MCB Bank Limited COMPLIANCE & CONTROLS GROUP

I NSIDER T RADING M ANUAL

2016
 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

Document Control Sheet

Title Insider Trading Manual

Owner Compliance & Controls Group

Prepared by Compliance & Controls Group

Review Frequency Once in two years

Latest Review/ Approval date March 2016

Next review date 2 years from the approval date

Version Version 1.0

 Legal Affairs Group

 Risk Management Group
 Operations Group
Reviewed by  Financial Control Group
 Corporate Affairs
 Audit and Risk Assets Review Group
 Human Resource Management Group

Recommended By Group Head – Compliance & Controls Group

Approved By President

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 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

TABLE OF CONTENTS
CHAPTER 1: INTRODUCTION ......................................................................................................... 3
1.1. Scope ......................................................................................................................................... 3
CHAPTER 2: DEFINITIONS ............................................................................................................. 4
2.1. Beneficial Ownership: ............................................................................................................... 4
2.2. Clients........................................................................................................................................ 4
2.3. Connected Persons ................................................................................................................... 4
2.4. Close Relatives .......................................................................................................................... 4
2.5. Closed Period ............................................................................................................................ 4
2.6. Dealing ...................................................................................................................................... 4
2.7. Executives ................................................................................................................................. 5
2.8. Insider Trading .......................................................................................................................... 5
2.9. Insider ....................................................................................................................................... 6
2.10. Inside Information / Unpublished Price Sensitive Information ................................................ 7
2.11. Inadvertent “Tipping”: .............................................................................................................. 7
2.12. Investments and Securities ....................................................................................................... 8
2.13. Material Information................................................................................................................. 8
2.14. “Nonpublic” Information .......................................................................................................... 9
2.15. “Tipping” of Information to Others......................................................................................... 10
CHAPTER 3: PROHIBITION OF “INSIDER TRADING” ...................................................................... 11
3.1. List of Insiders ......................................................................................................................... 11
3.2. Undertaking - For Shares / Securities Of Mcb And Its Clients Listed On Stock Exchange(S) .. 12
3.3. SIX MONTHLY SHAREHOLDING DISCLOSURES ........................................................................ 13
3.4. FREQUENCY OF FINANCIAL REPORTING ................................................................................. 13
3.5. DISCLOSURE OF INTEREST BY A DIRECTOR, CEO, OR EXECUTIVE ........................................... 14
Chapter 4 SANCTIONS ................................................................................................................ 15
Chapter 5 ROLE OF COMPLIANCE ................................................................................................ 16
ANNEXURE-I .............................................................................................................................. 17
ANNEXURE II.............................................................................................................................. 18
ANNEXURE-III ............................................................................................................................ 20

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 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

CHAPTER 1: INTRODUCTION
Insider Trading Manual is an underlying document of Policy on Prohibition of Insider Trading. It
is prepared to ensure that the Bank is in compliance with Securities Act 2015, Listed Companies
(Prohibition of Insiders Trading) Guidelines (SECP) issued in 2001, Code of Corporate
Governance 2012(SECP) and any other law for the time being enforced and changes made
therein, of the country which prohibit insider trading. During the course of performing duties
employees have access to unpublished price sensitive information, which is either directly or
indirectly related to their job responsibilities. Leakage and/or misuse of this information can
hamper organization’s reputation.

If at any point in time provision/s of this Manual contradicts or is inconsistent with the laws &
regulations of Pakistan, then the updated provision(s) of the applicable law(s) and regulation(s)
will supersede the relevant text in this document.

1.1. Scope

This Manual applies to all Directors, employees (all permanent/regular and Bank contract
employees) and connected persons of MCB Bank Limited (MCB Bank), and investment and
trade activities of close relatives of the aforementioned individuals.

This Manual applies to Material Unpublished price sensitive information, relating to all the
listed securities of MCB Bank and its Clients, unless specifically excluded in the Policy on
Prohibition of Insider Trading (the “Policy”). It also covers material non-public information
relating to any member institutions, counterparties, vendors, or any other company, whose
unpublished price sensitive information may come in the knowledge of individuals covered
under the scope of the Policy through their association with MCB Bank.

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 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

CHAPTER 2: DEFINITIONS

2.1.Beneficial Ownership:

For the purposes of tendering gain, beneficial ownership of securities of any person shall be
deemed to include the securities beneficially owned, held or controlled by him or his spouse or
by any of his dependent lineal ascendants or descendants.

2.2. Clients
This includes listed companies (including listed associates and subsidiaries of listed
companies) with / for whom MCB is maintaining Client-Banker Relationship, Performing
Research and/or Managing Portfolio.

2.3. Connected Persons

Is a director or occupies the position as an officer or an employee of the company or holds a

position involving a professional or Business relationship between himself and the
company and who may reasonably be expected to have an access to unpublished price
sensitive information in relation to that company.

2.4. Close Relatives

Close relatives means spouse(s), dependent lineal ascendants and descendants.

