3rd Schedule - Code of conduct - Securities and Exchange Board of India (Vault Managers) Regulations, 2021

THIRD SCHEDULE [See regulation 16] CODE OF CONDUCT SECURITIES AND EXCHANGE BOARD OF INDIA (VAULT MANAGERS) REGULATIONS, 2021 1. While providing vaulting services, the Vault Manager shall: i. be prompt in providing vaulting services to the beneficial owners. ii. take reasonable care to organize and control its affairs responsibly and effectively, with adequate risk management systems. iii. maintain adequate financial resources. iv. observe proper standards of market conduct in all their businesses relating to vaulting services. v. maintain the highest standards of integrity, fairness and professionalism in the discharge of its duties. vi. exercise due diligence in safe-keeping of the assets of the beneficial owners in its custody for which it is acting as a Vault Manager. vii. be continuously accountable for the movement of gold between its own authorized vaults and shall provide complete audit trail, whenever called for by the Board. viii. establish and maintain adequate infrastructural facility to be able to discharge vaulting services. ix. ensure that all operating procedures of the Vault Manager shall be well documented and backed by operation manuals. x. maintain confidentiality in respect of the information of the beneficial owner. xi. take necessary precautions to ensure that continuity in record keeping, where the records are kept electronically, is not lost or destroyed and that back up of entire records is available. xii. extend to other Vault Managers, depositories and clearing organizations all such co-operation that is necessary for the conduct of business in the areas of inter-vault settlements, transfer and withdrawal of gold. xiii. ensure that an arm s length relationship is maintained, both in terms of staff and systems, from its other businesses. xiv. be liable for loss of or any damage to the gold caused by its failure to exercise such care and diligence in regard to the gold as a careful and vigilant owner of the gold would exercise while in custody of the gold.