karvy group employees code of conduct and …hr.karvy.com/hrpolicies/etpver2.pdf · karvy group...

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KARVY GROUP

EMPLOYEES CODE OF CONDUCT AND

BUSINESS ETHICS

Version 2.0

(February 1st, 2011)

(This is a proprietary and confidential document of Karvy and any circulation/reproduction of the same shall be with the written permission of Karvy)

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TABLE OF CONTENTS

Chapter

No. Contents Page No.

I Introduction 3

II Definitions 3

III Objective, Scope & Applicability of Code 6

IV Responsibility Matrix 8

V Employees’ Trading Policy 10

VI Pre-Clearance of Employees’ Trade 11

VII Additional Requirements Specific to Employees Working in

Various Departments 16

VIII Grey List/ Restricted List 20

IX Dealing with External Entities 21

X Confidentiality of Client Data/ Information 22

XI Group Policy on Countering Bribery

23

XII Client Entertainment and Gifts

23

XIII Dealing with Clients 25

XIV General Guidelines on Employees Behaviour and Work Environment

26

XV Anti Money Laundering Policy 28

XVI Non-compliance with this Code 29

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I. Introduction:

Karvy is engaged in the business of stock broking, depository participant, merchant banking, registry and share transfer services, investment banking, distribution of financial products, debenture trustee, underwriters, primary dealings in government securities, corporate and financial advisory, insurance broking and commodity broking and BPO. The activities of Karvy are regulated by the Securities & Exchange Board of India, Reserve Bank of India, Stock Exchanges, Depositories, Clearing Corporation of the Stock Exchanges, IRDA, FMC, NCDEX, MCX, etc. under the various Rules and Regulations, Bye-laws, Guidelines and Directives of those respective regulatory/ government authorities which are applicable to the businesses transacted by Karvy.

Given the diversity of the business operations and the multiplicity and complexity of the regulations that Karvy’s activities are subject to and given the impact of non-compliance, it is important that the employees of Karvy understand and comply strictly with the various regulatory requirements applicable to their respective business/ functions.

This “Employees Code of Conduct and Business Ethics” has been prepared –

To specify the responsibilities of the employees of KARVY, with regard to their business and professional conduct – internal as well as external.

To create an environment where all the employees of KARVY Group maintain ethical standards and adhereto the ethical standards that are laid down.

II. Definitions:

The following are the definitions/clarifications for the various terms used in this manual:

‘Code of Conduct’ means this manual and amendments thereto from time to time and shall include the reporting formats in respect of dealing in securities and the notices / instructions issued pursuant to this manual.

‘Karvy’ refers to Karvy Stock Broking Ltd., Karvy Consultants Ltd., Karvy Computershare Pvt Ltd., Karvy Investor Services Ltd., Karvy Comtrade Ltd., Karvy Insurance Broking Ltd. Karvy Global Services Ltd, Karvy Inc., Karvy Financial Services Ltd., and other associated companies of the group. ‘Securities’ defined in this manual will include equity shares, derivatives stocks, commodity derivatives, bonds, debentures or other marketable securities, units of mutual funds, or any other securities as may be defined by the Compliance Department and notified to the employees.

‘Designated Employees’ includes all Directors (excluding independent Directors) and employees at all levels/grades including their spouses, dependent children and their spouses and anyone

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who is financially dependent on the Director/employee. Even Research Analysts/Consultants and the non-executive Directors are covered under the term ‘Designated Employees’ ‘Control Group’ shall comprise of Senior Executives overseeing and guiding implementation of Employees Code of Conduct and Business Ethics. ‘Compliance Officer’ means compliance officer as may be nominated by the Board from time to time for the purpose of administration of the code.

‘Private Transactions’ will include any private transaction which has an underlying listed security in the form of pledge or spot transaction or off market transactions. ‘Inside Information/Confidential Information’ is the piece of Information which is unpublished and has been provided to ‘Karvy ‘ on a confidential basis’ by an external source like a client or a prospective client and which is yet to be made known to the public. For the purpose of interpretation of the words ‘inside information’ and ‘unpublished’, please also refer definitions provided in SEBI (Prohibition of Insider Trading) Regulations. ‘Material Price Sensitive Information’

“Material Price Sensitive Information” means any information which relates directly or indirectly to a company and which if published is likely to materially affect the price of securities of the company and includes

a) Periodical financial results of the company; b) Intended declaration of dividends (both interim and final); c) Issue of securities or buy-back of securities; d) Any major expansion plans or execution of new projects; e) Amalgamation, mergers or takeovers; f) Disposal of the whole or substantial part of the undertaking; g) Any significant changes in policies, plans or operations of the company; h) Client’s trading position or proposals for investment / divestment i) Stocks of companies currently being researched by Research Analysts and relevant

unpublished information received at the time of appraisal j) Stocks being researched / analyzed / evaluated for potential investment and relevant

unpublished information at the time of appraisal The information is material and price sensitive if the dissemination of the same is likely to affect the market price of that security and would influence the investors/speculators in their decision of trading in that security.

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‘Grey List’ – Whenever Karvy enters into any discussion for obtaining mandate, for any activity, from any existing listed company, the shares/instrument of the listed company will be placed in the Grey List. This means that the trading in this scrip will be monitored closely and depending on the circumstances, the concerned employees will be prohibited from dealing in this scrip. The scrip will be removed from the list if Karvy does not get the mandate of the assignment. ‘Restricted List’ – Whenever Karvy gets the mandate of an existing listed company, to undertake specific assignments, the shares of that listed company will be placed in the Restricted List. This means that all the employees are prohibited from trading in this scrip. The scrip will be removed from the list once the assignment is completed.

‘Bribery’ – Bribery is defined as any offer or receipt of any gift, money, loan, fee, reward or other advantage to or from any person (including an employee) as an inducement in the conduct of the business, particularly where such offer of receipt of any bribe is dishonest, illegal or a breach of trust.

