ARG COMPLIANCE MANUAL - Rathi Online

B. Code Of Conduct For Prevention Of Insider Trading For ARG Employees (As Per SEBI Guidelines)Departments and persons for whom further restrictions for buying and selling of securities is applicable:DirectorsAll Head of the Departments (VP & Above)ComplianceDealing DepartmentResearch DepartmentRisk DepartmentFor Applicable PersonsNot to communicate any Price Sensitive Information to any non-applicable person. In exceptionalcircumstances confidential information can be given to non-applicable person on the basis of "needto know" criteria, under intimation to the compliance officer.Not to use Price Sensitive Information to buy or sell securities of any sort, whether for their ownaccount, their relative‟s account, Company's account or a client's account. (Relative to include self,spouse, dependant children and their spouses, dependant parents, dependant grand parents,dependant brothers, sisters and their spouses)Not pass on such information directly or indirectly by way of making a recommendation for thepurchase or sale of securities.For Research TeamFor Dealers:To intimate compliance officer of all existing companies on which the research activity is carriedout on the date of introduction of this codeTo intimate compliance officer any addition to the above list on initiation of research.To disclose their share holdings/ interest in companies on which they are conducting research to thecompliance officer.Analysts who prepare research report of a listed company shall not trade in securities of thatcompany for 30 days from preparation of such report.To intimate the compliance officer immediately upon the execution of the order where the tradedquantity either buy or sell on account of any trade (client / proprietor) is more than 0.5% (BulkDeal) of the number of equity shares of the company listed on the stock exchange.115