Code of Conduct

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..... all reasonable steps to establish the true and full identity of each of its clients, and of each client s financial situation and maintain record of the same. 6. A Debenture Trustee shall ensure that any change in registration status/any penal action taken by Board or any material change in financial position which may adversely affect the interests of clients/debenture holders is promptly informed to the clients and any business remaining outstanding is transferred to another registered intermediary in accordance with any instructions of the affected clients. 7. A Debenture Trustee shall avoid conflict of interest and make adequate disclosure of its interest. 8. A Debenture Trustee shall not divulge to anybody either orally or in writing, .....

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..... nformation about its business, including contact details, services available to clients, and the identity and status of employees and others acting on its behalf with whom the client may have to contact. 15. A Debenture Trustee shall ensure that adequate disclosures are made to the debenture holders, in a comprehensible and timely manner so as to enable them to make a balanced and informed decision. 16. A Debenture Trustee shall endeavour to ensure that- (a) inquiries from debenture holders are adequately dealt with; (b) grievances of debenture holders are redressed in a timely and appropriate manner; (c) where a complaint is not remedied promptly, the debenture holder is advised of any further steps which may be available to the debenture .....

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..... ess a disclosure of his interest including long or short position in the said security has been made, while rendering such advice. (b) In case, an employee of the Debenture Trustee is rendering such advice, the debenture trustee shall ensure that he discloses his interest, the interest of his dependent family members and that of the employer, including their long or short position in the said security, while rendering such advice. 23. A Debenture Trustee shall ensure that any person it employs or appoints to conduct business is fit and proper and otherwise qualified to act in the capacity so employed or appointed (including having relevant professional training or experience). 24. A Debenture Trustee shall ensure that it has adequate resour .....

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