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III. Objective, Scope & Applicability of Code:

1. Objective of Employees Code of Conduct and Business Ethics a) Serve as guidepost for business behavior of employees. b) Create awareness among the employees of their respective responsibilities &

accountabilities. c) Provide appropriate standards of official / business conduct & behaviour. d) Bring higher degree of transparency, integrity, accountability and corporate social

responsibility. e) Achieve good corporate governance by complying with all the laws, rules and regulations

applicable to the Group and fulfilling responsibilities towards stakeholders. f) Protect Company's assets and property and ensure its efficient use. g) Ensure use of company's assets for legitimate business purposes only. 2. Scope of Code

This code deals with- a) Personal securities transactions of the Designated Employees and lays down detailed

guidelines to be followed in this respect. b) Disclosure by the Employees, while tendering public investment advice. c) Policies and procedures to prevent any instance of insider trading and guard against

abuse of price sensitive information. d) Procedure for seeking approval before accepting outside directorship to avoid

conflicting situations. e) Guidelines for Prevention of Money Laundering. f) Protocol for interaction with Regulatory authorities. g) Guidelines for interaction with Media. h) Guidelines on Information Security. i) Group Policy on Countering Bribery. j) Modalities of client entertainment and gifts. k) Procedure for redressal of investor grievances. l) General Guidelines on Employees’ Behaviour and Work Environment

3. Limitation & Review of Code: Though the Code of Ethics is designed to address identified and potential conflicts, it will have its limitations in terms of not being able to identify all the potential situations. It is therefore understood that the Code should be abided in both spirit as well as in letter. In case of doubt

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please seek guidance of your Department Head / Zonal Business Head/ Designated Compliance Officer, or Group Head - Compliance. In addition to the above principles / restrictions, there are also certain reporting requirements which are expected to be adhered to at all the times. Karvy may, from time to time, amend this Code or stipulate additional Codes, depending upon the situation and change in the internal policies of the company. All employees are bound by such changes/additions in the Code as and when these changes/ additions come into force. All employees are required to read this code and confirm their understanding and acceptance of the code. The acknowledgement format for confirmation by employees is given in Annexure I. 4. Applicability of Code: The revised code shall be applicable to all employees engaged in business conducted by KARVY and be effective from August 9, 2011, The new employees shall be bound by the Code from the date of appointment irrespective of the fact that whether they are on probation or not.

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IV. Responsibility Matrix:

The first line of responsibility lies with the Department Heads/ Zonal Managers/ Zonal Business Heads/ Designated Compliance Officers, in ensuring that the activities of the employees in their respective company/ function/ department/ zone are in line with this manual and in tandem with the Karvy’s policy of maintaining high standards of corporate governance, integrity with regard to trading by employees. Any instance which is not in line with this manual should be reported to the Group Head – Compliance/ Group Head - HR immediately. 1. Control Group Control Group will be formed to oversee and guide the implementation of Employee Code of Conduct and Business Ethics. This control group will comprise of (1) Group Head - HR (2) COO – KSBL (3) Country Head – KSBL (4) Group Head - Compliance and two other Senior Executives, nominated by CMD/ Board of Directors. The quorum for meeting of Control Group shall be at least three (3) members out of six (6) to be present in the meeting. 2. Group Head - HR The Group Head - HR shall maintain a record of the Designated Employees and any changes made in the list of Designated Employees. The Group Head - HR, shall be responsible for pre-clearing of all Designated Employees and their dependents’ trades, monitoring of trades and reporting violations to the CMD. The Group Head - HR shall maintain records (on behalf of the Control Group) of all the declarations given by the employees in the appropriate form for a minimum period of three years. The Group Head - HR shall forward to Group Head - Compliance on half yearly basis, all the details of pre-approval of dealings in the securities by the employees and the accompanying documents that such persons had executed under the pre-dealing procedure as envisaged in this code.

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3. Group Head - Compliance Group Head – Compliance will be responsible for compliance of various regulatory/government provisions governing the activities of Karvy. Any queries or suggestions to this policy may be addressed to him at [email protected] The Group Head - Compliance would be responsible for implementation of this Employees Code of Conduct and Business Ethics under the overall supervision of the CMD/ Board of Directors. The Group Head - Compliance shall bring to the notice of CMD/Board of Directors, any violations of the internal and regulatory compliance norms. 4. Department Heads/ Zonal Business Heads Karvy is involved in businesses, whose activities are complimentary and/or linked to each other. Karvy’s business activities can result in real or perceived conflicts of interests. Ethical business practices and the regulatory laws require that the company should develop and implement appropriate control procedures to minimize these conflicts of interests and avoid misuse of confidential information. The conflict of interest arises mainly due to access to confidential information about a particular business/client, which has to be kept confidential. Hence, it becomes important and imperative for all the Department Heads/ Zonal Heads/ Zonal Business Heads at KSBL to maintain arms-length-relationship between the various businesses and proper Chinese walls are erected and maintained between the various businesses. 5. Limited access to confidential information

Files containing confidential information shall be kept in secured manner. Computer files must have adequate security in terms of login and password, etc. Access to these files should be on a restricted basis and will be controlled by the concerned Department Head/ Zonal/ Regional Business Head.

mailto:[email protected]

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V. Employees’ Trading Policy

The Employee Trading Policy has been designed to prevent legal, business and ethical conflicts and to guard against the misuse of proprietary or confidential information provided to Karvy by the existing and prospective clients. The objective of the policy is to not to discourage trading by employees, but to:

Encourage long-term investments by employees.

Ensure proper safeguards to various businesses of Karvy.

Ensure priority on client’s interest and transactions.

Discourage employees from engaging in personal trading on a scale or of a kind that would distract them from their daily responsibility.

Discourage trading that might have appearance of impropriety.

Discourage speculative/manipulative trading. All employees of Karvy are required to open their trading and DP account only with KSBL/ KCTL and conduct their transactions only with KSBL or KCTL unless they have written permission from Group Head – HR to open account with an entity other than KSBL/ KCTL. For this purpose, KSBL/KCTL will facilitate opening of a client account by the employee. The client code will be given by the Central Registration Department (CRD) of KSBL/ KCTL at HO. The client code will be in a specific pattern or shall have specific attribute in order to differentiate the employees’ accounts from other clients’ account. In case of employees who trade on exchanges outside India, exception to this prohibition will be allowed based on the employee’s ability to justify the need for the same. In such cases, the employee will be required to take prior written permission of Group Head – HR. Principles Karvy employees may deal in securities on their own account provided the employee will not:

Abuse the freedom to deal

Deal to the disadvantage of any client

Deal to the disadvantage of the company

Risk the reputation of the company, Group and the employee

Put personal interest above the company’s interest

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VI. Pre-Clearance of Employees’ Trade

1. Investments in IPO

Employees are permitted to invest in primary market by subscribing to Initial Public Offer (IPO)/ Repeat Public Offer (RPO) upto securities of value not exceeding Rupees Two lacs at the offer price. However, the employees associated with Investment/ Merchant Banking and RTI/RSI related business, shall be required to obtain pre-clearance of Group Head – HR before making any application for IPO/RPO. Director* is permitted to invest in primary market by subscribing to Initial Public Offer (IPO)/ Repeat Public Offer (RPO) upto securities of value not exceeding Rupees Ten lac at the offer price. An employee or Director* making an application for an IPO/ RPO above Rupees Two lacs or Rupees Ten lac respectively, or for an amount exceeding Rupees Two lacs shall be required to obtain pre-clearance of the Group Head – HR and inform the latter within 24 hours on

a. Receiving credit of securities in Demat account b. Sale of Securities thus allotted

The formats for intimation are enclosed as Annexure 3 Employees of KISL: All employees of KISL are prohibited from making application in the IPOs of the issuer company for which KISL has procured the mandate for management of their public offerings, irrespective of the amount of application or position of the employee. In case of secondary offering, where KISL is the merchant banker, the employees of KISL are prohibited from applying in such secondary IPOs and also from trading in the shares / securities of that issuer company.

