Complaint to SECP under Securities Act 2015

TO THE SECRETARY, SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN, NIC BUILDING, 63 JINNAH AVENUE, ISLAMABAD

COMPLAINT REGARDING VIOLATION OF SECURITIES ACT 2015 AND MARKET REGULATIONS

Complainant: complainant_name, CNIC No. complainant_cnic, investor_type Address: complainant_address Contact: complainant_phone Email: complainant_email Respondent: respondent_company_name (Respondent Company) Registration No.: registration_number Address: respondent_address

The undersigned, complainant_name, hereby lodges a formal complaint with the Securities and Exchange Commission of Pakistan regarding violation of the Securities Act 2015 and market regulations by respondent_company_name and its officers.

The respondent is a publicly listed company registered with SECP under Registration No. registration_number. The complaint pertains to violation_type in connection with the respondent's securities, trading practices, and disclosures.

The respondent company has engaged in systematic market abuse and made material misrepresentations to the investing public in violation of Section 156 of the Securities Act 2015: MISREPRESENTATIONS MADE: 1. misrepresentation_1 2. misrepresentation_2 3. misrepresentation_3 These statements were published in official disclosures, prospectuses, and periodic reports filed with SECP. The misrepresentations were made knowingly or with reckless disregard for their accuracy. VIOLATIONS OF SECURITIES LAW: 1. violation_1 2. violation_2 3. violation_3 The respondent engaged in violation_type affecting security_type securities traded on the stock exchange. The transaction occurred on transaction_date, and the false statement was issued on statement_date. DOCUMENTARY AND MATERIAL EVIDENCE: Documentary Evidence: doc_evidence_1, doc_evidence_2, doc_evidence_3 Material Evidence: material_evidence_1, material_evidence_2 IMPACT ON COMPLAINANT: The complainant is an investor_type investor who relied on the misrepresentations and suffered direct financial loss. The securities were artificially inflated by inflation_percentage%, resulting in a loss of loss_amount.

Alleged Violations: The respondent has violated Section 156 of the Securities Act 2015 by: (i) violation_1; (ii) violation_2; (iii) violation_3. The respondent's conduct constitutes market abuse, false/misleading disclosure, and price manipulation.

Evidence: Documentary evidence supporting this complaint includes: doc_evidence_1, doc_evidence_2, doc_evidence_3. Material evidence includes: material_evidence_1, material_evidence_2.

The respondent company published false financial statements on statement_date which did not reflect the true financial position. The stock price was artificially inflated by inflation_percentage based on these false disclosures. The complainant suffered financial loss of loss_amount as a direct result.

The complainant has already reported this matter to prior_authority on prior_report_date without resolution. The SECP investigation is the appropriate forum for addressing this securities violation.

IN THE RESULT, the complainant humbly requests that the Securities and Exchange Commission of Pakistan be pleased to: 1. Accept this complaint and register an investigation under Section 156 of the Securities Act 2015; 2. Investigate the respondent company's violations of securities laws and market regulations; 3. Examine trading records, financial statements, and disclosures for fraudulent content; 4. Suspend trading in the respondent's securities if required in public interest; 5. Impose penalties and direct compensation to affected investors; 6. Initiate criminal proceedings where warranted. And for such other relief as may be deemed appropriate.

PRAYER

It is, therefore, most respectfully prayed that may be pleased to:

(a) Take cognisance of the present complaint under Section 156 of the Securities Act 2015 and the Companies Act 2017;

(b) Initiate a formal investigation into the conduct of accused_regulated_person including market manipulation, insider trading, or false / misleading information as described above;

(c) Suspend or cancel the licence / authorisation / registration of the accused regulated person, pending determination of the investigation, where warranted;

(d) Impose monetary penalties under Sections 150, 151, 156 and 162 of the Securities Act 2015 commensurate with the gravity of the conduct;

(e) Direct disgorgement of profits made or losses avoided through the prohibited conduct;

(f) Refer the matter to law enforcement authorities for criminal prosecution where warranted under Section 158 of the Securities Act 2015; and

(g) Pass any other or further order that the Commission may consider just and proper in the circumstances.

complainant_counsel_name Advocate/Representative for Complainant Enrolled on Roll No. advocate_roll_no Date: filing_date