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INTERNAL CONTROL POLICY

INTERNAL CONTROL POLICY

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Policy to safeguard against insider trading:The trading room is provided with a camera and microphone and the activities in thetrading room are recorded and kept under constant surveillance. Employees are notallowed to trade in the normal course. Employees are allowed to buy and sell sharespurely from an investment point of view and any employee wanting to buy and sell hasto take prior permission of the management. All employee accounts are under zerolimit. However, an employee being allowed to buy and sell, he/ she is allowed amaximum limit of Rs. 50, 000/- This does not however mean that an employee would beallowed to utilize this limit on a daily basis. No employee is allowed to trade on acontinuous basis for two days. Dealers are continuously watched to make sure that nodealer is leaking client information. Any employee found leaking client information issubject to immediate dismissal.

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