sebi:ORDER/PM/RR/2019-20/7065
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Facts / Headnote
Noticee held liable for violation and monetary penalty of Rs 2,00,000 imposed under Section 15HB of SEBI Act, 1992
Provisions invoked
- s. 15
- s. 15H
- s. 15J
Regulations
- Reg. 12(1)
- Reg. 199
- Reg. 12
- Reg. 201
Parties
- Anirudh P Sethi
Holding
The Noticee, as Executive Director from May 14, 2014, failed to frame and implement the Code of Conduct and thereby violated Regulation 12(1) read with Clause 1.2 of Schedule I, Part A of PIT Regulations, 1992 read with Regulation 12 of PIT Regulations, 2015, and is liable to a monetary penalty of Rs 2,00,000 under Section 15HB of the SEBI Act.
Full text
Adjudication Order against Anirudh P Sethi in the matter of Alexander Stamps and Coin Limited Page 2 | 13 violation of Regulation 12(1) read with Clause 1.2 of Schedule 1, Part A of PIT Regulations, 1992 read with Regulation 12 of PIT Regulations, 2015 by the Noticee.
Adjudication Order against Anirudh P Sethi in the matter of Alexander Stamps and Coin Limited Page 3 | 13 e) As per provisions of Schedule I (Part A) of SEBI (PIT) Regulations, 1992, the Compliance officer shall be responsible for the implementation of Code of conduct under the overall supervision of the Board of the listed company. f) The Noticee, being a director of the Company, had failed to ensure the implementation of the Code of Conduct as required under SEBI (PIT) Regulations, 1992. Therefore, the Noticee has been alleged of violation of Regulation 12(1) read with Clause 1.2 of Schedule 1, Part A of SEBI (PIT) Regulations, 1992 read with Regulation 12 of SEBI (PIT) Regulations, 2015.
Adjudication Order against Anirudh P Sethi in the matter of Alexander Stamps and Coin Limited Page 4 | 13 e) The alleged technical lapse was not deliberate and intentional and in contumacious disregard of provisions of law f) I have not indulged in any manipulative, fraudulent or unfair trade practices g) I have not made any gains or derived any unfair advantage as a result of alleged technical and minor lapse. Even there is no allegation that I have gained in any manner as a result of alleged lapse h) I submit that the allegations pertain to technical and procedural lapses which are venial in nature. I am committed to complying with the law and request that the procedural lapses be viewed leniently and no penalty be imposed on me.
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Source: SecMarx — sebi:ORDER/PM/RR/2019-20/7065. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (bench, timelines, appeal chain) is cited to us.