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Insider trading means

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(a) An act of subscribing, buying, selling, dealing or agreeing to subscribe, buy, sell or deal in any securities, by any director or key managerial personnel or any other officer of a company either as principal or agent if such director or key managerial personnel or any other officer of the company is reasonably expected to have access to any non – public price sensitive information in respect of securities of company; or 

(b) An act of counseling about procuring or communicating directly or indirectly any non – public price – sensitive information to any person; 

Insider means any person who is:

(a) A connected person; or

(b) In possession of or having access to unpublished price sensitive information; 

Connected Person “Connected person” means, -

(i) Any person who is or has during the 6 months prior to the concerned act been associated with a company, directly or indirectly, in any capacity including by reason of frequent communication with its officers or by being in any contractual, fiduciary or employment relationship or by being a director, officer or an employee of the company or holds any position including a professional or business relationship between himself and the company whether temporary or permanent, that allows such person, directly or indirectly, access to unpublished price sensitive information or is reasonably expected to allow such access.

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