2011/02/005

February 01, 2011

To All,

Sub: Employee Trading and Code of Conduct Policy

This refers to our Employee Trading and Code of Conduct Policy (“The Policy”). The key points of the policy are reiterated herein below:

·  All employees are required to open their Trading and Demat account only with India Infoline Limited.

·  Declaration as per the format and the details of Trading and Demat account to be uploaded on IWIN.

·  Securities should be held for a minimum period of 30 days from the date of purchase/allotment.

·  No trading in F&O segment.

·  No Intra-day trading.

·  Trading only through dedicated dealers

As you are aware, for the ease of all employees, dedicated dealers have been appointed through whom the trades are mandatorily required to be routed as per the policy. The details of the dedicated dealers are as follows:

IIFL WEALTH EMPLOYEES / INSTITUTIONAL / INVESTMENT BANKING EMPLOYEES / OTHER IIFL EMPLOYEES
NAME OF DEDICATED DEALER / Mr. Santosh Singh and/or Ms. Romin Vora / Mr. Biren Patel and/or Mr. Sachin Gholap / Ms. Joyce Fernandes
EMAIL ID OF DEDICATED DEALER / / and/or /
TRADELINE NO. / (022) 43411819/43411872 / (022) 46464632 / 46464617 / (022)
40071000 /39440000

All employees are required to place their trade orders only with their respective Dedicated Dealers.

PRE-CLEARANCE AND PLACING OF ORDER PROCESS:

·  For placing orders for trades through the dedicated dealers, all employees are required to place request for trade in the format attached herewith (Application for Pre-Clearance and Placing Orders).

·  After filling up required details the said application has to be emailed to their respective dedicated dealers at the given email ids.

·  Based on the request received from employee, the respective dedicated dealer may execute the trade after due verification.

MINIMUM HOLDING OF 30 DAYS:

All employees are well aware that securities should be held for a minimum period of 30 days from the date of purchase/allotment. In case the sale of securities is necessitated by personal emergency, the holding period may be waived by the HOD/Compliance Officer after recording in writing his/her reasons. The request should be placed in the format attached herewith (Application for Waiver of Minimum Holding Period) with approvals of HOD/Compliance Officer.

VIOLATION OF POLICY:

If any employee is found violating The Policy, appropriate action shall be taken against the employee including penalty of Rs.10,000/- (Rupees Ten Thousand Only) or profit amount from the trade carried out (whichever is higher). Any penalty levied on employee shall be deducted directly from the monthly salary. Further, if any employee continues to violate policy even after levying of penalty, the account of the employee will be freezed with immediate effect.

All employees are required to strictly comply with the Employee Trading and Code of Conduct Policy attached herewith.

In case of any queries, please send a mail to or

Regards,

Corporate Communications,

India Infoline Ltd.