Astral : Code of Conduct under SEBI(PIT) Reg., 2015

14th January, 2022
BSE Limited	National Stock Exchange of India Limited
P.J Towers	Exchange Plaza, C-1,Block-G,
Dalal Street	Bandra - Kurla Complex, Bandra (E)
Mumbai - 400001	Mumbai - 400051
Dear Sir/Madam

Sub.: Violation under Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 by Designated Person

In term of SEBI Circular SEBI/HO/ISD/ISD/CIR/P/2020/135 dated 23rd July, 2020, please find attached herewith Report by the Company for violation related to Code of Conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015.

Kindly take the same on your records.

Thanking You,

For, Astral Limited

Krunal Bhatt

Company Secretary

Report by Astral Limited for violations related to code of conduct under SEBI (Prohibition of Insider Trading) Regulations, 2015.

[Schedule B read with Regulation 9 (1) of SEBI (Prohibition of Insider Trading) Regulations, 2015]

Sr.	Particulars		Details
No.
1.	Name of the Listed company		Astral Limited
2.	Please tick appropriate checkbox		Listed Company
			Listed Company
	Reporting in capacity of :
			Intermediary
		Details of Designated Person (DP)
3.	A.		Fiduciary
Name of DP		Mr. Yogesh Shah
	PAN of DP		AACPS2006G
	Designation of DP		Deputy General Manager
	Functional Role of DP		Working in Marketing department of the
					Company.
	Whether DP is Promoter or belongs to		No
	B. If Reporting is for immediate relative of DP
	Promoter Group
	Name of the immediate relative of DP		NA
	C. Details of transactions (s)
	PAN of the immediate relative of DP		NA
	Name of the scrip		Astral Limited - Equity Shares
	No of shares traded and value (Rs.)		Pledge - 1000 shares on 3rd January, 2022.
	D. In case value of trade(s) is more than		Rs.10 lacs in a calendar Quarter
	(Date- wise)		(Rs. 22,81,800)
	Date of intimation of trade(s) by concerned		N.A
	DP/director/promoter/promoter group to
	Company under regulation 7 of SEBI (PIT)
	Regulations, 2015.		Reported	through	system	driven
	Date of intimation of trade(s) by Company
	to stock exchanges under regulation 7 of		disclosure.
	SEBI (PIT) Regulations, 2015
4.	Details of violations observed under Code		"Margin Pledge" of 1000 equity shares of
	of Conduct		the Company in favour of Broker without
					pre-clearance and during closure of
					trading of window.
5.	Action taken by Listed company		The Company imposed penalty of
					Rs. 50,000/- to the Designated Person and
					asked him to deposit the penalty to SEBI
					IPEF.
6.	Reasons recorded in writing for taking		The Compliance Office on becoming aware
	action stated above		of the transaction through weekly benpose
					data enquired about the transaction from
					the Designated Person.

						The Designated Person informed the
						Compliance Officer that the trade was
						executed by him	inadvertently. The
						Designated Person also informed and
						declared that he was not in possession of
						any	unpublished	price	sensitive
						information about the Company or its
						securities at the time execution of the
						aforesaid trade.
						Considering the above submissions by the
						Designated Person and being the first time
						violation, the Designated Person was
						issued warning and was imposed fine of Rs.
						50,000/-. He was further informed to
						deposit the said fine amount to SEBI IPEFth
						Bank Account which he deposited on 13
						January, 2022.
7.		Details of the previous instances of				NA
		violations, if any, since last financial year
8.	If any amount collected for Code of Conduct			violation(s)
		Mode of transfer to SEBI - IEPF				Online
		(Online/Demand Draft)
	Details of transfer/payment
	In case of Online :
		Particulars				Details
		Name of the transferor				Mr.Yogesh Shah
		Bank Name, branch and Account number				HDFC Bank
		UTR/Transaction reference Number				N013221793681861
		Transaction date				13th January, 2022
		Transaction Amount (in Rs.)				Rs. 50,000
		In case of Demand Draft (DD):NA.
		Particulars				Details
		Bank Name and branch
		DD Number
		DD date
		DD amount (in Rs.)
9.		Any other relevant information				NA

For Astral Limited

Krunal Bhatt

Compliance Officer

PAN : AHVPB4783F

E-mail : [e-mail]

Date : 14th January, 2022

Place : Ahmedabad