REVISED FREQUENTLY ASKED QUESTIONS (FAQs) Relating ... · to close his/her account with other brokers and shift to KSBL /KCTL. 9. Do I need to open Demat Beneficiary Client Account

REVISED FREQUENTLY ASKED QUESTIONS (FAQs)

Relating

EMPLOYEES CODE OF CONDUCT

AND BUSINESS ETHICS

Version 2.0

Prepared By:

Department of Compliance Based on the Provisions of the Aforesaid Code of Conduct

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

August 13, 2010 Page 2 of 22

OBJECTIVE AND SCOPE OF CODE OF CONDUCT 1. What are the Objectives of Employees Code of Conduct and Business Ethics?

Ans. 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 adherence to the ethical standards that are laid down.

2. Can employee of the company invest into Equities/ Commodity futures?

Ans : This Code of Conduct has not been evolved to discourage investments by employees but to

Encourage long-term investments by employees

Ensure proper safeguards to various businesses of Karvy

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

Not to engage in trading that might result in the appearance of impropriety.

Discourage speculative/manipulative trading

Ensure priority on client’s interest and transactions

An employee of the company can invest into equities and can also buy “Gold” through KCTL.

3. Does this policy cover the spouses and dependents of the employees?

Ans : This code is applicable not only to employees but also to their spouses, dependent children and their spouses and anyone who is financially dependent on the employee.

4. Is this policy applicable to employees of Karvy Computershare Limited or Karvy

Comtrade Limited or Karvy Financial Services Limited ?

Ans : ‘Karvy’ refers to Karvy Stock Broking Limited, Karvy Consultants Limited, Karvy

Computershare (P) Limited, Karvy Investor Services Limited, Karvy Comtrade Limited,

Karvy Insurance Broking Limited, Karvy Global Services Limited, Karvy Inc., Karvy

Financial Services Limited, Karvy Realty (India) Limited, Karvy Data Management

Services Limited and other associated companies of the group.


OPENING OF TRADING AND DP ACCOUNT BY AN EMPLOYEE AND EMPLOYEE’S DEPENDANTS

5. Can I open a trading account with KSBL or KCTL ? Ans : As per the policy it is mandatory for an employee to open trading account only with

KSBL or KCTL. All employees of “KARVY” have to do their transactions with KSBL or KCTL only. Employees are prohibited from opening an account with any other broker. 6. Can I open a Trading account with other Broker?

Ans: Employees are prohibited from opening an account with any other broker. All employees of Karvy will have to do their transactions only with KSBL or KCTL. For this purpose, KSBL/KCTL will facilitate opening of a client account.

Exception: In case of an employee who trades on Exchanges outside India, exception to this prohibition is allowed based on the employee’s ability to justify the need for the same.

7. Do I need to take prior permission for opening a trading account with KSBL/ KCTL?

Ans: As per the Code of Conduct an employee is entitled to open account with any branch of KSBL/ KCTL without seeking prior permission. However, in the account opening form, an employee has to declare that he/ she is an employee of Karvy Group and also mention his/her employee code.

8. Do I need to shift my Trading account from other Broker to KARVY?

Ans: Yes. All employees of KARVY Group have to trade through KSBL or KCTL only for their trades as well as those of their dependents. As such, an employee would be required to close his/her account with other brokers and shift to KSBL /KCTL.

9. Do I need to open Demat Beneficiary Client Account with KSBL DP?

Ans: Yes, It is mandatory to open Demat account only with KSBL DP.

It case of exceptional circumstances, you can seek permission of Group Head – HR to open Demat account with DP other than KSBL DP.

INVESTMENTS & TRADING BY AN EMPLOYEE & EMPLOYEE’S DEPENDANT 10. Can I buy and sell shares at my will?

Ans: Yes. An employee can buy and sell securities in his account up to Rupees One Lac, without requiring any pre-approval subject to the following conditions:

a. 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 one lac in a day.


b. 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.

c. 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.

11. Which are the Investments that require pre-clearance ?

Ans: All trading/investments (in secondary market and secondary public offerings of the capital and commodities market) by the employees for an amount exceeding Rupees One lac will require pre-clearance from the Group Head - HR.

12. Does this code govern investment in equity shares only or it is applicable to other

securities as well?

Ans: Securities defined in this Code include equity shares, derivatives stocks, bonds,

debentures or other marketable securities, units of mutual funds, etc.,

However, employees are not allowed to invest in speculative products like “Futures

and Options (F&O)” or engage in intraday trading.

13. What should I do in case I wish to invest in shares, Exchanged Traded Funds or buy

“Gold” through KCTL in “Commodity Futures”?