2.5. Closed Period

The closed period is a period during which no director, CEO or executive shall, directly or
indirectly, deal in the shares of the listed company in any manner.

The closed period shall start from the day when any document/statement, which forms the
basis of price sensitive information, is sent to the board of directors and terminate after the
information is made public. It is expected that such a restriction would help minimize the risk
of insider trading by key management/directors of the company.

Company Secretary shall inform about close period to Directors, CEO, and Executives of the
Bank & shall also intimate about close period to respective Stock Exchange(s).

2.6. Dealing

"Dealing in securities" means an act of buying, selling or agreeing to buy, sell or deal in
security(ies) by any person either as principal or agent (for self or anyone else)

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MCB Bank Limited

2.7. Executives

As defined in Code of Corporate Governance 2012, “Executive” means the CEO, COO, CFO,
Head of Internal Audit and Company Secretary by whatever name called, and other
employees of MCB Bank, whose basic salary exceeds threshold1 as decided by the Board from
time to time.

2.8. Insider Trading

“Insider trading” shall include:

a) An insider person transacting any deal, directly or indirectly, using inside

information involving listed securities to which the inside information pertains,
or using others to transact such deals;

b) Any other person to whom inside information has been passed or disclosed by an
insider person transacting any deal, directly or indirectly, using inside information
involving listed securities to which the inside information pertains or using others to
transact such deals;

c) Transaction by any person as specified in clauses (a) and (b) or any other person
who knows or ought to have known under normal and reasonable circumstances,
that the information possessed and used for transacting any deal is inside information;
or

d) An insider person passing on inside information to any other person, or suggesting or

recommending to another person to engage in or dealing in such listed securities
with or without the inside information being disclosed to the person who has dealt in
such securities.

The following shall not be deemed as insider trading:

(a) Any transaction performed under an agreement that was concluded before the time of
gaining access to inside information; or

(b) The disclosure of inside information by an insider person as required under law.

No contract shall e void or unenforcea le y reason only of an offence under this section”

1
As resolved by the BOD, currently the “threshold” is Rs. 500,000

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MCB Bank Limited

2.9. Insider
a) A person who is a director, chief executive, managing agent, Chief Financial Officer
(CFO), Company Secretary or Group Head Audit & RAR of MCB Bank or the
beneficial owner holding directly or indirectly not less than ten percent (10%) of
the shares of MCB Bank; or

b) A person who, is or was connected with MCB Bank or is deemed to have been
connected with MCB Bank, and who is reasonably expected to have access, by
virtue of such connection, to unpublished price sensitive information in respect of
securities of MCB Bank who has received or has had access to such
unpublished price sensitive information. List of Insider roles in MCB can be
defined as e.g. members of the Management Committee; relevant employees of
Corporate Finance & International Banking Group, Risk Management Group,
Asset Rehabilitation Group, Capital Markets, Treasury Group, Financial Controls
Group, Audit & Risk Assets Review Group and Retail Banking Group etc.

For clarification, Insider includes:

a) Any sponsor, executive officer or director of an issuer of listed securities;
b) Any sponsor, executive officer, director or partners of a legal person or
unincorporated business association, in which the issuer holds a share or voting
rights, directly or indirectly, of twenty-five (25%) percent or more;
c) Any sponsor, executive officer director or partner of a legal person or
unincorporated business association who holds, directly or indirectly, a share or
voting rights of twenty percent (20%) or more in an issuer of listed securities;
d) Any sponsor, executive officer or director of an organization that has been
engaged in the placement of securities or the public offer of securities, as well as
any employee of the issuer or an organization participating in the issuing and
marketing of such securities who has had access to insider information during
his employment, for a period of one year after leaving employment;
e) Any person holding a share, directly or indirectly, which enables him to appoint
director on the board, or ten per cent (10%) or more shares of an issuer of listed
securities;
f) Any sponsor, executive officer or director of a credit institution in which the
issuer of listed securities has an account;
g) Any person obtaining inside information as part of his employment or when
discharging his usual duties in an official capacity or in any other way relating to
work performed under contract of employment or otherwise;
h) Any person obtaining inside information through unlawful means;
i) Spouse, lineal ascendant or descendant including step children partner or
nominee of a person referred to in clauses (a) to (h); and
j) Any person obtaining information or advice to trade in a security from any
person referred to in clauses (a) to (i).

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MCB Bank Limited

2.10. Inside Information / Unpublished Price Sensitive Information

"Unpublished price sensitive information" in relation to a listed security means any

information which relates to the following matters or is of concern, directly or indirectly, to a
company, and is not generally known or published by such company for general information,
but which if published or known, is likely to materially affect the price, of securities of that
company in the market:-

a) Financial results (Quarterly, Half-yearly and Annual) of the company;

b) Intended declaration of dividends (both interim and final);
c) Issue of shares by way of rights, bonus, etc.
d) Any major expansion plans or execution of new projects;
e) Amalgamation, mergers and takeovers;
f) Disposal of the whole or substantially the whole of the undertaking;
g) Such other information as may affect the earnings of the company; and
h) Any changes in policies, plans or operations of the company.

