Fixed Deposit  Account Rules Fair Practice Code For Lending  Collection of Dues and Repossession of Security Savings Bank Account Rules Collections of cheques/instruments Code Of Conduct For Prevention Of Insider Trading Compensation Policy Customer Grievance Redressal Policy Implementation of PM 15 Point Programme Loan Policy Document for Micro & Small Enterprises Sector Policy for selection and appointment of Statutory Central Auditors and Statutory Branch Auditors in the Bank Features of Deceased Claims Settlement Process Related to Deposit Accounts Policy on Grievance Redressal for Govt. Pensioners Policy on Bank Deposits

UCO BANK
HEAD OFFICE: T&IM DEPARTMENT
(SHARE SECTION)
10, BTM SARANI: KOLKATA-700 001

CODE OF CONDUCT FOR PREVENTION OF INSIDER TRADING

1.1.The Bank has appointed General Manager (Inspection) as the Compliance Officer for this purpose and he will report to the Chairman & Managing Director and in his absence to the Executive Director.

1.2. The compliance officer shall be responsible for setting forth policies, procedures, monitoring adherence to the rules for the preservation of "Price Sensitive Information", pre-clearing of designated employees' and their dependents' trades (directly or through respective department heads or in any other manner as may be decided by the Chairman & Managing Director/ Executive Director of the Bank), monitoring of trades and the implementation of the code of conduct under the overall supervision of the Board of the Bank.

Explanation:

(i) Designated employees for the purpose of the code of conduct guidelines are defined as follows - all General Managers, all Dy. General Managers, all officers in Accounts Department, Board Secretariat, Chairman's Secretariat and Executive Director's Secretariat, all Officer Secretaries to the Dy General Managers and above.

(ii) Any other employees designated by the Bank from time to time to
whom these trading restrictions shall be applicable, keeping in mind
the objectives of this code of conduct. The Chairman & Managing
Director is authorized to identify the designated employees.

iii) The dependants for the purpose of this guidelines will be spouse,
sons and daughters.

1.3. The compliance officer shall maintain a record of the Directors/designated employees and any changes made in the list of Directors/designated employees.

1.4. The compliance officer shall assist all the employees in addressing any clarifications regarding the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulation, 1992 and the Bank's code of conduct.

2.0. Preservation of "Price Sensitive Information" .

2.1. Employees/Directors shall maintain the confidentiality of all Price
Sensitive Information. Employees/Directors shall not pass on such information to any person directly or indirectly by way of making a recommendation for the purchase or sale of securities.

2.2. Need to Know :

2.2.1. Price Sensitive Information is to be handled on a "need to know" basis, i.e., Price Sensitive Information should be disclosed only to those within the company who need the information to discharge their duty.

2.3. Limited Access to Confidential Information:

2.3.1. Files containing confidential information shall be kept secured. Computer files must have adequate security of login and pass word etc.

3.0. Prevention of misuse of "Price Sensitive Information".

3.1. All directors/officers and designated employees of the company shall be subjected to trading restrictions as enumerated below :

3.2. Trading Window.

3.2.1. Bank will specify the trading period (as on 3.2.3) to be called trading window for trading in the bank's securities. The trading window shall be closed during the time the information referred to in para 3.2.3. is unpublished.

3.2.2. When the trading window is closed, the employees/directors shall not trade in the company's securities in such period.

3.2.3. The trading window shall be closed from the date of declaration of the following events to the stock exchanges till the time of publication in newspaper/announcement media :

3.2.4. The trading window shall be opened 24 hours after the information referred to in para 3.2.3. is made public.

3.2.5. All directors/designated employees of the Bank shall conduct all their dealings in the securities of the Bank only in a valid trading window and shall not deal in any transaction involving the purchase or sale of the Bank's securities during the period when trading window is closed, as referred to in para 3.2.3. or during any other period as may be specified by the Bank from time to time.

