Turtlemint Fintech Solutions reported two violations of its Insider Trading Code to the Bombay Stock Exchange and National Stock Exchange on August 17, 2026. The company disclosed that two designated persons traded shares during a period when the trading window was closed, breaching SEBI (Prohibition of Insider Trading) Regulations, 2015.

The violations involved City Head Vinay Pawadshetter and Quality Analyst Pooja Pawar. In both cases, the trades were executed by immediate relatives of the designated persons. The company’s Audit Committee reviewed the incidents on August 14, 2026, and directed the issuance of warning letters to both individuals.

Violation Details

Vinay Pawadshetter, who serves as City Head in the Retail function, was linked to a trade executed by his immediate relative, Tulsi Reddy. On July 21, 2026, Reddy sold 100 shares at an average price of ₹144.80, resulting in a total consideration of ₹14,480. This transaction occurred during a closed trading window.

Pooja Pawar, a Quality Analyst in the Risk, Compliance and Control function, was associated with a trade by her immediate relative, Nandkumar Nathu Tambe. On August 3, 2026, Tambe purchased eight shares at an average price of ₹120.19, for a total value of ₹961.52. This trade also took place while the trading window was closed.

Company Response

The company stated that it had circulated intimation regarding the closure of the trading window to all designated persons via email on June 26, 2026. Reminder emails were sent on June 28, June 29, and July 10, 2026.

For both cases, the company issued show cause notices. A response was received from Pawadshetter on July 31, 2026, and from Pawar on August 13, 2026. The Audit Committee concluded that the trade amounts were insignificant and that the trades were made inadvertently without intention to violate regulations. Consequently, warning letters were issued on August 17, 2026.

The filing noted that there were no previous instances of violations by these individuals since the last financial year. No monetary penalty was collected or transferred to the SEBI Investor Protection and Education Fund (IPEF).

Turtlemint Fintech Solutions Limited reported six instances of insider trading code violations by its designated persons, who executed trades during the closed trading window in June and July 2026. The company’s Audit Committee reviewed each case and directed the issuance of formal warning letters, noting that the trades were inadvertent and involved insignificant monetary values. This disclosure, filed with the Bombay Stock Exchange and National Stock Exchange on August 7, 2026, underscores ongoing compliance monitoring under the SEBI (Prohibition of Insider Trading) Regulations, 2015.

The violations occurred despite the company circulating intimation of the trading window closure via email on June 26, 2026, followed by reminder emails on June 28 and June 29, 2026. All six designated persons received show cause notices on July 14, 2026, and submitted responses between July 14 and July 24, 2026. The Audit Committee deliberated on the matter on July 17, 2026, concluding that no prior violations had been recorded since the last financial year. Warning letters were issued to all individuals on July 30, 2026.

The transactions involved a mix of purchases and sales across various employee levels, from interns to senior directors. The total consideration for all trades remained below ₹10 lakh per individual, exempting them from immediate public disclosure under Regulation 7 of the PIT Regulations. However, internal compliance protocols required reporting these breaches to the stock exchanges as part of the company’s obligation to monitor and report trading by designated persons.

The company emphasized that the trades were made without intention to violate the regulations. Prashant Saini, Company Secretary & Compliance Officer, signed the disclosure, confirming that no amounts were collected for these code violations. The report was submitted in accordance with SEBI Circular SEBI/HO/ISD/ISD/CIR/P/2020/135 dated July 23, 2020.

Compliance Context

The incidents highlight the challenges of enforcing trading window restrictions across a diverse workforce, including technology staff and sales leadership. While the monetary impact was negligible, with the largest single trade valued at ₹13,543.60 by Kunal Dhru, the procedural rigor demonstrated by Turtlemint Fintech Solutions Limited reflects adherence to regulatory expectations. The Audit Committee’s decision to issue warnings rather than impose financial penalties aligns with the principle of proportionality, given the inadvertent nature of the breaches and the lack of prior offenses.