Flow Chart showing movement of forms between Insider & Compliance Officer

Role & Duties of the compliance officer

All the above processes are managed by Introspect.

COMPLIANCE OFFICER

EMPLOYEE / INSIDER

Initial &

Periodic

Disclosure forms

sent to

Insider

Approve /

Refuse

Trade Pre-

clearances

Intimate

about

Trade

Window

Closures

Submit

Initial/Continual

disclosure

Request Trade

Pre-

clearance

Submit Continual

disclosure

All Processes

centrally

managed by

INTROSPECT

Compliance

Officer * MD / CMD

Insider/Employee

Stock Exchange(s)

Submit list of initial & continual disclosures

(Forms A, B, C & D)

Submit list of transactions of Insiders

Intimate trade closure windows

Remind pending Initial/Periodical disclosures Insider/Employee

Remind pending Pre-clearance/Trade conf Insider/Employee

Monitor holding/transactions of substantial

shareholders Stock Exchange(s)

Send pre-filled forms that includes Periodical

Disclosure, Pre-clearance Confirmation

/Rejection etc.,

Insider/Employee

Introspect

Routine Activities and integration of Introspect with Shareholders’ data

Compliance

Officer

Issuer/Registrar NSDL

/CDSL

INTROSPECT

Monitor addition of new

accounts of insiders/subs.

Shareholders, matching on

PAN / Name.

Monitor Insider holdings

between disclosed & current

figures

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 approval-

valid-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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