Insider
Trading Policy :
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, inter alia, 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 (hereinafter referred to as “the
Code”) has been adopted by M/s. M. P. Vora
Shares & Securities Pvt. Ltd. (hereinafter
referred to as “MPVSSPL”), Member
of Bombay Stock Exchange Limited & National
Stock Exchange of India Ltd.
Director
:
-
MPVSSPL has appointed a Compliance Officer who
reports to the Managing Directors.
-
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
MPVSSPL). 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 MPVSSPL 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 MPVSSPL’s Code.
Prevention
of “Price Sensitive Information” :
-
Employees / Directors shall maintain the Confidentiality
of all Price Sensitive Information & must
not pass such Information directly or indirectly
by way of making a Recommendation for the Purchase
or Sale of Securities
-
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 MPVSSPL, 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 MPVSSPL, 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,
MPVSSPL 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, MPVSSPL’s Account or a Client's
Account. The Trading Restrictions shall apply
for Trading in Securities.
-
All Directors / Employees of MPVSSPL, who intend
to deal in the Securities of listed Companies
where MPVSSPL has some assignments shall pre-clear
the Transactions as per the pre-dealing Procedure
as described here below.
-
An Application may be made in such form as specify
by MPVSSPL 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 MPVSSPL in his rule
& regulations.
-
An Undertaking shall be executed in favor of
MPVSSPL by such Employees / Directors incorporating,
the following Clauses, as may be applicable
:
1. |
That the Employees / Director
does not received any "Price
Sensitive Information"
at the time of signing the Undertaking. |
2. |
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. |
3. |
That he / she has not contravened
the Code of Conduct for prevention
of Insider Trading as specified
by MPVSSPL. |
4. |
That he / she has made a Full
and True Disclosure in the matter. |
-
In
order to monitor above Procedures and Trading
in Client Securities based on Inside Information,
MPVSSPL shall restrict Trading in certain Securities
and designate such List as Restricted / Grey
List.
-
Security of a Listed Company shall be put on
the Restricted / Grey List if MPVSSPL is handling
any Assignment for the Listed Company or preparing
Appraisal Report.
-
Any Security, which is being purchased or sold
or is being considered for Purchase or Sale
by MPVSSPL on behalf of its Clients shall be
put on the Restricted / Grey List
-
As
the Restricted List itself is a Highly Confidential
Information it shall not be communicated to
anyone outside MPVSSPL. The Restricted List
shall be maintained & kept by Compliance
Officer.
Penalty
for Contravention of the Code :
-
Any Employee / Director who trades in Securities
or communicates any Information or counsels
any Person Trading in Securities, will be treated
as Contravention of the Code & conduct,
may be penalized and appropriate Action may
be taken by MPVSSPL
-
Employees / Directors of MPVSSPL, who violate
the Code, may also be subject to Disciplinary
Action by the Company.
-
The
Action by MPVSSPL shall not preclude SEBI from
taking any Action in case of Violation of SEBI
(Prohibition of Insider Trading) Regulations,
1992.
Information
to SEBI in case of Violation of SEBI (Prohibition
of Insider Trading) Regulations :
In
case of any violation observed by MPVSSPL / its
Compliance Officer that there has been a Violation
of these Regulations, MPVSSPL shall inform the
SEBI
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