Ans : As stated in answer to Q.No.10, an employee does not need pre-clearance if he buys

and sells securities upto Rupees One Lac and is not violating the provisions

mentioned therein. In case of transactions exceeding Rupees One Lac, the employee

needs pre-clearance of VP-HR.

14. What is the process of pre-clearance?

Ans: For the purpose of investment, an employee is required to send a mail to VP-HR as

per the Annexure-2(A) through his Zonal Business Head or Department Head for

seeking pre-clearance of purchase in the secondary Market.

On receiving the approval from the VP-HR, the employee can execute the

transactions, in the client code allotted to him/her from any branch of KSBL or KCTL.

The pre-clearance will be valid for 5 working days after the receipt of approval from

the VP-HR. If the trade is not executed within 5 working days, then fresh approval

has to be taken again from the VP-HR.

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

withdrawn and the trade (or unexecuted part thereof) shall not be executed by the

employee.

For seeking pre-clearance or any clarification on Code of Conduct please mail to [email protected]

mailto:[email protected]


15. Is there any dedicated email id for seeking pre-clearance?

Ans: YES. HR has created a dedicated email ID [email protected] for receiving requests

for pre-clearance.

16. What if I have indicated the price A at the time of pre-approval and by the time I get

the pre-clearance price has moved to A+1/A-?

Ans: No. The price mentioned in pre-approval would be indicative only. 17. What if I have to buy some security very urgently because price might shoot up by

the time I get the approval?

Ans: The employee is required to route his request for pre-clearance through Zonal Business Head / Department Head to VP-HR for approval. It is suggested to keep reasonable time on hand when an employee applies for pre-clearance.

18. Do I need pre-clearance for sale of securities?

Ans: Yes for Sale of Securities exceeding Rs.1 lac or where minimum holding period of 30 days has not been observed, an employee needs Pre-Approval from the VP-HR by sending a mail as per Annexure-2(b).

19. What a Department Head/ Zonal Head/ Regional Broking Head had to see while

recommending a request from an employee for pre-clearance?

Ans: While recommending the employee’s request for pre-clearance, the recommending officer 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





20. Do I need to submit any related details even after taking pre-clearance for buy/ sale of securities?

Ans: Employees holding a position of General Manager and above, shall be required to submit, at prescribed intervals, in the following details of their securities transactions including the statement of Dependent family members and Related Entities to the Group Head – HR

(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. SUBSCRIPTION TO IPO/ RPO AND MUTUAL FUNDS 21. What is the time duration for which this pre-clearance is valid?

Ans: It is valid only for Five days. If trade is not executed within 5 days, then fresh approval has to be obtained.

22. If I have taken prior permission of Zonal Broking Head/ Department Head for

opening the account, do I still require taking pre-approval before purchasing/ selling of securities?

Ans: Prior approval from Zonal Broking Head/ Department Head for opening account does not exempt an employee from seeking pre-clearance for purchase or sale of securities of the value of transaction exceeds Rs.1 lac. The employee has to seek pre-clearance from VP-HR by making an application on email as per the formats annexed with the Employee Code of Conduct and Business Ethics.

RESTRICTIONS ON TRADING IN INTRADAY, DERIVATIVES AND ACCOUNT OF

FRIENDS & RELATIVES 23. Am I allowed to apply for subscription to IPO(Initial Public Offers)?

Ans: 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 One lac at the offer price. However, the employees associated with Investment/ Merchant Banking and RTI/RSI related business, shall be required to obtain pre-clearance before making any application for IPO/RPO

An employee making an application for an IPO/ RPO in a category other than retail category, shall be required to obtain pre-clearance of the Group Head – HR and inform the latter within 48 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




24. Do I need pre-approval/submit declaration for all Mutual funds?

Ans: YES. Securities defined in this code also include units of Mutual Funds.

25. Am I allowed to do intraday trading or short term investment?

Ans : Employees are not allowed to do intraday trading. Short Term investments are

allowed provided it is held for a minimum period of 30 days.

Exception: In case where the sale of securities is necessitated due to personal reasons, the holding period may be waived by the VP-HR if he is satisfied with the justification given by the employee.

26. Can I do investments in “Futures & Options” by taking positions in contracts having

expiry more than 1 month?

Ans: NO. Irrespective of the holding period trading in derivatives is not allowed. 27. Can I use this account for trading on behalf of my relatives/ colleagues?

Ans: Employee trading account has to be used by the bonafide account holder only. This account cannot be used for trading on behalf of relatives or friends.

28. I am required to open a demo/test account for the purpose of giving online real-time

demonstration to my clients? Do I need pre-clearance of purchase or sale of securities made in demo account?

