ARG COMPLIANCE MANUAL - Rathi Online

C. Employee TradingIPolicy For Trading In Shares & Commodities By Employees Of Anand Rathi GroupEmployees of Anand Rathi Group their spouses, dependent parents and dependent children wishing to dealin securities are required to abide by the following code of conduct:13. Dealing in securities must be only through Anand Rathi Group. However, exceptions shall beallowed in case of the spouse of a staff member who is working in some other broking house wheresimilar policy is in place. Such exceptions shall be granted only after prior approval is obtainedfrom Compliance Officer at Anand Rathi Group.14. All the trades should be executed through the Dealing Desk at the respective Branch. Dealers at theDealing Desk would send confirmation of all the transactions executed through email on same day.15. Buying and selling shares of the same company within the same settlement shall normally not beallowed.16. Trading in F & O, would be permitted only for the limited purpose of hedging / arbitrage. Tradingin commodities would be allowed through investment in arbitrage – structured products.17. Concerned Business Head / Head of Department should be vigilant about policy implementation byhis/her team members and should inform relevant authorities in case the policy is violated.However, the compliance officer shall have the right to call for relevant information from any staffmember. All the employees would submit a self certification of following this policy to HRdepartment; this would be coordinated by HR department.18. If any employee is found to be breaking this policy, management may take strict disciplinary action,which may include reflecting in the appraisal and even termination of services from the company.19. To transact in securities only after pre clearance from compliance officer in case of transactionvalue is Rs. 25 Lakh or more or the number of securities is 25000 or more. This will include even toIPO‟s. Approval from Compliance shall be valid for a period of one week.20. Hold their investments for a minimum period of 30 days this will include even to IPOs. (From thedate of allotment for IPOs)21. In case the sale of securities is necessitated by personal emergency before the minimum period,obtain confirmation from the compliance officer22. Declare all holdings in securities at the time of joining the organization or for existing persons onintroduction of this code to the Compliance Department.23. Compliance Department would take record of all transactions and holdings of employees in softcopy through DP AC on Quarterly and Annual Basis.24. All employees shall submit the Undertaking for the trading account held by him / her and theirdependents before initiating any trades.116