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Trigyn Technologies Limited Insider Trading Policy

Trigyn Technologies Limited (the “Company”) is a public company whose equity shares are listed on National Stock Exchange of India Limited and BSE Limited and subject to the rules and Regulations issued by the Securities and Exchange Board of India (SEBI).

The Board of Directors of the Company have adopted this Insider Trading Policy (the “Policy”) to comply with the SEBI (Prohibition of Insider Trading) Regulations, 2015 including any Statutory Modification or Re-enactment thereof for the time being in force). (“SEBI Regulations”)

The SEBI Regulations prohibit an Insider from Trading in the securities of a company listed on any stock exchange on the basis of any unpublished price sensitive information.

Unpublished Price Sensitive Information (“UPSI”) means any information which relates directly or indirectly, to the Company or its securities, that is not generally available which upon becoming generally available, is likely to materially affect the price of the securities of the Company.

“Generally available” information means information that is accessible to the public on a nondiscriminatory basis.

The SEBI Regulations prohibit the communication of Unpublished Price Sensitive Information (UPSI) to any person except as required under law. Further, procuring any person to Trade in the securities of any company on the basis of UPSI is also prohibited under the SEBI Regulations and the securities laws. Violations of the SEBI Regulations and the securities laws subject Insiders to severe penalties including fines and imprisonment.

  1. Rules
    The rules shall be called ‘Rules for Trading in the securities of Trigyn Technologies Limited by an Insider’ (“Rules”). These Rules shall come into force with immediate effect.

  2. Definitions
    Words and expressions used but not defined in this Code shall have the same meaning assigned to them in the SEBI (Prohibition of Insider Trading) Regulations, 2015 or the Securities and Exchange Board of India Act, 1992, the Securities Contracts (Regulation) Act, 1956, the Depositories Act, 1996 or the Companies Act, 2013 and the rules and regulations made thereunder, as the case may be or in any amendment thereto.

    In this rules unless the context otherwise requires, the following words, expressions and derivations therefrom shall have the meanings assigned to them as under:–
     
    • 2.1 “Act” means the Securities and Exchange Board of India Act, 1992.
    • 2.2 “Board” means the Board of Directors of the Company.
    • 2.3 “Company” means Trigyn Technologies Limited.
    • 2.4 "Compliance Officer" means Company Secretary or such other senior officer, designated so, who is financially literate and is capable of appreciating requirements for legal and regulatory compliance under these regulations and reporting to the Board of Directors and who shall be responsible for compliance of policies, procedures, maintenance of records, monitoring adherence to the rules for the preservation of unpublished price sensitive information, monitoring of trades and the implementation of the codes specified in these regulations under the overall supervision of the Board of Directors of the Company.
    • 2.5 “Connected Person” means:
      • (i) any person who is or has during the six months prior to the concerned act been associatedwith a company, directly or indirectly, in any capacity including by reason of frequentcommunication with its officers or by being in any contractual, fiduciary or employmentrelationship or by being a director, officer or an employee of the Company or holds anyposition including a professional or business relationship between himself and theCompany whether temporary or permanent, that allows such person, directly orindirectly, access to unpublished price sensitive information or is reasonably expected toallow such access.
      • (ii) Without prejudice to the generality of the foregoing, the persons falling within the following categories shall be deemed to be connected persons unless the contrary is established,
        • a. an immediate relative of connected persons specified in clause (i); or
        • b. a holding company or associate company or subsidiary company; or
        • c. an intermediary as specified in Section 12 of the Act or an employee or director thereof; or
        • d. an investment company, trustee company, asset management company or an employee or director thereof; or
        • e. an official of a stock exchange or of clearing house or corporation; or
        • f. a member of board of trustees of a mutual fund or a member of the board of directors of the asset management company of a mutual fund or is an employee thereof; or
        • g. a member of the Board of directors or an employee, of a public financial institution as defined in section 2 (72) of the Companies Act, 2013; or
        • h. an official or an employee of a self-regulatory organization recognised or authorized by the Board; or
        • i. a banker of the Company; or
        • j. a concern, firm, trust, Hindu Undivided Family, company or association of persons wherein a director of the Company or his immediate relative or banker of the Company, has more than ten per cent, of the holding or interest.
    • 2.6 Designated Person (s) shall include following persons:
      • a. Directors of the Company and its subsidiary;
      • b. Key Managerial Personnel (KMP’s) as per the Companies Act, 2013;
      • c. All promoters of the Company and promoters who are individuals or investment companies for intermediaries or fiduciaries;
      • d. Every employee in the grade of General Manager and above;
      • e. Every employee in the grade of Manager and above in the Accounts, Taxation, Treasury, Finance, Legal, IT and Secretarial Departments of the Company and in the Corporate Office or any other support staff who have access to unpublished price sensitive information;
      • f. Employee upto two levels below KMP of intermediary, fiduciary and material subsidiary irrespective of their functional role or ability to have access to unpublished price sensitive information;
      • g. Employees of material subsidiaries of the Company designated on the basis of their functional role or access to unpublished price sensitive information in the organization by their board of directors;
      • h. Employees of intermediaries or fiduciaries designated on the basis of their functional role or access to unpublished price sensitive information in the organization by their board of directors or analogous body;
      • i. Any other employee as may be determined and informed by the Compliance Officer from time to time.
    • 2.7 “Insider Trading Policy” means Insider Trading Policy as approved by the Board of Directors of the Company as amended from time to time.
  3. Prohibition on communicating or procuring UPSI
    An Insider shall not –