The moment the merchant banking team gets involved in pre-mandate exercise of an existing listed company, the same should be intimated to the Group Head - HR/ Group Head - Compliance. The employees of KISL are permitted to subscribe to the shares / securities in the Initial Public Offerings (‘IPOs’) in retail category, only in those issues where KISL is not a merchant banker. However the employee has to intimate the Group Head - HR about the details of his application within 24 hours of making the application. *Independent Directors are excluded from this Code

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Where Karvy is the Merchant Banker or the Registrar: In case Karvy Computershare Private Limited is appointed as Registrar and/ or KISL is the Merchant Banker for the public issue, the employees should not influence the concerned department for favouring of allotments/refunds, etc. Similarly, the employees of the Merchant Banker/Registrar should not exhibit any undue favour to other employees in allotments/refunds etc.

2. Investment in Secondary Market

All trading/investments (in secondary capital and commodities market and secondary public offerings of the capital market) by the employees and Directors for an amount exceeding Rupees Two lacs and Rupees Ten lac respectively will require pre-clearance from the Group Head – HR. It is further provided that pre-clearance of trade in securities falling in grey list would be mandatory, irrespective of amount of proposed trade, for all Employees engaged in Institutional Broking, Merchant Banking, Arbitrage Trading, Legal & Compliance, Risk Equity Advisory, PMS Advisory and Finance & Accounts and also for all the Employees in the grade of General Manager and above irrespective of their function and department. Process of Pre-Clearance Group Head – HR Shall approve / dis-approve the request for trade / investment made by the employee within 48 hours from the time of receipt of the said request. Seeking pre-clearance implies that the employee has declared that he/she is not in possession of any unpublished price sensitive information and employee’s request for investment or trading is in compliance with this Policy, more specifically.

That the Designated Employee does not have any access or has not received any Price Sensitive Information upto the time of making the request.

That in case the Designated Employee has access to or receives Price Sensitive information after making the request but before the execution of the transaction he shall inform the Group Head – HR of the change in his position and that he would completely refrain from dealing in the Securities of the client company till the time such information becomes public.

That the Designated Employee has not contravened the Employees Code of Conduct and Business Ethics and provisions relating for Prevention of Insider Trading as Specified by the Company and SEBI from time to time.

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That the Designated Employee has made a full and true disclosure in the matter. The Designated Employee shall be required to execute an undertaking in favour of the company incorporating intra alia the aforesaid clauses, as may be applicable. To obtain Pre-Clearance the employee may apply, as per the format given in Annexure 2 (A) & 2 (B), to Group Head – HR through his Department Head/ Zonal/ Regional Business Head. The Department Head/ Zonal/ Regional Business Head will forward the same, with his/her recommendation, to the Group Head – HR for consideration. In case an employee is himself a Department Head/ Zonal Head, the request will be routed to Group Head – HR, through CMD/ Country Head. The intimation may be sent by the employees through email which will be construed as intimation/application through their respective Department Head/ Zonal/ Regional Business Head at mail–id [email protected] . However, the Group Head – HR may insist on physical application also, with the signature of the applicant employee. In such a case the employee is required to make a physical application. The Department Head/ Zonal/ Regional Business Head/ Country Head/CMD, while approving and recommending employee’s request for pre-clearance, may consider, among other factors, the following:

Appearance of the security on the Restricted list/Grey list

Possession of inside information by the employee

Appearance of Impropriety (trades that appear to be as creation of artificial market, manipulation, etc. and could be queried by the regulatory authorities, excessive speculation, trades that are in conflict with the interest of the clients, etc)

Unusual trading activity

Incidence of front running

Possibility of Insider Trading A Director seeking pre-clearance can apply directly to Group Head – HR on mail-id [email protected] for seeking pre-clearance. On receiving the approval from the Group Head - HR, the employee can execute the transactions, in the client code allotted to him/her from any branch of Karvy Stock Broking Ltd. The pre-clearance will be valid for five working days after the intimation of the approval from the Group Head – HR. If the trade is not executed within five working days, then fresh approval has to be taken again from the Group Head - HR



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If the security, proposed to be traded by the employee, is placed on the Restricted List/ Grey List, immediately after the approval, then the pre-clearance shall be deemed to have been withdrawn and the employee shall desist from executing the trade in full or unexecuted part thereof. Exempt category of investments For the avoidance of doubt, under these Rules, consent is NOT required for dealing in the following:-

Investments in Fixed Deposits with banks / Financial Institutions / Companies, Life insurance policies, provident funds or investments in savings schemes such as National Savings Certificates, National Savings Schemes, Kisan Vikas Patra, or any other similar investment

Investments of non-financial nature such as gold, silver, real estate etc.

Investments in government securities, money market instruments and money market mutual fund schemes. The term Money Market instrument / Money Market Mutual Funds shall have the same meaning as defined under the SEBI Regulations:

Bullion;

Precious metals;

Bonds issued by Reserve Bank of India;

Debt securities/bonds issued by central/state government, a government body, a local authority or other public or state owned entity;

Bonds approved by the government for the purposes of Section 88 of the Income Tax Act, 1961;

Unlisted mutual funds

The exercise of an option or warrant giving the right to receive an equity security;

currency linked structured deposits (e.g. embedded options yield enhancement products);

Interest rate linked structured deposits;

Certificates of deposit;

Index linked deposits;

Taking up of a scrip dividend in lieu of cash or the receipt of scrip/bonus shares. Sale of Securities and Minimum Holding period All Investments in secondary market, can be sold at the discretion of the employee post expiry of the minimum holding period.

