regulations, 2015).

		Annexure -A
	Report by Stampede Capital Limited (Company) for violations related to code of Conduct under
	SEBI (Prohibition of Insider Trading) Regulations, 2015 (SEBI PIT Regulations, 2015).
Sr. No.	Particulars	DETAILS
1	Name of the listed Company/I Tiduci Li	Stampede Capital Limited
	Please tick appropriate check box Reporting in capacity of:
2	L] Listed Company	Listed Company
	LI Intermediary
	L] Fiduciary
	Details of Designated Person(DP) A.
		Holdings Limited Private Gayi Adi and. Management Trends Private
	__ Name ofthe DP i.	Limited)
	PANofthe DP ii.	AAHCG3348M
	Designation of DP iii.	Promoter
	Functional Role of DP iv.	-
	Whether DP is Promoter or belongs to v. Promoter Group	Yes
3	If Reporting is for immediate relative of DP: N.A. B.
	Name ofthe immediate relative of DP i.
	PAN of the immediate relative of DP ii.
	Details of transaction(s) C. Name ofthe scrip i.	Shares Voting Equity with Differential Right (DVR Shares) of Stampede Capital Limited

intimation Date of of i. concerned trade(s)by DP/director/promoter/promot Company under group er to regulation SEBI (PIT) of 7 Regulations, 2015	August 10, 2021
ii. Date of intimation of trade(s) by Company exchanges stock to under regulation (SEBI of 7 PIT Regulations, 2015)	August 12, 2021
Details of violations observed under Code of Conduct	Sold 4,78,574 DVR Shares on August 06, 2021@ A. Rs. 3/- Per shares when the trading window was closed. Sold 5,24,290 DVR Shares on August 06, 2021@ Rs. 3.15/- Per shares when the trading window was closed.
Action taken Listed by company/Intermediary/Fiduciary	Pursuant to the provision of (SEBI PIT Regulations, 2015), The violation as disclosed above was placed before the Audit Committee of the Company in its August meeting The Audit 2021. held on 10, Committee pursued the violation and resolved that: A warning letter be issued by the Company to A. (Formerly Holdings Limited Private Gayi Adi Management known GayiAdi Trends and as Designated Person Private Limited), the of Company that it would not be engaged in any of dealings Equity Shares kind the of the in Company which violation shall be the of in Company's Conduct Code and _ SEBI of (Prohibition Trading) Regulations, Insider of 2015. A warning letter be issued by the Company to B. Gayi Adi Holdings Limited to be extra Private executing cautious transactions while the in compliance ensure Code future and of of Conduct and SEBI (Prohibition Insider of Regulations, 2015 Trading) and in case of any subsequent violation stricter action(s) will be taken by the Company. monetary 20,000/ (Rupees penalty A of Rs. C. Twenty Thousand Only) be levied on the said violation.

	On August 10, 2021, it was brought to the attention
	of the Compliance Officer of the Company that Gayi Adi Holdings Private Limited, Designated Person of
	Stampede Limited, had inadvertently, Capital through its Stock Broker, sold 4,78,574 DVR shares
	on August 06, 2021, @ Rs. 3/- Per DVR share and DVR shares on August 06, 2021, @ sold 5,24,290
	DVR share without obtaining pre 3.15/- Per Rs. ("Trade"). The Trade occurred clearance of trade
	when the trading window was closed.
	Trade Broker The was carried Stock out by the without the knowledge of Gayi Adi Holdings Private
	Limited. In Stock Broker services, the investor does not generally monitor the investment day-to-day
	Holdings decisions. case Gayi Adi as well, In this Private Limited had given no instruction to conduct
Reasons recorded in writing for	knowledge Trade and had the also no of the it Trade having Broker occurred. The Stock
taking action stated above	unilaterally took the decision to conduct the Trade.
	The Audit Committee Company's Board of of the Directors, which responsible review of for the is
	compliance with the Insider Trading Policy of the Company was notified of this matter. Based on the
	submission Holdings Limited, Private of Gayi Adi Committee was Audit believes, that the an this
	inadvertent Trade made without intent to violate the Company's Insider Trading Policy or the SEBI
	(Prohibition of Insider Trading) Regulations, 2015 ("PIT Regulations").
	However, the Audit Committee has determined that
	Company's was there violation Insider of the a Trading Regulations and and Policy PIT the
	therefore a penalty must be imposed on Gayi Adi Holdings Private Limited.
Details of the previous instances of violations, if any, since last financial	NA
year If any amount collected for Code of Conduct violation(s)
Mode of transfer to SEBI- i.	The penalty will be remitted via permitted mode to

. Details of transfer/payment (In case of Online): In case of Demand Draft(DD): Particulars Bank Name and branch DD Number DD date DD amount (in Rs. other relevant information Any 9 Thanking You, Yours faithfully, behalf of Stampede For and on Capital Limited as Maya Mr. Whole Time Director and Compliance Officer : August 13, 2021 : Hyderabad		accordingly.
Date Place

For and on behalf of Stampede Capital Limited

Mr. as Maya Whole Time Director and Compliance Officer