    Provided that nothing contained above shall be applicable when an UPSI is communicated, provided, allowed access to or procured:

    • i. communicate, provide, or allow access to any UPSI, relating to the Company or its securities, to any person including other insiders, except to the extent allowed by these Rules;
    • ii. procure from or cause the communication by an Insider of UPSI, relating to the Company or its securities;
    • i. in furtherance of legitimate purposes, performance of duties or discharge of legal obligations pursuant to appropriate confidentiality and non-disclosure agreements being executed; or
    • ii. in the event the Board of Directors direct or cause the public disclosure of UPSI in the best interest of the Company; or
    • iii. within a group of persons if such persons have been identified and secluded within a“chinese wall” or information barrier by the Compliance Officer from the rest of theCompany for a particular purpose or for a specified period of time in furtherance oflegitimate purposes, performance of duties or discharge of legal obligations, and aresubjected to, among other conditions, additional confidentiality obligations, informationbarriers designed to prevent exchanges of UPSI outside the “chinese wall”, and theexecution of an undertaking by such persons to abstain and / or forego Trading duringsuch seclusion or till the UPSI no longer constitutes UPSI.
  4. Prohibition on Insider Trading
    An Insider shall not, directly or indirectly: –

    Provided the restriction in 4 (i) above shall not apply to:

