sebi:Order/PM/PA/2021-22/14399

SEBI · SEBI · 2021-05-07 · Prasanta Mahapatra, Adjudicating Officer

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Facts / Headnote

Violation established; penalty of Rs.5,00,000 imposed under Section 15HB of the SEBI Act, 1992

Provisions invoked

Regulations

Parties

Holding

The Noticee, as a designated person, violated clause 6 of the Code of Conduct read with regulation 9(1) of the PIT Regulations by executing 9 transactions exceeding the Rs.10 lakh threshold without pre-clearance. A monetary penalty of Rs.5,00,000 under section 15HB of the SEBI Act was imposed.

Full text

Adjudication order in respect of Ashok Dal & Oil Mills Page 2 of 21 in the matter of Sanwariya Consumer Ltd. Code of Conduct to Regulate, Monitor and Report Trading by Insiders specified in Schedule B (hereinafter referred to as “Code of Conduct”) read with regulation 9(1) of the PIT Regulations by not obtaining pre-clearance from the Company before carrying out 9 transactions which triggered the requirement of obtaining pre-clearance as per the threshold prescribed by the board of directors of the Company. In view of the above, adjudication proceedings were initiated against the Noticee.

Adjudication order in respect of Ashok Dal & Oil Mills Page 3 of 21 in the matter of Sanwariya Consumer Ltd. (i) It was observed that the Noticee is being governed by the terms of the partnership deed dated April 01, 2010 submitted by the Company vide email dated October 24, 2018 wherein Gulab Chand Agrawal is one of its partners who was also an executive chairman of the Company during the IP.

Adjudication order in respect of Ashok Dal & Oil Mills Page 4 of 21 in the matter of Sanwariya Consumer Ltd. the above, it was observed that ADOM being a designated person under the provisions of PIT Regulations was required to take pre-clearance from the Company before carrying out the aforesaid transactions.

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Source: SecMarx — sebi:Order/PM/PA/2021-22/14399. 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.