sebi:Order/AS/RM/2024-25/31265-31266
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Facts / Headnote
Penalty imposed on both Noticees under Section 15HB of the SEBI Act
Provisions invoked
- s. 11B
- s. 11
- s. 15
- s. 15H
- s. 15J
- s. 15F
- s. 28A
Regulations
- Reg. 3
- Reg. 201
- Reg. 3(1)
- Reg. 3(4)
- Reg. 9
- Reg. 9(1)
- Reg. 8(1)
- Reg. 9(4)
Parties
- Mr. Milan Dalal
- Mr. Moloy Saha
Holding
The Noticees (MD and CEO of Foods and Inns Ltd.) violated Regulation 9(1) read with Schedule B of the PIT Regulations, 2015 by failing to formulate a Code of Conduct to regulate, monitor and report trading by designated persons, and each Noticee was imposed a penalty of ₹2,00,000 under Section 15HB of the SEBI Act.
Full text
Adjudication Order in the matter of Foods and Inns Ltd. Page 2 of 18 APPOINTMENT OF ADJUDICATING OFFICER 2. SEBI appointed undersigned as the Adjudicating Officer (AO), vide communique dated November 21, 2024, under Section 15-I (1) of the SEBI Act, 1992 read with Rule 3 of SEBI (Procedure for Holding Inquiry and Imposing Penalties) Rules, 1995 (hereinafter referred to as 'SEBI Adjudication Rules') to inquire into and adjudge under the provisions of the Section 15HB of the SEBI Act, the violations alleged to have been committed by the Noticees.
Adjudication Order in the matter of Foods and Inns Ltd. Page 3 of 18 (Amendment) Regulations, 2018’. However, upon being asked to provide a copy of the aforesaid Code of Conduct, FIL vide its e-mail dated September 02, 2024 provided a copy of the ‘Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information’.
Adjudication Order in the matter of Foods and Inns Ltd. Page 4 of 18 7. Upon being asked about any other policies formulated by the company towards achieving compliance with PIT Regulations, 2015, Noticee 2 in discussion with Company Secretary and Compliance Officer of the company viz. Mr. Ameya Masurkar during his statement of examination on oath inter alia provided a policy document on ‘Employee Code of Conduct’. The said policy is, however, noted to cover aspects relating to individual conduct, human rights, anti-discrimination, anti-harassment, etc., and not aspects as mentioned under Regulation 9(1) read with Schedule B of PIT Regulations, 2015.
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Source: SecMarx — sebi:Order/AS/RM/2024-25/31265-31266. 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.