    • i. Trade in securities that are listed or proposed to be listed when in possession of UPSI;
    • ii. Trade in securities of the Company except when the Trading Window is open and the Insider is not in possession of UPSI.
    • (a) A transaction that is an off-market inter-se transfer between Promoters who were in possession of the same UPSI without being in breach of these Rules and both parties had made a conscious and informed trade decision; and
    • (b) Trades pursuant to a Trading Plan set up in accordance with these Rules.
  5. Trading Window
    • 5.1 The trading period, i.e. the trading period of the stock exchanges, called ‘trading window”, is available for trading in the Company’s securities.
    • 5.2 The trading window shall be closed as per the provisions of PIT regulations.
    • 5.3 When the trading window is closed, the Designated Persons shall not trade in the Company’s securities in such period.
    • 5.4 All Designated Persons shall conduct all their dealings in the securities of the Company only in a valid trading window and shall not deal in any transaction involving the purchase or sale of the Company’s securities during the periods when the trading window is closed, as referred to in Point No. (ii) above or during any other period as may be specified by the Company from time to time.
    • 5.5 The Compliance Officer shall intimate the closure of trading window to all the designated employees of the Company when he determines that a designated person or class of designated persons can reasonably be expected to have possession of UPSI. Such closure shall be imposed in relation to such securities to which such UPSI relates.
    • 5.6 The Compliance Officer after taking into account various factors including the UPSI in question becoming generally available and being capable of assimilation by the market, shall decide the timing for re-opening of the trading window, however in any event it shall not be earlier than 48 hours (Forty eight hours) after the information becomes generally available either through NSE/BSE or newspaper publication whichever is earlier.
    • 5.7 The trading window shall also be applicable to any person having contractual or fiduciary relation with the Company, such as auditors, accountancy firms, law firms, analysts, consultants etc., assisting or advising the Company.
  6. Pre- clearance of Trading
    1. Designated Persons may Trade in the securities of the Company when the trading window is open, after obtaining approval of the Compliance Officer by submitting an application as per Annexure 1 and an undertaking as per Annexure 2.
    2. The Compliance Officer shall not approve any proposed Trade by Designated Person if the Compliance Officer determines that such Designated Person is in possession of UPSI even though the trading window is open.
    3. The Compliance Officer may, after being satisfied that the application and undertaking are true and accurate, approve Trading by a Designated Person, on the condition that the Trade so approved shall be executed within seven trading days following the date of approval as per Annexure 3.
    4. The Designated Person shall, within two days of the execution of the Trade, submit the details of such Trade to the Compliance Officer as per Annexure 4. In case the transaction is not undertaken, a report to that effect shall be filed in the said form.
    5. If the pre-cleared Trade is not executed within seven trading days after the approval is given, the Designated Person must secure pre-clearance of the transaction again.
    6. A Designated Person who Trades in securities without complying with the pre-clearance procedure as envisaged in these Rules or gives false undertakings and/or makes misrepresentations in the undertakings executed by him/her while complying with the preclearance procedure shall be subjected to the penalties as envisaged in these Rules.
    7. Nothing in this rule shall apply to any Trade involving a value less than Rs. 5 Lakhs or such other amount as may be specified by the Board of Directors from time to time (a “de minimis Trade”) provided the Designated Person is no in possession of UPSI while executing the deminimis Trade.
  7. Additional trading restrictions on Designated Persons
    1. No Director or Key Managerial Personnel shall enter into derivative transactions in respect of the securities of the Company.
    2. All Designated Persons who Trade in the securities of the company shall not enter into an opposite transaction during the next six months following the prior transaction. In case of any contra trade be executed, inadvertently or otherwise, in violation of such a restriction, the profits from such trade shall be liable to be disgorged for remittance to the SEBI for credit to the Investor Protection and Education Fund administered by SEBI.
  8. Trading Plan
    1. A Designated Person shall be entitled to formulate a Trading Plan that complies with the SEBI Regulations (a “Trading Plan”) and present it to the Compliance Officer for approval and public disclosure pursuant to which Trades may be carried out in his behalf in accordance with such plan.
    2. The Compliance Officer shall review and approve the Trading Plan if it complies with the SEBI Regulations and shall disclose the Trading Plan to the stock exchanges.