Ans: All such accounts are exempt from the compliance to the “Code of Conduct” provided your Zonal Broking Head/ Divisional Head takes specific approval of VP-HR for each such account.

29. Can I give mandate to my Family members and Friends to operate my Trading

Account?

Ans: NO. Employees need to use their respective trading account for their own investment only by obtaining Pre-clearance, where required, as per the Code of Conduct.

30. Can I place orders on behalf of my family members for Investment through my

Trading Account?

Ans: NO. Dependents as defined in the Code of Conduct and other relatives and friends of the employee need to open separate accounts in their own names and place the orders by themselves.

31. Can any colleague employee, not having Trading account, transfer the securities to my Demat account and sell the securities in my Trading Account?

Ans: NO


REGULATORY REQUIREMENTS

32. I understand that employees of other broking units are free to trade by opening a trading account with their own broker or with any outside broker?

Ans: This information is not true. All Institutional brokers are having “Code of Conduct” on similar lines for regulating investments by their employees.

33. Is there any regulatory requirement for this “Code of Conduct”?

Ans: Provisions of SEBI (Prohibition of Insider Trading) Act, 1992, is applicable to the intermediaries like broking entities Under Chapter IV of the Regulation, listed companies and intermediary associated with securities markets are required to have policy on disclosure and internal procedures for prevention of Insider trading. Employees of broking companies are considered to have access to the sensitive information and to prevent any misuse of the information each institutional broker has evolved a code of conduct for its employees.

Prevention of insider trading applicable to broking entities require all Directors, officers, and designated employees of the organization, who intend to deal in securities ,to have pre-clearance of transactions.

GREY LIST/ RESTRICTED LIST 34. What is the Grey List/ Restricted List?

Ans: 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.

HOLDINGS BEFORE JOINING KARVY 35. How and whom and whom should I inform the securities which I purchased before

joining KARVY?

Ans : At the time of Joining the Karvy Group, each employee is required to declare and submit the following details to VP-HR.

1. Demat / Trading account declaration of self and dependent family members as per Annexure – 4A.

2. Holding details of self and dependent family member as per Annexure – 4B.


36. I have not submitted the above details at the time of Joining Karvy Group. Please advise

the procedure to complete this process as I do not want to violate Code of Conduct?

Ans: The employee who has not earlier submitted the requisite details at the time of joining should submit these details to VP- HR immediately as per the formats given above.

EXTENSION IN SCOPE OF CODE 37. Does Policy “Employees’ Code of Conduct and Business Ethics” is restricted to

Employee Trading Only? Ans: The scope of the ‘Code’ has not been restricted to Employee Trading but it has

been enhanced to cover other areas like:

a) General Guidelines on Employees Behaviour and Work Environment b) Protocol for interaction with Regulatory authorities. c) Guidelines for interaction with Media. d) Guidelines on Information Security. e) Guidelines on Group Policy and process for Countering Bribery. f) Modalities of client entertainment and gifts. g) Procedure for redressal of investor grievances. h) Guidelines for Prevention of Money Laundering. i) “Supplementary Code of Conduct” for Branches & Dealers (Annexured to Code of

Conduct and Business Ethics) 38. Are there any norms to follow if am required to interact with the Electronic or Print

Media? Ans: Yes. Below are the restrictions every employee to follow if he happen to contact

Electronic or 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

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.

39. Are there any restrictions on giving gifts or entertainment to Client during the course

of Business?

Ans: YES. 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.

40. Can I know more about Karvy Group Policy on Anti-Bribery?

Ans: 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.

VIOLATION OF CODE OF CONDUCT

41. How am I bound by the Code of Conduct?

Ans: At the time of joining KARVY, each employee is required to sign a declaration as given in Annexure I. Thus declaration binds the employee to the Code of Conduct.


42. What are the consequences if I do not comply with this Code?

Ans: Any non compliance with the clauses of this code will be viewed seriously and the management of Karvy can initiate appropriate disciplinary action against the employees including suspension/termination of services.

43. Can I know more about Karvy Group Policy on Anti-Bribery?

Ans: 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.


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 : _________________________


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

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.


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.

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.


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.



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.


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 Relationship Trading A/c No.

Demat A/c No.

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)

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.


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


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

(Applicable To Broking Functions Of KSBL & KCTL)

Annexure 6 - Supplementary Code of Conduct for Branch Coordinators & Dealers.doc

Documents

REVISED FREQUENTLY ASKED QUESTIONS (FAQs) Relating ... · to close his/her account with other brokers and shift to KSBL /KCTL. 9. Do I need to open Demat Beneficiary Client Account