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Normally the minimum holding period of securities in secondary market post purchase would be 30 days, but it may be changed from time to time depending on the security market conditions. However, in case the sale of securities is necessitated due to personal reasons before the expiry of the minimum holding period, the employee may apply to the Group Head – HR for waiver of the same along with justification thereof, through their respective Department Head/ Zonal/ Regional Business Head. The Group Head – HR may give approve the waiver after recording the reasons thereof in writing. Conditions Overriding Pre-Clearance

1. Any employee having a turnover (sale +purchase) exceeding Rupees Ten lac per calendar quarter should seek pre clearance even if he intends to invest less than Rs Two lac in a transaction.

2. Notwithstanding any waiver in pre-clearance, the employee will be responsible for

having a self discipline of holding the shares purchased from secondary market for a minimum period of 30 days.

3. Where an employee sells securities without approval of the competent authority before

completion of holding period, he would not only attract disciplinary action but the profits so earned may also be forfeited.

Disclosures and Reporting Requirements Relating to Transaction in Securities

a. An employee, at the time of joining, will intimate to the Group Head – HR his existing holdings in the various securities along with details of trading accounts and demat accounts opened by him and his dependents prior to joining KARVY, in the prescribed formats – Annexure 4A & Annexure 4B.

b. The employee shall also submit a declaration (Annexure 5) disclosing names of his/ her

immediate family members who have affiliation with Karvy or any other Broking House including insurance broker, as a sub-broker, franchisee, authorized person, agent or in any other capacity. The employee can intimate HR subsequently where his immediate family members enter into such relation or when such information comes to his knowledge after his joining Karvy.

c. Employees holding a position of General Manager and above, shall be required to

submit, at half yearly intervals, the following details of their securities transactions including the statement of Dependent family members and Related Entities to the Group Head – HR

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(i) All holdings in Securities by Designated Employees at the time of joining the Company.

(ii) Statement of transactions in Securities at such periodicity as may be prescribed by the Company.

(iii) Annual statement of all holdings in Securities.

d. The Group Head – HR shall maintain records of all the declarations given by the Designated Employees in the appropriate form for a minimum period of 3 years.

e. The Group Head – HR shall place before the Managing Director /Board of Directors, on

an half yearly basis all the details of the dealing in the securities by Designated employees of the organization and the accompanying documents that such persons had executed under the pre-clearance procedure envisaged under this code. The Group Head – HR will regularly monitor the transactions of various employees and report to the CMD, on the special findings, if any.

VII. Additional Requirements Specific to Employees Working in

Various Departments

An employee of Research Department shall not make any transaction which is ‘contra’ to the recommendation made by him or the research team of Karvy.

An employee of Research Department shall not make any transaction which will be deemed to be front running. For this purpose, the employee can execute the transactions only after his report/ recommendation has been disseminated to the clients of Karvy or the report/ recommendation has been disseminated to the public.

Wherever Karvy is handling pre-issue activities of any public offerings, the research team shall not take any research report on that particular company after the offer document has been filed with SEBI. Any research report taken should be prior to the date of filing of offer document with SEBI. Research Analysts, while taking out any research reports, shall ensure that all the items of price sensitive information have already been informed to the Stock Exchanges. No research report/ recommendation should be made based on market rumours/tips/inside information. All recommendations made should be justifiable by proper and well documented fundamental/technical analysis.

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Research Analyst should avoid making any general comment on the market/scrip performance, unless and until he has means and documents to justify his comments based on the technical/fundamental analysis. While arranging for conference calls between the clients and the company (on which the research department is proposing to take a research report/already taken a research report), the research team should not instigate the company and/or its officials to share confidential, unpublished, price sensitive information. In case such information is shared by the company and/ or its officials, on their own, before incorporating it in the research reports, the Research Analyst should verify whether the same has been disseminated to the public through the Stock Exchanges. Institutional Dealings Confidentiality of all transactions executed on behalf of various institutions has to be maintained. All employees of KSBL’s institutional desk are prohibited from transacting during the trading hours. In case an employee of the institutional desk desires to execute any transaction, they can place their request with the Head of Institutional Desk who will facilitate execution of the transaction after verifying that such transaction would not amount to Insider Trading/Front Running. All employees of the Institutional Desk should adhere to the guidelines, instructions and procedures for institutional desk prescribed by the Compliance Department. Stock Broking

All activities of the stock broking will be governed by the Broking Operations and Compliance Manuals circulated by HO. Also the KSBL Operations, RMS and other departments on a regular basis, stipulate and circulate various guidelines, instructions and procedures. All employees of stock broking will have to mandatorily follow these guidelines, instructions and procedures stipulated in the above mentioned manuals and in other regular communications by various departments of HO.

In addition the employees of Stock Broking shall be required to follow the “Supplementary Code of Conduct” for Branches & Dealers as given in the Annexure 6. Further all employees should qualify NCFM qualification even if they are not engaged in sales and marketing. Depository Participant

All activities of the depository participant will be governed by the DP Operations and Compliance manuals circulated by HO. Also the HO, on a regular basis, stipulates and circulates

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various guidelines, instructions and procedures. All employees of DP will have to mandatorily follow these guidelines, instructions and procedures stipulated in the above mentioned manuals and in other regular communications by various departments at HO. Commodity Broking

All activities of the commodity broking will be governed by the Operations and Compliance manual circulated by HO. All the employees of KCTL will have to mandatorily follow the compliance manual and all other guidelines and instructions communicated by the various departments of KCTL at HO.

In addition the employees of KCTL shall be required to follow the “Supplementary Code of Conduct” for Branches & Dealers as given in the Annexure 6. Further all employees should qualify relevant certification even if they are not engaged in sales and marketing.

Distribution

Each employee shall: 1. Take necessary steps to ensure that the clients’ interests are protected.

2. Adhere to SEBI Mutual Fund Regulations and guidelines related to selling, distribution and advertising practices.

3. Be fully conversant with the key provisions of the offer document as well as the operational

requirements of various schemes.

4. Provide full and latest information of schemes to investors in the form of offer documents, performance reports, fact sheets, portfolio disclosures and brochures, and recommend schemes suitable to client’s investment objectives and appropriate for the client’s financial net worth and needs.

5. Highlight risk factors of each scheme, avoid misrepresentation and exaggeration.

6. Urge investors to go through offer documents/key information memorandum before deciding to make investments.

7. Disclose all material information related to the schemes/plans while canvassing for business.

8. Abstain from indicating or assuring returns in any type of the scheme, unless the offer document is explicit in this regard.

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9. Maintain high service standards and ensure that critical operations such as forwarding of forms and cheques to AMCs/registrars and dispatch of statement of account and redemption cheques to investors are done within the time frame prescribed in the offer document and SEBI Mutual Fund Regulations.

10. Not collude with clients in faulty business practices such as bouncing cheques, wrong claim of dividend/redemption cheques, etc.