    3. The Trading Plan once approved shall be irrevocable and the Designated Person shall mandatorilyhave to implement the plan, without being entitled to either deviate from it or to execute anytrade in the securities outside the scope of the Trading Plan. However, the implementation of theTrading Plan shall not be commenced, if at the time of formulation of the plan, the DesignatedPerson is in possession of UPSI and the said information has not become generally available at thetime of the commencement of implementation. The commencement of the Trading Plan shall bedeferred until such UPSI becomes generally available information. Further, the Designated Personshall also not be allowed to Trade in securities of the Company, if the date of Trading in securitiesof the Company, as per the approved Trading Plan, coincides with the date of closure of TradingWindow announced by the Compliance Officer.
  9. Penalty for Insider Trading
    1. An Insider who acts in contravention of these Rules shall be liable to have his services or relationship with the Company, as the case may be, terminated.
    2. Directors, Officers and employees of the Company who violate these rules shall be subject to disciplinary action by the Company, which may include wage freeze, suspension, in eligibility for future participation in the Company’s stock option plans or termination.
    3. The SEBI or any other appropriate regulatory authority would also be informed of the violation of these Rules so that appropriate action may be taken.
  10. Disclosure requirements
    • 10.1 Initial Disclosure:
      • a. Every Promoter, Member of the Promoter group, Key Managerial Personnel, Director of the Company and each of their Immediate Relatives shall disclose his holding of securities of the Company within thirty days of these Rules taking effect as per Form A set out in Annexure 5.
      • b. Every person on appointment as a Key Managerial Personnel or a Director of the Company or upon becoming a Promoter or Member of the Promoter group shall disclose his / her and Immediate Relatives’ holding of securities of the Company as on the date of appointment or becoming a promoter or Member of the Promoter group, to the Company within seven days of such appointment or becoming a promoter Member of the Promoter group, as per Form B set out in Annexure 6.
    • 10.2 Continual Disclosure
      • a. Every Promoter, Member of the Promoter group, Employee, Director of the Company and each of their Immediate Relatives shall disclose as per Form C set out in Annexure 7 to the Company the number of such securities acquired or disposed of within two trading days of such transaction if the value of the securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of Rs. Ten lakhs.
      • b. The disclosure shall be made within two working days of:
        • I. the receipt of intimation of allotment of shares, or
        • II. the acquisition or sale of shares or voting rights, as the case may be.
    • 10.3 Disclosure to the Stock Exchange: The Compliance Officer shall notify the stock exchanges, particulars of the Trades, within two trading days of the receipt of the Continual Disclosure or from becoming aware of such information.
    • 10.4 Disclosures by other Connected Persons: The Compliance Officer may, require any other Connected Person to disclose the holdings and trading in securities of the Company as per Form D set out in Annexure 8 at such frequency as he may determine.
    • 10.5 Half yearly disclosures: All Designated Person dealing in securities of the company shall be required to forward the following details of their securities transactions including the holdings of the dependent family members to the Compliance Officer in Form E set out in Annexure 9.
      • 10.5.1 All holdings in securities of the Company by the designated persons and their dependent family members at the time of joining the Company.
      • 10.5.2 Statement of any transactions in securities of the Company, whether pre-clearance of trade was obtained or not, in Form E on Half yearly basis within 30 days from the end of half year of each Financial Year.
      • 10.5.3 Half yearly Statement of all holdings in securities of the Company in Form E as on September 30 & March 31 of every year are to be made on or before October 30 & April 30 of that year.
  11. Miscellaneous
    1. The Board of Directors shall be empowered to amend, modify, interpret these Rules and such Rules shall be effective from such date that the Board may notify in this behalf.
    2. The Compliance Officer shall provide the Audit Committee of the Board, on a quarterly basis, all the details of Trading in securities by the Designated Persons including any violations of the Rules.
    3. The Compliance Officer shall maintain (a) updated list of Designated Persons, (b) records of disclosures and pre-clearance applications and undertakings for a period of five years and (c) a confidential list of any ‘restricted securities’ to which the Compliance Officer may require Designated Persons to seek pre-clearance before Trading in such ‘restricted securities’.
    4. The Company shall require all Connected Persons to formulate and adhere to a code of conduct to achieve compliance with these Rules. In case such persons observe that there has been a violation of these Rules, then they shall inform the Board of Directors of the Company promptly.
    5. The Company has adopted the ‘Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information’ available at www.trigyn.com to regulate the Company’s practices and procedures for fair disclosure of UPSI.
 

