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POLICY ON INSIDER TRADING
Tradehifi Stock Broking Pvt Ltd has appointed Compliance
Officer, who is responsible in formulating policies and
procedures and monitoring adherence to the rules for the
preservation of “Price Sensitive Information”, pre-clearing of
all employees and their dependents trades, monitoring of trades
and the implementation of the code of conduct under the overall
supervision of the Proprietor.
For the purpose of this code, the term “Insider” shall mean :
Employees in top Management and key employees
Employees as may be designated by the company from time to time
Spouse, son, daughter, father, mother and dependants, if any, of
the persons referred to in a & b above.
Access to Price Sensitive Information
Employees shall maintain confidentiality of Price Sensitive
information, if any, and do not pass on such information
directly or indirectly by way of making a recommendation for the
purchase [or] sale of securities.
Price Sensitive Information will be disclosed only to those
within the organization who need the information to discharge
their duty and whose possession of such information will not
give rise to a conflict of interest or appearance of misuse of
the information. The employees of the organization do not
communicate any Price Sensitive Information to any one in public
area.
Files containing confidential information will be strictly
secured and soft copies have access login and password, under
the direct supervision of the Compliance Office
Prior approval for trading
Officers/employees of Tradehifi who intend to deal in the
securities of any company, aggregating either 1000 in quantity
or Rs.1 lakh in value, to obtain prior approval for such trades
from the Compliance Officer, as per the pre-dealing procedure
explained hereunder
A written request will be made to the Compliance Officer
indicating the name and estimated number of securities that the
employees/directors intends to deal in, the details as to the
depository with which he has a security account, the details as
to the securities in such depository mode and any other relevant
details as may be required in this behalf.
Other restrictions
Proprietor/employees of Tradehifi shall execute their order
within one week after the approval of pre-clearance is given. If
the order is not executed within one week after approval is
given, the employee/director must pre-clear the transaction
again.
Officers/employees will hold their investments for a minimum
period of 30 days in order to be considered as being held for
investment purposes.
The holding period shall also apply to purchases in the primary
market (IPOs). In the case of IPOs, the holding period would
commence when the securities are actually allotted.
In case the sale of securities is necessitated by personal
emergency, the holding period may be waived by the Compliance
Officer after recording in writing his/her reasons in this
regard.
Reporting Requirements for transactions in securities
Officers/employees of the organisation shall be required to
forward following details of their securities transactions
including the statement of dependent family members to the
Compliance Officer:—
(a) all holdings in securities by officers/employees at the time
of joining the organisation
(b) Quarterly statement of transactions in securities
The Compliance Officer shall maintain records of all the
declarations given by the Officers/employees in the prescribed
format for a minimum period of three years.
The Compliance Officer shall place before the Proprietor, on a
quarterly basis, all details of the dealing in securities by
employees/officers of Tradehifi and the accompanying documents
that such persons had executed under the pre-approval procedure
as detailed in this code.
Penalty for contravention of code of conduct
Any employee who trades in securities or communicates any
information or counsels any person trading in securities, in
contravention of the code of conduct, will be penalised and
appropriate action will be taken by the Compliance Officer /
Proprietor of DSAS. Employees of DSAS who violate the code of
conduct will also be subject to disciplinary action by the
company, which includes wage freeze, suspension, etc.
The action if any taken by Tradehifi action, in case of
violation of Regulations, 1992.
will not preclude SEBI from taking any SEBI (Prohibition of
Insider Trading)
Information to SEBI in case of violation of SEBI (Prohibition of
Insider Trading) Regulations
In case it is observed by the compliance officer that there has
been a violation of these Regulations, SEBI will be informed by
the Compliance Officers
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