11. Avoid commission driven malpractices such as:

a. Recommending inappropriate products solely because the intermediary is getting higher commissions there from.

b. Encouraging churning of mutual fund investments to earn higher commissions, even if they mean higher transaction costs and tax for investors.

12. Avoid making negative statements about any AMC or scheme and ensure that comparisons, if any, are made with similar and comparable products.

13. Ensure that all investor related statutory communications (such as change in fundamental attributes, exit/entry load, exit options, and other material aspects) are sent to investors on time.

14. Maintain confidentiality of all investor deals and transactions.

15. While marketing various schemes, ensure that recommended scheme suits client’s investment objectives and financial needs rather than recommending a scheme in view of extra commission or incentive the scheme would earn for the employee or the company earned.

16. Not route commission back to investors and avoid attracting clients through temptation of rebate/gifts etc.

17. Qualify AMFI certification even if they are engaged in areas other than sales and marketing. Merchant Banking/Investment Banking

All employees of Merchant Banking/Investment Banking are prohibited from making application in the IPOs of the company for which Karvy has received the mandate. In case of repeat/ follow up offer, where Karvy is the Merchant Banker/Investment Banker, the employees of Merchant Banking/Investment Banking Department are prohibited from applying in such secondary/ repeat IPOs or trade in the share of that scrip in the secondary market.

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The moment the Merchant Banking/Investment Banking team gets involved in pre-mandate exercise of an existing listed company, the same should be intimated to the Group Head – Compliance for placement of all listed securities of the company under Grey List.

Registrate to Issue of Securities (RIS) / Registrar Transfer of Issue (RTI) 1. All activities of the RIS / RTI business shall be governed by the Operation and Compliance

Manuals circulated by Head office.

2. None of the employees of RIS / RTI shall act or disseminate any price sensitive information of the registry clients before they are made public in accordance with the listing agreement by the clients concerned.

3. The Head Office on a regular basis, shall lay down various procedures and guidelines and these procedures and guidelines need to be mandatorily followed by the employees of the RIS / RTI.

VIII. Grey List/ Restricted List

Any Company, in respect of which price sensitive information has been received or is likely to be received in course of any assignment taken up or under active consideration, shall be included in the Grey List. Every business head, or other senior employee specifically authorized in this regard, shall be responsible for notifying the Group Head – Compliance promptly of the companies to be included in the Grey List. Once, any Department/ Group Company/ Subsidiary company gets the mandate for any activity of any listed company (except the normal share transfer activity), the same should be intimated to the Group Head - Compliance. The Group Head - Compliance will then place it in the ‘grey list’, which would be published on HR intranet http://hr.karvy.com, and intimate it to the KSBL Risk team, Group Head – HR and concerned Department. Subsequently, if Karvy is successful in getting the mandate, the scrip will be shifted to the ‘restricted list’. In such a case all employees will be restricted from trading in such scrips. The Research Department will not cover the scrip and the Institutional Desk will not recommend the scrip to the institutional clients, till the mandate is completed. Once the mandate is over, the concerned Department will then intimate the same to the Group Head - Compliance who will then remove the scrip from the Restricted List. The Departments who are required to provide information to the Group Head – Compliance in respect of Grey/ Restricted list are Investment Banking/Merchant Banking, Research Department, Registrar and DP Divisions.

http://hr.karvy.com/

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Effect of Grey Listing

Application for pre-clearance of trades in securities of Grey List companies shall be rejected by Group Head – HR in the normal course unless he believes, on the basis of location and nature of duties, that the applicant is unlikely to have any knowledge of the relationship between the Company and the Grey List Company. Reasons for approving trades in Grey List companies shall be recorded by Group Head – HR. Reporting of Private Transactions

An employee, entering into any private transaction should intimate Group Head – HR through his Department/ Zonal Business Head/ Regional Business Head about the same within 48 hours of entering into such private transaction provided the value of such transaction exceeds Rupees Two lacs.

IX. Dealing with External Entities

Interaction with the Regulatory authorities Any interaction with any Regulatory Authorities like SEBI, RBI, FMC, and IRDA and Self Regulatory Organisations (SROs) like Stock Exchanges, Commodity Exchanges, Depositories, and AMFI will be done by the COO and the Department Heads/ Country Heads/ Zonal Heads only. No other employee shall correspond/communicate/interact with the regulatory authorities without the explicit permission of the Chairman/ COO/ Country Head/ Department Heads. All the Department Heads should consult the Group Head - Compliance before finalizing such replies to ensure that Karvy maintains a single stand before the Regulators. Contact with the Electronic and Print Media

No employee should discuss with Media about a company where KSBL or its Subsidiary is involved in an investment banking advisory transaction.

No employee should discuss KARVY ’s or the Group’s business or strategy or should conduct himself as if he is speaking on behalf of KARVY or the Group.

While speaking with media “client” confidentiality must be preserved at all times and there should not be any reference to the individual action of the clients

Only the following persons are authorised to brief the press on subjects identified below

Karvy Stock Broking Ltd, (KSBL) V.Mahesh

KARVY Group CMD

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Any other person speaking to the press will necessarily require the prior approval of the Group Head – Corporate Affairs.

Further Group Head – Corporate Affairs shall nominate/ authorize persons who can interact with media to express their views on market, economy, industry, market performance, outlook of companies’ results, subject to compliance to regulatory guidelines on interaction with electronic and print media.

X. Confidentiality of Client Data/ Information

Employees of Karvy will be receiving/accessing unpublished and sensitive information from/about Clients and Business Partners/ Vendors during the course of handling various assignments. The Clients and Business Partners/ Vendors of Karvy expect absolute confidentiality regarding the information shared with Karvy and its employees. Therefore, every employee of Karvy has the prime responsibility of safe guarding the confidentiality of all information obtained in the course of business and ensure that a situation which could be construed as conflicts of interest does not arise.

Information Security In order to prevent theft/misuse of proprietary/confidential information, Karvy has formulated an Information Security Policy. The Information Security Policy, apart from other things, covers the following:

a. Password Security and Access controls b. Information Protection c. Protection & Segregation of data d. E-mail Security e. Prevention of virus attack f. Backup Procedures g. Laptop/Desktop security

All Departments/ Zones should ensure that they follow the Information Security Policy & Procedures in letter and spirit. They may also take additional measures for strengthening data and information security.

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XI. Group Policy on Countering Bribery

The KARVY Group prohibits any Group officer or employee from offering any bribe or other inducement in any form, including kickbacks, on any portion of a contract payment, or the use of other routes or channels to provide improper benefits to customers, agents, contractors, suppliers or employees of any such party and Regulatory, Exchange or Government officials. The KARVY Group also prohibits any Group office or employee from accepting any gift except as provided under the Employees Code of Conduct and Business Ethics.