Forms for reporting requirements

Forms Particulars Compliance & Time Line
Annexure 1 APPLICATION FOR PRE-TRADING APPROVAL Designated Person intending to deal in securities in excess of Rs. 5 Lakhs (Market value) shall apply for pre-clearance with the Compliance Officer.
Annexure 2 UNDERTAKING TO BE ACCOMPANIED WITH THE APPLICATION FOR PRE-CLEARANCE Designated person should submit the undertaking along with Application for Pre-Trading Approval.
Annexure 3 PRE-CLEARANCE ORDER The Compliance Officer after being satisfied with the application for preclearance from the Designated Person may grant pre-clearance order.
Annexure 4 DISCLOSURE OF TRANSACTIONS Designated Person shall disclose within 2 days of transaction/ dealing in securities the trading details to the Compliance Officer.
Annexure 5 Form A –
Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 [Regulation 7 (1) (a) read with Regulation 6 (2) – Initial disclosure to the company]		 Initial Disclosure
Annexure 6 Form B –
Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 [Regulation 7 (1) (b) read with Regulation 6(2) - Disclosure on becoming a Director/KMP/Promoter]		 Disclose within 7 days of Appointment as a Director/ Key Managerial Personnel or becoming a promoter.
Annexure 7 Form C –
Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 [Regulation 7 (2) read with Regulation 6(2) – Continual disclosure]		 Disclose within 2 trading days – Every promoter(s)/ designated person/ director is required to inform of trading/ dealing in securities if value of securities (whether in one transaction or more transactions during a calendar quarter) is more than Rs. 10,00,000/- (Rupees Ten lakh)
Annexure 8 Form D -
Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Regulation 7(3)–Transactions by other connected persons as identified by the company		 Disclose within 2 trading days – Connected person is required to inform of trading/ dealing in securities if value of securities (whether in one transaction or more transactions during a calendar quarter) is more than Rs. 10,00,000/- (Rupees Ten lakh)
Annexure 9 Form E –
Half Yearly Statement		 Designated Person to report securities held as on 30th September & 31st March on a half yearly basis by 30th October & 30th April.
 

Annexure 1

APPLICATION FOR PRE-TRADING APPROVAL

To,
The Compliance Officer,
Trigyn Technologies Limited.

Pursuant to the SEBI (Prohibition of Insider Trading) Regulations, 2015 and the Company’s Insider Trading Policy, I seek approval to purchase / sell / subscribe_________ equity shares of the Company as per details given below:

1. Name of the Applicant  
2. Designation  
3. Number of securities held as on date  
4. Folio No. / DP ID / Client ID No.  
5. The proposal is for (a) Purchase of securities
(b) Subscription to securities (c) Sale of securities
6. Proposed date of trading in securities  
7. Estimated number of securities proposed to be purchased/subscribed/sold  
8. Current market price (as on date of application)  
9. Whether the proposed transaction will be through stock exchange or off-market trade  
10. Folio No. / DP ID / Client ID No. where the securities will be credited / debited  

I enclose herewith the Undertaking signed by me.

Signature: _______________
Name:
Date:

 

Annexure 2

UNDERTAKING TO BE ACCOMPANIED WITH THE APPLICATION FOR PRE-CLEARANCE

To,
The Compliance Officer,
Trigyn Technologies Limited

I, ________________________________, _________________________ of the Company residing at ______________________________________________, am desirous of trading in ____________ shares of the Company as mentioned in my application dated ___________ for pre-clearance of the transaction.

I further declare that I am not in possession of any unpublished price sensitive information up to the time of signing this Undertaking.

In the event that I have access to or receive any unpublished price sensitive information after the signing of this undertaking but before executing the transaction for which approval is sought, I shall inform the Compliance Officer of the same and shall completely refrain from trading in the securities of the Company until such information becomes public.

I declare that I have not contravened the provisions of the Rules as notified by the Company from time to time.

In the event of this transaction being in violation of the Rules or the applicable laws,(a) I will, unconditionally, release, hold harmless and indemnify to the fullest extent, the Company and its directors and officers, (the ‘indemnified persons’) for all losses, damages, fines, expenses, suffered by the indemnified persons, (b) I will compensate the indemnified persons for all expenses incurred in any investigation, defense, crisis management or public relations activity in relation to this transaction and (c)I authorize the Company to recover from me, the profits arising from this transaction and remit the same to the SEBI for credit of the Investor Protection and Education Fund administered by the SEBI.

I undertake to submit the necessary report within two days of execution of the transaction / a ‘Nil’ report if the transaction is not undertaken.

If approval is granted, I shall execute the Trade within seven days of the receipt of approval failing which I shall seek pre-clearance afresh.

I declare that I have made full and true disclosure in the matter.

