Policy on Insider Trading

The Securities & Exchange Board of India (Prohibition of Insider Trading) Regulations, 1992, was amended on 22nd February 2002 (hereinafter referred to as “Regulations”) in terms of which a Stock Broker is required to  frame a Code of Conduct for Prevention of Insider Trading by Employees of a Stock Broker, including its Directors. In line with the said Regulations, the following Code of Conduct has been adopted by Trusted Shares and Investments Ltd., - Member of the Stock Exchange, Mumbai.

Director

• The Compliance Officer shall be responsible for setting Policies and Procedures and monitoring the Rules & Regulations for the preservation of "Price Sensitive Information", pre-clearing of all Designated Employees and their Dependents Trades (directly or through respective Department heads as decided by the SNSFPL). Monitoring of Trades and the Implementation of the Code of Conduct under the overall Supervision of the Directors
• The Compliance Officer shall maintain a record of all Employees and any Changes done in the Employees List  from time to time & help to understand any Clarifications regarding SEBI (Prohibition of Insider Trading) Regulations, 1992 and.

Prevention of “Price Sensitive Information”

• Price Sensitive Information is to be handled on a "Need to Know" basis, i.e. Price Sensitive Information should be disclosed only to those within Trusted Shares and Investments Ltd.,, 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.
• All Files of, containing Confidential Information shall be kept Secure & all computer files must have Adequate Security of Login and Password, etc
• To prevent the Misuse of Confidential Information, Trusted Shares separates those Areas which routinely have access to Confidential Information, considered "Inside Areas" from those Areas which deal with Sale / Marketing / Investment Advise or other Departments providing Support Services, considered "Public Areas".
• The Employees in Inside Area may be physically segregated from Employees  in Public Area.
• The Employees in the Inside Area shall not communicate any Price Sensitive Information to anyone in Public Area.

Prevention of Misuse of Price Sensitive Information

• Employees / Directors shall not use Price Sensitive Information to Buy or Sell Securities of any sort, whether for their Own Account, their Relative’s Account, Trusted Shares and Investments Ltd’s Account or a Client's Account. The Trading Restrictions shall apply for Trading in Securities.
• An Application may be made in such form as specify by Trusted Shares in this regard, to the Compliance Officer indicating the Name and Estimated Number of Securities that the Employees / Director intends to deal in with details of Demat  DP with which he has a Security Account, the Securities in such Depository Mode and any other details as may be prescribed by Trusted Shares  in his rule & regulations.
• An Undertaking shall be executed in favor of Trusted Shares by such Employees / Directors incorporating, the following Clauses, as may be applicable
  • That the Employees / Director does not received any "Price Sensitive Information" at the time of signing the Undertaking
  • That in case the employees / director / partner receives "Price Sensitive Information" after the signing of the undertaking but before the execution of the transaction he/she shall inform the Compliance officer of the change in his position and that he/she would completely refrain from dealing in the securities of listed companies.
  • That he / she has made a Full and True Disclosure in the matter