3.3. Pre-clearance of trades:

3.3.1. All directors/designated employees of the Bank who intend to deal in securities of the Bank (above a minimum threshold limit of 25000 shares or Rs.5 lac in value or the dealing which changes the share holding pattern or voting right by 1%, should preclude the transaction as per the predealing procedure as described hereunder :

3.3.2. An application may be made in such form as the Bank may notify in this regard to the compliance officer indicating the estimated number of securities that the designated employee/director intends to deal in, the details as to the depository with which he has a security account, the details as to the securities in such depository made and such other details as may be required by any rule made by the Bank in this behalf.

3.3.3. An undertaking shall be executed in favour of the Bank by such designated employee/director/ incorporating inter-alia, the following clauses as may be applicable :

(a) that the employee/director/ does not have any access or has not received "Price Sensitive Information" up to the time of signing the undertaking.

(b) that in case the employee/director/ has access to or receives "Price Sensitive Information" after the signing of the undertaking but before the execution of the transaction he/she shall inform the compliance officer of the change in his position and that he/she would completely refrain from dealing in the securities of the Bank till the time such information becomes public.

(c) that he/she has not contravened the code of conduct for prevention of insider trading as notified by the Bank from time to time.

(d) that he/she has made a full and true disclosure in the matter.

4.0. Other restrictions:

4.1. All directors/designated employees shall execute their order in respect of the securities of the Bank within one week after the approval of preclearance is given. If the order is not executed within one week after the approval is given, the employee/director must preclear the transaction again.

4.2. All directors/designated employees shall hold their investments in securities for a minimum period of 30 days in order to be considered as being held for investment purposes. The holding period shall also apply to subscription in the primary market (IPOs). In the case of IPOs, the holding period would commence when the securities are actually allotted.

4.3. In case the sale of securities is necessitated by personal emergency, the holding period may be waived by the compliance officer after recording in writing his/her reasons in this regard.

5.0. Reporting requirements for transactions in securities.

5.1.All directors/designated employees of the Bank shall be required to forward following details of their securities transactions including the statement of dependent family members (as defined in paragraph 1.2.(iii) ) to the compliance officer :

(a) All holding of the share/voting rights of the bank held by directors/designated employees within 4 days of the date when the code of conduct comes into effect or within 4 days of becoming director/designated employee whichever is later.

(b) The director/designated employee shall disclose to the Bank, the change in the share holding or voting rights, if there has been a change in such holdings from the last disclosure made under paragraph 5.1(a) and the change exceeds Rs.5 lac in value or 5000 shares or 2% of total share holding or voting right whichever is lower.

Disclosure under the paragraph 5.1(b) shall be made within 4 working days of -

(j) the receipt of intimation of allotment of shares or
(ii) the acquisition or sale of shares or voting rights as the case may be.

The Bank within 5 days of receipt shall disclose to all stock exchanges where the shares are listed, the information received under guidelines in paragraph 5.1(a) and 5.1(b) above.

(c) Annual statement of all holding in securities as on 31st March every year within 15 days of the close of year.

5.2. The compliance officer shall maintain records of all the declarations in the appropriate form given by the directors/designated employees for a minimum period of 3 years.

5.3. The compliance officer shall place before the Chairman & Managing director or a committee specified by the Bank on a monthly basis all the details of the dealing in the securities by employees/directors/ of the Bank and the accompanying documents that such persons had executed under the predealing procedure as envisaged in this code.

6.0. Penalty for contravention of code of conduct.

6.1. Any employee/director/ who trades in securities or communicates any information for trading in securities in contravention of code of conduct may be penalized and appropriate action may be taken by the Bank.

6.2. Employees/directors of the Bank who violate the code of conduct shall also be subject to disciplinary action by the Bank, which may include wage freeze, suspension, etc.

6.3. The action by the Bank shall not preclude SEBI from any action in case of violation of SEBI (Prohibition of Insider Trading), Regulations, 1992.

1.0. Information to SEBI in case of violation of SEBI (Prohibition of Insider Trading) Regulations, 1992.

1.1. In case it is observed by the Bank/compliance officer that there has been a violation of SEBI (Prohibition of Insider Trading) Regulations, 1992, SEBI shall be informed by the Bank.

8. The code of conduct will come into being with effect from 22nd March, 2004.