Signature: _______________
Name:
Date:

 

Annexure 3

PRE-CLEARANCE ORDER

To
Name _______________
Designation ________________
Place _______________________

This is to inform you that your request for dealing in _____________(nos) shares of the Company mentioned in your application dated ____________is approved. Please note that the said transaction must be completed on or before ___________ (date) that is seven days from today.

In case you do not execute the approved transaction/ deal on or before the aforesaid date you will have to seek fresh pre-clearance before executing any transaction/deal in the securities of the Company. Further, you are required to fill the details of the executed transactions in the attached format within 2 trading days from the date of aforesaid transaction/deal. In case the transaction is not undertaken a “NIL” Report, along with reasons for non-execution of transaction shall be necessary.

Yours Faithfully,

For Trigyn Technologies Limited

Compliance Officer

Date: __________
Encl.: Format for submission of details of transaction.

 

Annexure 4

DISCLOSURE OF TRANSACTIONS
(To be submitted within 2 days of transaction /trading in securities of the Company)

To,
The Compliance Officer,
Trigyn Technologies Limited

I hereby inform that I

  • have not bought / sold/ subscribed any securiƟes of the Company
  • have bought/sold/subscribed to ________ securiƟes as menƟoned below on ____ (date)

(strike out whichever is not applicable)

Name of holder No. of securities traded Bought / sold / subscribed DP ID/Client ID/Folio No. Price (Rs.)
         
         
         

I declare that the above information is correct and that no provisions of the Company’s Rules and/or applicable laws/regulations have been contravened for effecting the above said transactions(s).

Signature: _______________
Name:
Date:

 

Annexure 5

Form A

Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 [Regulation 7 (1) (a) read with Regulation 6 (2) – Initial disclosure to the company]

To,
The Compliance Officer,
Trigyn Technologies Limited (ISIN: ___________)

Details of Securities held by Promoter, Key Managerial Personnel, Director and other such persons as mentioned in Regulation 6(2) of SEBI Regulations.

Name, PAN No., CIN/DIN & address with contact nos. Category of Person (Promoters/ KMP /Directors/ immediate relatives/ others etc.) Securities held as on the date of regulation coming into force % of Shareholding
    Type of security (For eg.–Shares, Warrants, Convertible Debentures etc.) No.  
         
         

Note: “Securities” shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015.

Details of Open Interest (OI) in derivatives of the company held by Promoter, Key Managerial Personnel (KMP), Director and other such persons as mentioned in Regulation 6(2)

Open Interest of the Future contracts held as on the date of regulation coming into force-- Open Interest of the Option Contracts held as on the date of regulation coming into force--
Contract Specifications) Number of units (contracts * lot size) Notional value in Rupee terms Contract Specifications) Number of units (contracts * lot size) Notional value in Rupee terms
           
           

Note: In case of Options, notional value shall be calculated based on premium plus strike price of options

Name & Signature:
Designation:

Date:
Place:

 

Annexure 6

Form B

Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 [Regulation 7 (1) (b) read with Regulation 6(2) - Disclosure on becoming a Director/KMP/Promoter]]

To,
The Compliance Officer,
Trigyn Technologies Limited (ISIN: ___________)

Details of Securities held on appointment of Key Managerial Personnel or Director or upon becoming a Promoter of a listed company and other such persons as mentioned in Regulation 6(2) of SEBI Regulations.

Name, PAN No., CIN/DIN address with contact nos. Category of Person (Promoters/ KMP /Directors/ Immediate relatives/ others etc. Date of appointment of Director /KMP OR Date of becoming Promoter Securities held at the time of Becoming Promoter/appointment of Director/KMP % of Shareholding
Type of security (For eg.–Shares, Warrants, Convertible Debentures etc.) No.
           
           

Note: In case of Options, notional value shall be calculated based on premium plus strike price of options

Name & Signature:
Designation:
Date:
Place:

 

Annexure 7

FORM C

Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 [Regulation 7 (2) read with Regulation 6(2) – Continual disclosure]

To,
The Compliance Officer,
Trigyn Technologies Limited (ISIN: ___________)

Details of change in holding of Securities of Promoter, Designated Person or Director of a listed company and other such persons as mentioned in Regulation 6(2) of the SEBI Regulations.

