ARG COMPLIANCE MANUAL - Rathi Online

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 exceptional circumstancesconfidential information can be given to non-applicable person on the basis of "need to know" criteria, under intimation tothe compliance officer.Not to use Price Sensitive Information to buy or sell securities of any sort, whether for their own account, their relative‟saccount, 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 the purchase or sale ofsecurities.To transact in securities only after pre clearance from compliance officer in case of transaction value is Rs. 25 Lakh or moreor the number of securities is 25000 or more. This will include even to IPO‟s. Approval from Compliance shall be valid fora period of one week.Hold their investments for a minimum period of 30 days this will include even to IPOs. (From the date of allotment forIPOs)In case the sale of securities is necessitated by personal emergency before the minimum period, obtain confirmation fromthe compliance officerDeclare all holdings in securities at the time of joining the organization or for existing persons on introduction of this codeto the Compliance Department.Compliance Department would take record of all transactions and holdings of employees through DP AC on Quarterly andAnnual Basis.For Research TeamTo intimate compliance officer of all existing companies on which the research activity is carried out on the date ofintroduction 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 the compliance officer.Analysts who prepare research report of a listed company shall not trade in securities of that companyfor 30 days from preparation of such report.75