POLICY FOR CLIENT CODE MODIFICATION

Objective : To frame the guidelines for modification to client codes post trade execution and reporting of such Client Code Modifications.

Brief about Client Code Modification: Client Code Modification means modification / change of the client codes after execution of trades. Stock Exchanges provide a facility to modify any client code after the trade has been executed to rectify any error or wrong data entry done by the dealers at the time of punching orders. However, such Client Code modification is subject to certain guidelines as to the time limit within which the client code modification is to be carried out, terminal / system on which such modifications can be done etc. The facility is mainly to provide a system for modification of client codes in case genuine errors in punching / placing the orders. It is to be used as an exception and not a routine. To prevent misuse of the facility Stock Exchanges levy penalty / fine for all noninstitutional client code modifications.

IScope of the Policy: This policy covers all the Client Code Modifications carried out / to be carried out in any of the client accounts controlled by HO, subject to the guidelines issued by the SEBI / Stock Exchanges from time to time, in any segment of any exchange for which VIPL is a member broker. Error Trades: “Error Trades” means the trades which will be modified / to be modified / allowed, to be modified subject to guidelines of the SEBI / Stock Exchanges and this policy. For the purpose of this Policy, only the following types of trades shall be modified / allowed to be modified:

In case of NSE (NOTE: no consistent pattern in such modifications):

• Client code/name and modified client code/name are similar to each other but such modifications are not repetitive.
• Family Code (spouse, dependent parents, dependent children and HUF).
• Punching error / typing error of client codes due to any genuine error or mistake in order entry, while punching the order, by any of dealer.
• Trade entered for wrong client due to any miscommunication from the client / authorized representative of the client.

• The facility for Client Code Modification can be used only in case of Error Trade.
• The Client Code Modification shall be carried out only on the designated system and / or as per the process as may be prescribed by SEBI / Stock Exchange. Place for Client Code Modifibcation: Any Client Code Modification shall, subject to compliance of this policy, be carried out by RMS at HO of all the Error Trades happened in Capital Market Segment of NSE.

Penalty: The penalty or fine, if any, levied on VIPL for any wrong trade occurred due to any miscommunication from the client / authorized representative of the client shall be borne by the client.