NIIT : Code of conduct under SEBI (PIT) Regulations

August 4, 2022
The Manager	The Manager
National Stock Exchange of India Ltd	BSE Limited
Listing Department	Corporate Relationship Department,
Exchange Plaza	1st Floor, New Trading Ring,
5th Floor, Plot no C/1, G Block	Rotunda Building
Bandra Kurla Complex	Phiroze Jeejeebhoy Towers,
Bandra (E), Mumbai - 400 051	Dalal Street, Mumbai- 400 001

Sub: Reporting of non-compliance by Designated Person of NIIT Code of Conduct to Regulate, Monitory and Report Trading by Designated Person as required by SEBI (Prohibition of Insider Trading) Regulations, 2015

Scrip Code : BSE - 500304; NSE - NIITLTD

Dear Sir,

This is with reference to the above-mentioned subject.

Please find attached herewith a Report (in prescribed format) on non-compliance by Designated Persons of NIIT Code of Conduct to Regulate, Monitory and Report Trading by Designated Person as required by SEBI (Prohibition of Insider Trading) Regulations, 2015.

Kindly acknowledge the receipt. Thanking you,

Yours truly,

For NIIT Limited

Deepak Bansal

Company Secretary &

Compliance Officer

Encs: a/a

Report by NIIT Limited for violations related to Code of Conduct under SEBI (Prohibition of Insider Trading)

Regulations 2015

S.No.			Particulars		Details
1. Name of the listed company/Intermediary/Fiduciary		NIIT Limited
2.		Please tick appropriate checkbox		Listed Company
	Reporting In Capacity Of:
			Listed Company
			Intermediary
			Fiduciary
3.		A. Details of Designated Person (DP)
		i. Name of the DP		Vaibhav Behl
		ii. PAN of the DP			AOZPB7685M
		iii. Designation of DP		Senior Manager
		iv. Functional Role of DP		Member - Internal Audit Team
		v. Whether DP	is Promoter or belongs to Promoter		No
		Group
		B. If Reporting is for immediate relative of DP		Not applicable
		i. Name of the immediate relative of DP	-
		ii. PAN of the immediate relative of DP	-
		C. Details of transaction(s)
		i. Name of the scrip		Equity Share of NIIT Limited
		ii. No. of shares traded and value (Rs.) (Date- wise)		Purchase :
					June 01, 2022: 409 equity shares, Rs. 194,286.85

Sale:

June 17, 2022; 409 equity shares; Rs. 152,016.05

D. In case value of trade(s) is more than Rs. 10 lacs in a calendar quarter -

	i. Date of intimation of trade(s) by concerned DP/	Not applicable
	director/ Promoter/ Promoter Group to Company under
	regulation 7 of SEBI (Prohibition of Insider Trading)
	Regulations 2015
	ii. Date of intimation of trade(s) by Company to Stock	Not applicable
	Exchange under regulation 7 of SEBI (Prohibition of
	Insider Trading) Regulations 2015

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4.		Details of violations observed under SEBI (Prohibition of		Contra Trade i.e., selling	Company shares within 6
		months of buying the same as per Clause 11.1 of NIIT
		Insider Trading) Regulations 2015
			Code (as per compliance of Clause 10 of Schedule B of
					SEBI (Prohibition of Insider Trading) Regulations, 2015)
5.		Action taken by Listed Company/ Intermediary/		The Company has taken	following actions against
		Fiduciary			Mr. Vaibhav Behl:
					- Levied a monetary penalty of Rs. 10,000/-, to be
					deposited in SEBI-IPEF account.
					- Issued warning letter to be more cautious in future
					or face severe consequences and to comply with
					the provisions of the Code in letter and spirit.
6.		Reasons recorded in writing for taking action stated		- The first transaction of PURCHASE & the contra
		above			trade of SALE transaction were done in the same
					month instead of giving a gap of six months, as per
					the Company's PIT Code.
					- Both transactions were done while trading window
					was open
					- Taken together, DP did not make any profit;
					instead, a loss of Rs. 42,270.80
					- DP confirmed that he was not holding UPSI
					- The value of the transactions were lower than the
					threshold set for taking pre-clearance from the CO
					- This was the first time this DP has dealt in the
					Company's shares
					- First instance of non-compliance by this DP
					- Present lapse appeared to be an inadvertent action
					and did not seem to reflect any mala-fide intent on
					the part of DP
7.		Details of the previous instances of violations, if any,		None
		since last financial year
8.		If any amount collected for Code of Conduct violation(s)		Yes
		i. Mode of transfer to SEBI - IPEF		Online transfer
		ii. Details of transfer/payment made On-line
		Particulars	Details
					Name of the transferor	Vaibhav Behl
					Bank Name, branch and	ICICI Bank -
					Account number	xxxxxxxxx48
					UTR/ Transaction	456947034
					reference number
					Transaction date	01-08-2022
					Transaction Amount (in	Rs. 10,000.00
					Rs.)
9.		Any other relevant information		N.A.
	Yours Faithfully,
	Name of Compliance Officer: Deepak Bansal
	PAN: ABTPB4125B
	Email ID:[e-mail]
	Date: August 4, 2022	Place: Delhi
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