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Code of Conduct for Prohibition of Insider Trading
 
Pre-clearance of Trades

All Directors, Officers and Designated Employees of the Company intending to deal in the securities of the Company upto the Threshold Limit fixed, as defined and provided hereinbefore, may do so without any pre-clearance from the Compliance Officer.

In all other cases, they should pre-clear the transactions as per the pre-dealing procedure as provided hereunder :

Make an application in the prescribed Form E annexed hereto, to the Compliance Officer indicating the estimated number of securities that he/she intends to deal in, the details as to the depository(ies) with which he/she maintains a security account, the details as to the securities in such depository mode and such other details as may be required by any rule made by the Company in this behalf.

He / She shall execute an undertaking in favour of the Company incorporating, therein, inter alia, the following clauses, as may be applicable:

that he/she does not have any access or has not received Price Sensitive Information upto the time of signing the undertaking ;

that in case he/she has access to or 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/her position and that he/she would completely refrain from dealing in the securities of the Company till the time such information becomes public ;

Files containing confidential information shall be kept secure. Computer files must have adequate security of login and password, etc.

that he/she has not contravened any provisions of this Code, as may be notified by the Company from time to time ;
that he/she has made a full and true disclosure in the said matter.

The Directors/Officers/Designated Employees shall execute their transactions in respect of securities of the Company within one week after the approval of pre-clearance is given failing which the transaction has to be pre-cleared again. They shall hold their investments in securities for a minimum period of 30 days from the date of purchase/actual allotment. In case of personal emergency the 30 days holding period may be waived by the Compliance Officer (application to made in Form F) after recording in writing the reasons in this regard.

In case of the Compliance Officer intending to deal in the securities of the Company beyond the threshold limit the pre clearance of the Managing Director will have to be obtained. Similarly in case of personal emergency Compliance Officer may obtain the waiver from the Managing Director with regard to complying the minimum period of holding investments for 30 days.

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