Flow Chart showing movement of forms between Insider & Compliance Officer

COMPLIANCE OFFICER

Initial & Periodic Disclosur e forms sent to Insider

Approve / Refuse Trade Preclearances

Intimate about Trade Window Closures

All Processes centrally managed by INTROSPECT

Submit Initial/Con tinual disclosure

Request Trade Preclearance

Submit Continual disclosure

EMPLOYEE / INSIDER

Role & Duties of the compliance officer

Submit list of initial & continual disclosures (Forms A, B, C & D)

Stock Exchange(s) MD / CMD Insider/Employee Insider/Employee Insider/Employee

Compliance Officer *

Submit list of transactions of Insiders

Intimate trade closure windows Remind pending Initial/Periodical disclosures

Introspect
Remind pending Pre-clearance/Trade conf Monitor holding/transactions of substantial shareholders Send pre-filled forms that includes Periodical Disclosure, Pre-clearance Confirmation /Rejection etc.,

Stock Exchange(s)

Insider/Employee

All the above processes are managed by Introspect.

Routine Activities and integration of Introspect with Shareholders data

NSDL /CDSL

Issuer/Registrar

Monitor addition of new accounts of insiders/subs. Shareholders, matching on PAN / Name. Monitor Insider holdings between disclosed & current figures

Compliance Officer

INTROSPECT
Track those Insider s who violate the Code of Conduct on a periodical basis.

Insiders/Subs. Shareholders Ledger based on benpos files.

Process Flow for (Insider > Trade Pre-Clearance > Approval/Rejection) 1) Blank Trade Pre-clearance Form is sent to Insider on request (optional) 2) Pre-Clearance Request is received from Insider by Mail / Paper 3) Data Entry for the request is done in Introspect (Stage: Request Pending for Approval) 4) Acknowledgement Email/letter is sent to Insiders confirming receipt of Request. (Optional). 5) Compliance Officer Reviews all Pending requests in Introspect and marks them for Approval / Rejection. 6) Separate emails / letters are sent to insiders informing the approval with approvalvalid-upto-date (or) Rejection. 7) Send Reminder letters to those Insiders where approved Pre-Clearances are pending for Confirmation-of-Trade. 8) Mark Confirmation-of-Trade for Pending Cases in the system.

Process Flow for Monitoring the Insider Transactions 1) Comparison of Insider Master (vs) Benpos to find missing member ids (as-on-date) by: a. Matching Name of Insider with Address b. Matching PAN no. 2) Comparison of Last available disclosure (vs) Benpos (as-on-date) to find: a. Discrepancy in holding as per Benpos with that of Last disclosed b. Cases triggering Pre-clearance (by entering cut-off-limit) c. Cases triggering Continual disclosure 3) Insider Ledger (for any period) to: a. Monitor Shareholding position & buy/sale between the given period. b. Find cases violating Minimum Holding Period (Opposite transaction carried out within 6 months of the first one) c. Find cases violating Transaction(s) prohibited within Trade-window-closure (Blackout period).

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