Growth Engine Ltd., a listed company which was incorporated in 2015. The company is booming and favouring the younger generation to work. The Capital Structure of the company as on March 31, 2024 is as follows :
| Particulars | ₹ (Crore) |
| Authorised Share Capital 200,00,000 Equity Shares of ₹ 10 each | 20.00 |
| Issued, Subscribed and Paid-up Share Capital 100,00,000 Equity Shares of ₹ 10 each | 10.00 |
| Share Premium | 2.00 |
| General Reserve | 7.04 |
| Profit & Loss Account | 3.16 |
In the Board Meeting, an agenda for formulation of policy for Sweat Equity Shares has been discussed. As an Independent director of the company, Ratan objected on a clause, which made him ineligible for availing Sweat Equity Shares. He also suggested that either the company should go for Employee Stock Option Scheme or sweat equity shares can be issued in the form of preferential Issue.
The company decided to issue 30% sweat equity shares to eligible employees to keep them motivated and partners in growth. Lock-in period for sweat equity will be five years. For this purpose, a resolution in General meeting of company was passed in this manner.
“The Resolution specifies 30 lakh sweat equity shares, Current Market price ₹ 50 per share with a consideration of ₹ 10 per share to be issued to eligible employee”.
The company seeks your advice with reference to the provision of issue of sweat equity shares under the Companies Act, 2013 and SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 on the following points :
1.Is the issuance of sweat equity shares at a discount appropriate ?
2.Is the size of the sweat equity share issue appropriate, and is the lock-in period justifiable ?
3.Is Ratan eligible to receive sweat equity shares ?
4.Is Ratan eligible for the Employee Stock Option Scheme ?
5.Can sweat equity shares be issued through a preferential issue, as suggested by Ratan ?
1)Regulation 30 of the SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 provides that a company whose equity shares are listed on a recognised stock exchange may issue sweat equity shares in accordance with section 54 of the Companies Act, 2013 and SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 to its employees for their providing know-how or making available rights in the nature of intellectual property rights or value additions, by whatever name called. Also, SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021, defines the term sweat equity shares which means sweat equity shares as defined in sub-section (88) of section 2 of the Companies Act, 2013. In accordance with section 2(88) of the Companies Act, 2013, sweat equity shares means such equity shares as are issued by a company to its directors or employees at a discount or for consideration, other than cash, for providing their know-how or making available rights in the nature of intellectual property rights or value additions, by whatever name called.
Further section 54(1)(d) of the Companies Act, 2013 provides that where the equity shares of the company are listed on a recognised stock exchange, the sweat equity shares are issued in accordance with the regulations made by the Securities and Exchange Board in this behalf and if they are not so listed, the sweat equity shares are issued in accordance with such rules as may be prescribed. In this regard, Rule 8 of the Companies (Share Capital and Debentures) Rules, 2014, stipulates that a company other than a listed company, which is not required to comply with SEBI Regulations on sweat equity, shall not issue sweat equity shares to its directors or employees at a discount or for consideration other than cash, for their providing know-how or making available rights in the nature of intellectual property rights or value additions, by whatever name called, unless the issue is authorised by a special resolution passed by the company in general meeting.
Since Growth Engine Ltd. is a listed company and is required to comply with SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021, issuing sweat equity shares at a discount is appropriate.
2)In terms of Regulation 31 of the SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021, a company shall not issue sweat equity shares for more than 15% of the existing paid-up equity share capital in a year. However, the issuance of sweat equity shares in the company shall not exceed 25% percent of the paid up equity share capital of the company at any time.
Further, Rule 8 (4) of the Companies (Share Capital and Debenture) Rules, 2014 states that a company shall not issue sweat equity shares for more than 15% of the existing paid up equity share capital in a year or shares of the issue value of Rs.5 crores, whichever is higher. However, the issuance of sweat equity shares in the company shall not exceed 25% of the paid up equity share capital of the company at any time.
In the given situation, size of issue of sweat equity shares i.e., 30% to be issued by a public company to a class of directors and employees was not within the prescribed limit. Hence, the size of issue of sweat equity shares of the company was not appropriate.
Lock-in Period: Regulation 38(1) of the SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021 provides that the sweat equity shares shall be locked in for such period of time as specified in relation to a preferential issue under the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018, as amended from time to time.
Further, SEBI (ICDR) Regulations, 2018 states that the specified securities, allotted on a preferential basis to the promoters or promoter group and the equity shares allotted pursuant to exercise of options attached to warrants issued on a preferential basis to the promoters or the promoter group, shall be locked-in for a period of 18 months from the date of trading approval granted for the specified securities or equity shares allotted pursuant to exercise of the option attached to warrant, as the case may be. The specified securities allotted on a preferential basis to persons other than the promoters and promoter group and the equity shares allotted pursuant to exercise of options attached to warrants issued on preferential basis to such persons shall be locked-in for a period of six months from the date of trading approval.
Accordingly, in the given situation, the lock-in period of sweat equity is 5 years which is not in the compliance of the above conditions.
3)In accordance with the explanation to the Rule 8(1) of the Companies (Share Capital and Debentures) Rules, 2014, the expressions ‘Employee’ means -
a)a permanent employee of the company who has been working in India or outside India, or
b)a director of the company, whether a whole-time director or not; or
c)an employee or a director as defined in sub-clauses (a) or (b) above of a subsidiary, in India or outside India, or of a holding company of the company;
According to the provisions pertaining to Sweat Equity Shares under the SEBI (Share Based Employee Benefits and Sweat Equity) Regulations, 2021, term ‘employee’ means,
(i)An employee of the company working in India or abroad; or
(ii)A director of the company whether a whole time director or not.
In the given question, Ratan is an independent director on the Board, he is eligible under the scheme for Sweat Equity shares.
4)As per SEBI (Share Based Employee Benefits and Sweat Equity) Regulations 2021, “Employee”, except in relation to issue of sweat equity shares, means-
(i)an employee as designated by the company, who is exclusively working in India or outside India; or
(ii)a director of the company, whether a whole time director or not, including a nonexecutive director who is not a promoter or member of the promoter group, but excluding an independent director.
Since, Ratan is an independent director, will not be eligible under scheme for Employee Stock Option Scheme.
5)An issue of Sweat Equity Shares is not a ‘preferential issue. As per Regulation 2(1)(nn) of SEBI (ICDR) Regulations, 2018 provides the meaning of a preferential issue excludes an issue of sweat equity shares there from, which means issue of sweat equity shares is not a preferential issue. Further, Rule 13 of the Companies (Share Capital and Debentures) Rules, 2014, clearly excludes issue of sweat equity shares from the definition of preferential offer.
Accordingly, the sweat equity shares cannot be issued through a preferential issue as suggested by Ratan.
Source: ICSI Guideline Answers, December 2024, Q. 3 (Syllabus 2022).