No employee shall channel improper payments through agent or supplier;

Rather the employee shall undertake due diligence in appropriate cases before appointing an agent or supplier; and shall ensure that compensation paid to agent or supplier is appropriate and justifiable remuneration for legitimate services rendered.

Any relationships with agent and supplier should be documented and the agreement should include a right of termination in the event the agent or supplier makes any improper payment.

XII. Client Entertainment and Gifts

1. Client Entertainment and Gifts

An employee may give or receive gifts or entertainment to/from clients during the course of business ONLY if it is abundantly clear from the nominal value of the gift or benefit and from the circumstances in which it is given, that no attempt has been made to compromise the interests of the employee or KSBL, as a whole or partially. 2. Accepting Gifts / Entertainment from Clients / Business Associates

• Gifts or other benefits given by someone who has no business connection with KSBL can be disregarded

• If there is a business connection, the rule applies even if the direct recipient of the gift or other benefit is a related person (i.e. an employee’s immediate family member, including his/her spouse, children, parents and any other person having a close domestic relationship with the employee. It also includes any legal entity over which an employee is able to exercise influence)

• Accepting gifts or favours from a client, potential client, supplier or potential supplier of goods or services to KSBL or any Group company is not permitted unless what is given is of nominal value or if refusal to accept would be considered discourteous or harmful to KSBL or its Group company. Approval must be obtained from the Head of Department/ Zonal Head in the unusual eventuality of accepting the gift

• Cash and near cash (e.g. gold) is not to be accepted

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• Normal gifts (provided they are not cash) at Diwali or New Year or on some other special occasion may in general be accepted, so long as the same are not of value more than of Rs.500

• Normal business courtesies (e.g. lunch and dinner invitations) may be accepted • Employee should not solicit gifts or entertainment or accept any form of entertainment

which is underwritten but not attended by the host

3. Giving Gifts / Entertaining Clients / Business Associates

• Gifts may be given to clients on the occasion of client visits and at Diwali or New Year or on some other special occasions

• If there is a business connection, the rule applies even if the direct giver of the gift or other benefit is a related person (i.e. an employee’s immediate family member, including his/her spouse, children, parents and any other person having a close domestic relationship with the employee. It also includes any legal entity over which an employee is able to exercise influence)

• Gifts should be commensurate with the value and the business relationship between the client and KARVY. The value of gifts that can be given to clients will be as laid down by management from time to time but should not be extravagant or excessive or unreasonable

• Cash and near cash (e.g. gold) should not to be given as gift to clients • Normal business entertainment e.g. lunch, dinner may be given to clients but this should

not be extravagant or excessive or unreasonable in the context of the volume of business generated or conducted with the client.

• Travelling expenses incurred by clients should not be borne by KARVY unless the same are in connection with client visits to corporates, etc. or has been arranged by KARVY.

External Directorships, Fiduciary Appointments and Outside Business Interests

Employees of KARVY are not normally permitted either to accept or continue any employment other than that of KARVY. In exceptional circumstances, applications by employees to take up or continue employment other than that of KARVY may be considered by the CMD provided Business Head/ Department Head and Group Head – HR are satisfied that such employment does not interfere or conflict with employee’s responsibilities to KSBL or any other Group company and on the understanding that KARVY may withdraw its consent at any time thereafter.

Appointment of employees of KARVY as non-executive directors of a non-Group company is discouraged. If an employee is offered such an appointment, he must take prior written approval of the CMD. Such appointments should not conflict with his responsibilities to KARVY Group.

Other Mandatory approvals

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An employee should seek written prior approval from the Chairman before the employee may :

Engage in any business other than that of Karvy.

Be employed or compensated by any person or organization other than Karvy.

Serve as an officer, Director, Partner or employee of an business organization other than Karvy.

Creates direct/indirect financial interests in organization, other than Karvy.

Intends to share information which is classified as ‘confidential’ and/or ‘proprietary’ information of Karvy.

Group Head – HR is responsible for maintaining records of external business interests of employees. Each employee should must initially provide information in respect of himself and his/ her spouse concerning:

• Directorships outside the Group, including brief details of the responsibilities of the position, the nature of activities of the entity, and the reasons, if relevant, for why the employee / spouse is to be represented on the board of the entity

• Business partnerships • 3% or more shareholding in listed companies and 10% or more shareholding in unlisted

companies • Trusteeships • Business ventures involving unlimited liability • Other personal liabilities connected with business activities • Any remunerative positions outside the Group • Secretarial or finance positions outside the Group

XIII. Dealing with Clients

Investor/Client/Customer Complaints

Any investor/client/customer complaints received should be resolved within 15 days. If the redressal of the complaint may take more time (due to the nature of the complaint which involves collection of data from many ends), then acknowledgement of complaint be sent to the investor/ client/ customer within 48 hours of its receipt assuring response to follow. The reply being sent to the investor will be approved by the concerned Department Head/ Zonal Business Head/ Regional Business Head.

1. All the letters and other written communication received from the investors / communication from Regulatory Authority/ Consumer Court must be entered in Inward Register specifically maintained for Investors’ Complaints / Grievances maintained under direct supervision of the Department Head/ Business Head/ Zonal Head.

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2. In normal course the investors’ complaint shall be responded to / resolved within a period of 15 days but not later than 30 days from the date of receipt of the investor complaint / communication from Regulatory Authority.

3. The concerned employee shall regularly update the status from time to time till the investor’s complaint / grievance gets resolved and shall record the same in Inward Register.

4. No reply will be sent without the approval of the Department Head / Business Head/ Zonal Head.

XIV. General Guidelines on Employees Behaviour and Work

Environment

1. WORK CULTURE

Implement highest degree of transparency, integrity, accountability and corporate social responsibility.

Ensure company’s assets are protected and efficiently used for legitimate official purposes.

Comply with all applicable policies, procedures, rules & regulations; manuals, circulars, internal guidelines, etc.

Comply with any lawful and reasonable direction given by someone who has authority to give the direction.

Maintain appropriate confidentiality of work, company and client related matters.

Promptly inform the Department Head/ Zonal Head of any event or action happening in the market place which affects or will affect the business interest of the company or which is against the Regulations prescribed by the regulatory authorities.

Escalate to Department Head/ Zonal Head/ Zonal/ Regional Business Head any case of embezzlement, misappropriation, cash dealing, money laundering & Terrorist or anti social activities or any other activity of like nature, of/through any employee, which has come to employee’s notice and that can be substantiated by him.

