Billionbrains Garage Ventures Limited (Groww) has submitted a report to the BSE and NSE regarding a violation of its Code of Conduct for Prohibition of Insider Trading (Insider Trading Code), as required under Regulation 9 of the SEBI (Prohibition of Insider Trading) Regulations, 2015 and the SEBI Master Circular no. SEBI/HO/ISD/ISD-PoD-2/P/CIR/2024/126 dated September 23, 2024.

Nature of the Event

The disclosure reports a violation of the company's Insider Trading Code by a designated person.

Details of the Designated Person (DP)

  • Name: Sankalp Yadav
  • PAN: *****0287B
  • Designation: Finance (Manager)
  • Functional Role: Business Finance
  • Promoter/Promoter Group: No

Details of the Transaction

  • Scrip: Billionbrains Garage Ventures Limited (Scrip Code: 544603, Symbol: GROWW)
  • Trades on August 26, 2026:
  • Bought 2 (Two) equity shares for ₹191.83 per share, aggregating to ₹393.16
  • Sold 2 (Two) equity shares, aggregating to ₹392.26
  • Subsequent Trade on September 17, 2026:
  • Purchased 1 (One) equity share (price not specified in the disclosure)

Details of the Violation

The violation involved the execution of contra trades (purchase and sale on the same day) in the company's equity shares by Sankalp Yadav, a Designated Person.

Action Taken by the Company

The Audit Committee investigated the matter and noted:

1. The contra trades (purchase and sale of 2 shares each on August 26, 2026) were inadvertent.

2. Mr. Yadav had been moved to a non-critical team, and his continuance on the DP list post-August 01, 2026, was not warranted given his revised role.

3. A delay in updating the designated persons list (which is updated at least twice a quarter) resulted in his name not being removed before these trades occurred.

4. No profit was disgorged as the trades were executed at a loss.

The reason recorded in writing for the action was "Execution of contra trade."

Previous Instances and Financial Impact

  • Previous instances of violations since last financial year: None
  • Amount collected for violation: Not Applicable (NA)
  • The financial impact of the trades themselves is quantified (₹393.16 purchase, ₹392.26 sale), but no additional financial penalty was imposed or collected.

Signatory and Compliance Officer

  • Name: Roshan Dave
  • Designation: Company Secretary and Compliance Officer
  • PAN: *****1701G