1. Flow Chart showing movement of forms between Insider & Compliance Officer
COMPLIANCE OFFICER
Initial & Approve / Intimate
Periodic Refuse about Submit Request Submit
Disclosur Trade Pre- Trade All Processes Initial/Con Trade Continual
e forms clearances Window centrally tinual Pre- disclosure
sent to Closures managed by disclosure clearance
Insider
INTROSPECT
EMPLOYEE / INSIDER
Role & Duties of the compliance officer
Submit list of initial & continual disclosures
(Forms A, B, C & D) Stock Exchange(s)
Compliance
Submit list of transactions of Insiders MD / CMD
Officer *
Intimate trade closure windows Insider/Employee
Remind pending Initial/Periodical disclosures Insider/Employee
Introspect
Remind pending Pre-clearance/Trade conf Insider/Employee
Monitor holding/transactions of substantial Stock Exchange(s)
shareholders
Send pre-filled forms that includes Periodical Insider/Employee
Disclosure, Pre-clearance Confirmation
/Rejection etc.,
 All the above processes are managed by Introspect.

2. Routine Activities and integration of Introspect with Shareholders’ data
NSDL
Issuer/Registrar
/CDSL Monitor addition of new
accounts of insiders/subs.
Shareholders, matching on
PAN / Name.
Monitor Insider holdings
between disclosed & current
figures
Compliance INTROSPECT
Officer
Track those Insider s who
violate the ‘Code of Conduct’
on a periodical basis.
Insiders/Subs. Shareholders
Ledger based on benpos files.

3. 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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