Forthwith bring to the notice of management any matter or event, which any employee of the Company is morally responsible to inform, that directly or indirectly impacts the business interests or is likely to cause any pecuniary loss to the company or has the effect of causing any damage to the reputation or image of the Group.

Ensure compliance with governmental laws, rules, notifications and regulations applicable to the Company's business. In the event the implication of any law is not clear, the Department Head/ Zonal Head/ Zonal Business Head be consulted for advice.

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2. BASIC ETHICS/ BEHAVIOURAL ETC

Treat everyone with respect and courtesy.

Deal on behalf of the company with professionalism, honesty, integrity as well as high moral and ethical standards. Such conduct shall be fair and transparent and be perceived to be as such by third parties.

Carry the identity card and employee should identify himself as an employee of KARVY.

Act with due skill, care and diligence in the conduct of all the activities.

Disclose and take reasonable steps to avoid, any conflict of interest (real or apparent).

Each employee should deal fairly with customers, suppliers, agents/ competitors, and other employees of group companies.

Do not make improper use of the employee's duties, status, power or authority, in order to gain, or seek to gain, a benefit or advantage for the employee by himself or for any other person.

Do not provide false or misleading information in response to a request for information that is made for official purposes.

Do not make improper use of Inside information,

Do not to indulge in or become party to creation of false market, price rigging, manipulation, insider trading etc. For the purpose of definition of the above terms appropriate SEBI regulation may be referred to.

3. CLIENT ORIENTED

Fulfill responsibility towards all the stake holders.

Maintain client confidentiality and do not discuss client’s financial or non-financial affairs with other clients or even with colleagues.

Highest priority be given to redressal of investor queries/grievances.

Ensure that inquiries from all the investors are adequately dealt with and ensure that all the business transactions are processed as per respective service standards and within prescribed turn-around time.

4. THINGS TO BE AVOIDED

Do not take unfair advantage of anyone through manipulation, concealment, abuse of confidential, proprietary or trade secret information, misrepresentation of material facts, or any other unfair dealing-practices.

Do not enter into any transaction or engage in any practice, directly or indirectly, that would tend to influence the employee to act in any manner other than in the best interests of the Company.

Do not to indulge in embezzlement, misappropriation of funds or pilferage.

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Do not discuss compensation, incentives or any other earnings with anyone else, unless required to do so by Competent Authority.

Avoid situation which could result in clash of personal interest with that of official interests. Under such circumstances employee should disclose to the Department Head/ Zonal Head/ Zonal Business Head and take appropriate guidance.

Do not publish, print or send any material like leaflet, descriptive literature or circulars, which shall be treated as an advertisement as per SEBI Regulations, unless the same is cleared by appropriate authority at the Head office.

Do not render, directly or indirectly, any investment advice about any security in the publicly accessible media, whether real-time or non real-time, unless duly authorized by a competent authority and without ensuring proper disclosure of own interest as well as company’s interest while rendering such advice.

Do not use rude, abusive or obscene language with customers, business partners or colleagues.

5. DRESS CODE

Men

Business casual (Formal shirt & trouser) from Monday to Friday.

Business Casuals do not include Jeans, T shirts & sneakers

Employees should wear neat and clean clothes and well polished shoes (with socks)

Marketing & front office need to wear a tie.

All Business/Division/Branch Heads whenever they visit clients on tours/business meetings need to wear a tie.

Women

Formal attire, which is, sober & suited to business environment (salwar kameez, sari or formal business suit).

Business Casuals do not include Jeans, T-shirts & sneakers.

Appropriate make-up, no excessive jewellary & other accessories.

P.S.: Every Saturday is a dress down day & casual attire is permitted for all employees.

XV. Anti Money Laundering Policy

All the employees are required to go through the Anti Money Laundering Policy of KARVY displayed on the HR intranet http://hr.karvy.com and follow the written procedures given there in letter and spirit.

http://hr.karvy.com/

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XVI. Non-compliance with this Code

This policy is applicable to all the employees of the KARVY Group and their dependants as defined in definition of “Employee” –

Each employee of KARVY is required to read this policy and comply with its provisions. Failure to comply with any of these provisions, shall constitute grounds for action, as deemed fit by the Management including suspension and termination of services and reference to the relevant Government/ Regulatory authorities.

The Company shall not preclude SEBI from taking any action against the employee 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, 1992 In case the Company observes that there has been a violation of these Regulations by an employee, the Company shall inform SEBI.

Confidentiality of Document

This Code is a confidential document of Karvy and is meant for internal use by the employees of KARVY. This document should not be distributed for any purpose outside KARVY, without the permission of the Group Head - HR.

List of Annexures

1. Acknowledgement of having read and understood Code of Conduct 2(A). Pre-Clearance for Purchase in Secondary Market 2 (B). Pre-Clearance for Sale in Secondary Market 3. Pre-Clearance for Applying for Purchase through Public Issue 4 (A). Information on Demat/ Trading Account 4 (B). Statement of Securities Holding 5. Declaration having affiliation with Karvy/ Other Broking House 6. Supplementary Code of Conduct for Branch Co-ordinators and Dealers

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ANNEXURE- I

Acknowledgement of Having Read and Understood

Code of Conduct

I Mr./Ms. _______________________ bearing employee number __________, hereby declare

that I have read and understood the “Employee Code of Conduct and Business Ethics”, which

has also been displayed on corporate website and HR intranet and I hereby undertake to

adhere to it at all times during my employment / association with KARVY.

I further undertake to be bound by any decision of the Organization in the event of my failing to

observe the above Employee Code of Conduct and Business Ethics.

Signature : _________________________

Date : _________________________

Place : _________________________

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ANNEXURE – 2 (A)

PRE CLEARANCE FOR PURCHASE IN SECONDARY MARKET Date : The Vice President – HRD

Hyderabad

Email ID: [email protected]

Through Proper Channel

Dear Sir, I wish to inform you that I propose to make the following investments whose details are given below:

S.No. Scrip proposed to purchase

Qty & Rate proposed

Name in which the

investment is being made

Likely period of holding after

purchase

Source of funds

Qty Rate Own funds

Loans Etc.

Declaration I hereby declare that –

I am not in possession of any unpublished, price sensitive, inside information on the company in which I am proposing to buy, by virtue of my position in the company, assignment I handle or otherwise.

I hereby confirm that –

The above securities are not in the restricted/grey list of KARVY.

The above purchase will be made within 5 working days of approval by the Competent Authority and


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The purchases will be made through KARVY Stock Broking Ltd.

