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September 18, 2025
We are pleased to announce the introduction of a new Prohibition of Insider Trading Policy in Mirae Asset Sharekhan (MASK) to reinforce our commitment to ethical conduct and regulatory compliance. The updated policy, applicable to all employees of MASK*, revises the definition of “Designated Persons”, standardises the approval validity period for employees trading in their personal accounts, and relaxes the rule for applying for initial public offerings through the personal accounts of employees. All Sherus must abide by the new Prohibition of Insider Trading Policy, which comes into effect from September x, 2025.
What has changed in MASK’s insider trading policy
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Existing |
New |
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Classification of “Designated Persons”
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Employees get automatically defined into various categories:
1. Permanent Sensitive: Designated employees (Research Analysts)
2. Simple Sensitive: Designated employees (Compliance PE - SSD, Compliance MI - SSD, Compliance Officer - SSD, Director - SSD), Branch Managers, Relationship Managers, Dealers, Group Heads, Zonal Heads, Client Relationship Executives, and Dial-N-Trade Executives
3. Non-Sensitive: Employees excluding those categorised as “Permanent Sensitive” and “Simple Sensitive”
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“Designated Persons” shall include:
a) Directors
b) Chief Executive Officer and employees up to two levels below Chief Executive Officer
c) Staff of Compliance and Risk, Research Analysts, Division Heads and Team Heads
d) Immediate relatives of the persons specified in (a), (b) and (c) above
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Approval validity for trading in personal accounts
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For “Permanent Sensitive” and “Simple Sensitive” employees, the approval validity is of two calendar days and that for “Non-Sensitive” employees, the approval validity is of seven calendar days.
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The approval validity is of five calendar days for all employees.
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Conditions for IPO application from personal accounts
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For IPOs, pre-clearance and holding period are mandatory for all employees.
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No pre-clearance and holding period are required for IPOs.
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You are requested to take note of the new policy and strictly follow the updated guidelines. Let’s continue to uphold the highest standards of integrity and protect our company’s reputation.
In case you need any clarification, please feel free to write to us at eit@sharekhan.com.
*MASK includes Sharekhan Limited, Sharekhan.Com India Private Limited, and Mirae Asset Sharekhan Financial Services Limited
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