Name, PAN, CIN/ DIN, & address with contact nos. Category of Person (Promot ers/ KMP / Director s/immedi ate relative to/others etc.) Securities held prior to acquisition/disposal Securities acquired/Disposed Securities held post acquisition/disposal Date of allotment advice/ acquisition of shares/sale of shares specify Date of intimatio n to company Mode of acquisition / disposal (on market/public/rights/preferential offer / off market/ Inter-se transfer, ESOPs etc.)
    Type of security (For eg. – Shares, Warrants, Converti Ble Debentures etc.) No. and % of shareh olding Type of security (For eg. –Shares, Warrants Converti ble Debentu resetc.) No. Value Transacti on Type (Buy/Sal e/Pledge /Revoke/ Invoke) Type of security (For eg. – Shares, Warrants ,Converti ble Debentur es etc.) No. and % of shareholdi ng From To    
                           

Note: “Securities” shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015.

Details of trading in derivatives of the company by Promoter, Employee or Director of a listed company and other such persons as mentioned in Regulation 6(2).

Trading in derivatives (Specify type of contract, Futures or Options etc) Exchange on which the trade was executed
Type of contract Contract specifications Buy Sell  
    Notional Value Number of units (contracts * lot size) Notional Value Number of units (contracts * lot size)  
             

Note: In case of Options, notional value shall be calculated based on Premium plus strike price of options.

Name & Signature:
Designation:
Date:
Place:

 

Annexure 8

FORM D

Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 Regulation 7(3)–Transactions by other connected persons as identified by the company

Details of trading in securities by other connected persons as identified by the company

Name, PAN, CIN/ DIN, & address with contact nos. Connectio n with company Securities held prior to acquisition/disposal Securities acquired/Disposed Securities held post acquisition/disposal Date of allotment advice/ acquisition of shares/sale of shares specify Date of intimatio n to company Mode of acquisition /dispos al (on market/pu blic/ rights/ Preferential offer / off market/Int erse transfer, ESOPs etc.)
    Type of security (For eg. – Shares, Warrants, Converti Ble Debentures etc.) No. and % of shareh olding Type of security (For eg. –Shares, Warrants Converti ble Debentu resetc.) No. Value Transacti on Type (Buy/Sal e/Pledge /Revoke/ Invoke) Type of security (For eg. – Shares, Warrants, Converti Ble Debentures etc.) No. and % of shareh olding From To    
                           

Note: “Securities” shall have the meaning as defined under regulation 2(1)(i) of SEBI (Prohibition of Insider Trading) Regulations, 2015.

Details of trading in derivatives by other connected persons as identified by the company

Trading in derivatives (Specify type of contract, Futures or Options etc) Exchange on which the trade was executed
Type of contract Contract specifications Buy Sell  
    Notional Value Number of units (contracts * lot size) Notional Value Number of units (contracts * lot size)  
             

Note: In case of Options, notional value shall be calculated based on premium plus strike price of options.

Name & Signature:
Designation:
Date:
Place

 

Annexure 9

FORM E
(HALF YEARLY STATEMENT)

To
The Compliance Officer,
Trigyn Technologies Limited,

I, ____________, in my capacity as ______________ of the Company hereby submit the following details of change in holding of securities of the Company as on _________

I. Details of securities held by me;

No of shares held on ____ (01st April/ 01st October) No of shares bought during the half year ended _______ No of shares sold during the half year ended ________ No of shares held on ______ (30th September/ 31st March) Folio No./ DP ID/Client ID
         

II. Details of shares held by each relatives/ Dependent Family Members (as applicable)

Name of Relatives/ Dependent Family Members Relationship No of shares held on _______ (01st April/ 01st October) No of shares bought during the half year ended _______ No of shares sold during the half year ended ________ No of shares held on ______ (30th September/ 31st March) Folio No./ DP ID/Client ID
             

I/We hereby declare that I/We have complied with the Code and SEBI Regulations with respect of the Securities purchased/ sold.

I/We further declare that the above disclosure is true and correct and is in accordance with the previous disclosure given to the Company.

Name: ________________
Signature: _____________