I am not involved in any sort of unusual trading, front running, and manipulative trades etc. that are prohibited.

I assure that –

The above purchase will be made within 5 working days from the date of approval of the Competent Authority.

I will keep the Group Head – HR informed about the purchase & furnish him the required details.

The above securities do not form part of any secondary public offerings managed by KARVY as a merchant Banker whether or not KARVY has an active role in the allotment process.

I am aware and acknowledge that if I engage in any other business not permitted to trade on, the company will be entitled to take disciplinary action (including fine, suspension and / or expulsion) against me. Further, I am also aware of the fact that all my & my family members future investments needs the approval from the competent authority as indicated in the ‘Employees Code of Conduct and Business Ethics’. Hence, I would request you to grant me approval for making the above purchases. Thanking you Yours faithfully Signature Name : Emp. Code : Designation : Company/Division : Note : Family members mean husband, wife, children. Family member also include parents and other relatives who are financially dependent on the employee.

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ANNEXURE – 2 (B)

PRE CLEARANCE FOR SALE IN SECONDARY MARKET Date : The Vice President – HRD Hyderabad Email ID: [email protected]

Through Proper Channel Dear Sir, I wish to inform you that I propose to sell/ dispose the following investment whose details are given below:

S.No.

Name in which the

investment is being held

Quantity to be Sold

Tentative Proposed Rate

of Sale

Tentative Proposed Date

of Sale

Declaration I hereby declare that –


I hereby confirm that –

The above securities are not in the restricted/grey list of KARVY.

The above sale will be made within 5 working days of approval by the Competent Authority and

The purchases will be made through KARVY Stock Broking Ltd.


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I am not involved in any sort unusual trading, front running, and manipulative trades etc. that are prohibited.

I assure that –

The above sale will be made within 5 working days from the date of approval of the Competent Authority.

I will keep the Group Head - HR informed about the sale & furnish them the required details.

The above securities do not form part of any secondary public offerings managed by KARVY as a merchant Banker whether or not KARVY has an active role in the allotment process.

I am aware and acknowledge that if I engage in any other business not permitted to trade on, the company will be entitled to take disciplinary action (including fine, suspension and / or expulsion) against me. Further, I am also aware of the fact that all my & my family members future investments needs the approval from the competent authority as indicated in the ‘Employees Code of Conduct and Business Ethics’. Hence, I would request you to grant me approval for making the above sale. Thanking you Yours faithfully Signature Name : Emp. Code : Designation : Company/Division : Note : Family members mean husband, wife, children. Family member also include parents and other relatives who are financially dependent on the employee.

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ANNEXURE – 3

PRE CLEARANCE FOR APPLYING FOR PURCHASE THROUGH PUBLIC ISSUE Date : The Vice President – HRD Hyderabad Email ID: [email protected]

Through Proper Channel Dear Sir, I wish to inform you that I propose to make an application in the forthcoming public issue of shares / bonds of M/s __________________________________ as per the details given below: (OR) I wish to inform you that I (individually)/ along with my relatives propose to make an application in the forthcoming public issue of shares / bonds of M/s __________________________________.

S.No. Shares / Bonds proposed to purchase

Qty & Rate proposed

Name in which the investment is being made

Likely period of holding after purchase

Source of funds

Qty Rate Own funds

Loans Etc.

Declaration

I hereby declare that –


I am aware that KARVY Computershare is a Registrar in this public issue.


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Tick the appropriate choice I confirm that I am not part of the team involved in finalization of allotment. I declare that I am a part of the team involved in finalization of allotment and I confirm that

I will not take any action which will result in any unfair allotment to me, my family or my friends.

I am aware and acknowledge that if I invest in securities not permitted to trade on, the company will be entitled to take disciplinary action (including fine, suspension and / or expulsion) against me. Further, I am also aware of the fact that all my & my family members future investments needs the approval from the competent authority as indicated in the ‘Employees Code of Conduct and Business Ethics’. Hence, I would request you to grant me approval for making the above investment. Thanking you Yours faithfully Signature Name :

Emp. Code :

Designation :

Company/Division :

Note : Family members mean husband, wife, children. Family member also include parents and other relatives who are financially dependent on the employee.

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ANNEXURE – 4(A)

INFORMATION ON DEMAT/ TRADING ACCOUNT I hereby declare that the following DEMAT/ TRADING ACCOUTNS are held by me/ my family members:

S.No. Name(self/family members)

Relationship Trading A/c No.

Dp id ./Client id

Service Provider

Operating Since

Location/ Address

I confirm that the above information provided is true to the best of my knowledge and assure that all future investments/ sale/ purchase will be made duly obtaining the approval from the competent authorities as indicated in the “Employees Code of Conduct and Business Ethics”. Name : E.Code : Location/ Branch : Date : Signature

If the above is not applicable

I here by declare that neither me nor any of my family members possess any DEMAT/ TRADING ACCOUNTS with KARVY or with any other service providers. Name : E.Code : Location/ Branch : Date : ------------------------------- Signature Note: Family members mean husband, wife, children, parents and others who are financially dependent on the employee.

ANNEXURE – 4(B)

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STATEMENT OF SECURITIES HOLDING AS ON ________________

NAME : EMP CODE:

Designation : Department :

Division/Region : Location :

Group Name :

(Dependent Name)* :

Depository Participant Name :

Demat Beneficiary Client Id :

Sl no Security Name ISIN No Type of Security (Equity/MF/ etc.,)

Qty

Place :

Date : Signature

*P.S : Please attach separate sheets for each dependent family member.

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ANNEXURE 5

Declaration Having Affiliation with Karvy/ Other Broking House I Mr./Ms. _______________________ joined Karvy Group on _________ in _______________________ department, bearing employee number ___________, hereby declare that none of my family members have affiliation with Karvy or any other Broking House, including insurance broker, as a sub-broker, franchisee, authorized person, agent or in any other capacity. I will intimate HR immediately if any of my family members enter into such relation and/ or such information comes to my knowledge subsequently as per format given below.

OR

I hereby declare that the below named family members have affiliation with Karvy/ Other Broking House as per details given below:

S.No. Name Relationship with employee

Trade Name

SEBI Registration No. (if any)

Location

I confirm that the above information provided by me is true to the best of my knowledge and nothing has been concealed therein. Name :

E.Code :

Location/ Branch :

Date :

-----------------------------------

Signature

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ANNEXURE 6 – Supplementary Code of Conduct for Branch Coordinators and Dealers

(Applicable To Broking Functions Of KSBL & KCTL)

karvy group employees code of conduct and …hr.karvy.com/hrpolicies/etpver2.pdf · karvy group...

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