sebi:Order/KS/VC/2019-20/4386
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Facts / Headnote
No penalty imposed; violation found but remedial measures already completed
Provisions invoked
- s. 15
- s. 19
- s. 15H
Regulations
- Reg. 9(1)
Parties
- Mr. Sreedhar Yedlapalli
Holding
The Noticee violated Clause 10 of the Code of Conduct under Schedule II read with Regulation 9(1) of PIT Regulations by entering contra trades within the 6-month prohibition period, but no penalty was imposed because the remedial measure of disgorging profits to the SEBI Investor Protection and Education Fund had already been completed.
Full text
Page 2 of 9 persons had prima-facie violated the Code of Conduct prescribed under PIT Regulations. During the course of examination, it was observed by SEBI that Mr. Sreedhar Yedlapalli (hereinafter referred to as ‘Noticee’) had entered into contra trades within prohibition period i.e. within 6 months of earlier trade.
Page 3 of 9 whether the Directors and Designated persons had prima-facie violated the Code of Conduct prescribed under PIT Regulations. b. During the course of Examination, it was observed that the Noticee had entered into the following trades in the scrip of BCL: Table 1 Date of Acquisition/ Sale No. of shares acquired No. of Shares Sold Sale/ Acquisition Value Balance No. of shares held 06-Feb-2018 150 - 12,837.50 150 06-Feb-2018 - 150 13,269.00 - c. In view of Table 1, it is observed that the Noticee had purchased 150 shares of BCL on February 06, 2018. Thereafter, he entered into a contra trade i.e. sale transaction of 150 shares on the same day i.e. February 06, 2018 i.e. within the period of 6 months from the buy transaction. The said alleged contra trades were executed during the examination period and the Noticee earned a profit of Rs. 432/- by those trades. The Noticee has not denied entering in the above said transactions. Further, the Noticee, vide Email dated March 05, 2019, has informed SEBI that he has remitted the profits made out of contra trades i.e. Rs.432/- to SEBI-Investors Protection and Education Fund A/c. d. In view of this, it is alleged that the Noticee had entered into contra trades within prohibition period i.e. within 6 months of earlier trades. Therefore, it is alleged that the Noticee, by entering contra trades within 6 months, has violated the provisions of Clause 10 of Code of Conduct mentioned at Schedule II read with Regulation 9(1) of PIT Re
Page 4 of 9 c. To my memory goes, I might have dealt with shares of BCL, the quantum of shares acquired and sold are too meagre and the profit realized was also too low. d. As a honest and committed person and law abiding citizen, I have remitted the entire profit of Rs. 432/- which arouse out of buy and sale trade of BCL shares to the account of SEBI Investors Protection and Education Fund Account. e. I have no intention or wanton desire to make secret profit or accumulate profit out of buy and sale trade. f. I have not made any profit out of buy and sale trade as specified in your Notice and all the profits made were already transferred to Investors fund account as state above.
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Source: SecMarx — sebi:Order/KS/VC/2019-20/4386. 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.