Also refer to “Inside Information” as defined in Section 129 of Securities Act 2015.

2.11. Inadvertent “Tipping”:

a) Directors, officers and employees should take care that material nonpublic
information is secure. For example, files containing such information should be sealed
and access to computer files containing such information should be restricted. In
addition, directors, officers and employees should not discuss such information in
public places where it can be overheard, such as elevators, restaurants, taxis and
airplanes.
b) No director, officer or employee is permitted to give trading advice of any kind about
the securities of an issuer to anyone while possessing material nonpublic information
about such issuer, which information came to such director, officer or employee
through his or her relationship with MCB Bank, except to advise others not to trade if
doing so might violate the law or Policy on Prohibition of Insider Trading. MCB Bank
strongly discourages all directors, officers and employees from giving trading
advice concerning the securities of MCB Bank or to third parties even when such
director, officer or employee does not possess material nonpublic information about
MCB Bank.

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MCB Bank Limited

2.12. Investments and Securities

Investment and Securities include all Public Listed Securities of MCB Bank, its Clients and
Direct / Indirect Subsidiaries or any other entity in which MCB Bank has stake of not less than
50%. In addition these include securities of companies with which MCB Bank is maintaining
any relationship as given above. These are defined below in the widest sense and including
but not limited to:

Shares, Debentures, Options, Futures, and Forwards, Investment Trusts, Financial

Derivatives, Contracts for Difference, Currency Futures, Funds, where beneficiary can self-
select investment in portfolio, Commodity Derivatives and any related cash position, Precious
Metal Derivatives and any related cash position, Fixed Income Products & Rights in any of the
above.

2.13. Material Information

Information is generally regarded as “material” if there is a substantial likelihood that a

reasonable investor would consider the information important in deciding whether to
purchase, sell or hold a security, or if the information would significantly alter the total mix of
publicly available information considered by the reasonable investor in making an investment
decision.

Material information can be negative or positive and can relate to virtually any aspect of MCB
Bank’s Business and its clients or to any type of security, debt or equity. For example, in
most cases information concerning the following events should e presumed to e “material:”

a) Changes in performance, or the expectation of the performance of business

b) Changes in financial condition, e.g. cash flow crisis, credit crunch;
c) Changes in control and control arrangement
d) Changes in Directors, and (if applicable) supervisors;
e) Changes in Directors, Service Contracts
f) Changes in auditors or any other information related to auditors’ activity;
g) Capital share consolidation and capital reduction;
h) Issue of debt securities, convertible instruments, options or warrants to acquire or
subscribe for securities;
i) Takeovers and mergers;
j) Purchase or disposal of equity interests or other major assets or business operations;
k) Formation of joint ventures;
l) Restructuring, reorganization demerger and spin-offs that have an effect on
corporation’s assets, liabilities, financial position or profits and losses;
m) Decision concerning buy-back programs or transactions in other listed financial
instruments;
n) Changes in memorandum and articles of association;
o) Filing and winding up petitions, the issuing of winding up orders or the
appointment of provisional managers or liquidators;

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MCB Bank Limited

p) Legal disputes and proceedings;

q) Revocation or cancellation of credit lines by one or more banks;
r) Revaluation of assets;
s) Insolvency of relevant debtors;
t) Reduction of real properties’ values;
u) Physical destruction of uninsured goods;
v) New licenses, patents, registered trademarks;
w) Decrease or increase in the value of financial instruments in portfolio which include
financial assets or liabilities arising from future contracts, derivatives, warrants swaps
protective hedges, credit default swaps;
x) Decrease in value of patents or rights or intangible assets due to market innovation;
y) Receiving acquisition bids for relevant assets;
z) Innovative products or processes;
aa) Changes in expected earnings or losses;
bb) Orders received from customers, their cancellation or important changes;
cc) Withdrawal from entity into new core business areas;
dd) Changes in investment policy;
ee) Changes in accounting policy;
ff) Ex-dividend date, changes in dividend payment date and amount of dividend;
gg) Changes in dividend policy;
hh) Divestment by majority shareholders;
ii) Pledge of company’s shares y controlling shareholders; or
jj) Changes in a matter which was the subject of a previous announcement.

The above list is merely illustrative and non-exhaustive. Therefore, any other type/s of
information may also be considered material depending upon its criticality and
circumstances.

2.14. “Nonpublic” Information

Information is “nonpu lic” if it is not available to the general public. In order for information
to be considered public, it must be broadly disseminated or made widely available to the
general public by distributing a press release through a widely disseminated news or wire
service or by any other non-exclusionary method of disclosure that is reasonably designed to
provide broad public access - such as an announcement at a conference of which the public
had notice and to which the public was granted access, either by personal attendance or
telephonic or electronic access.
In addition, even after a public announcement of material information, a reasonable period of
time must elapse in order for the market to react to the information. When in doubt, the
information involved should be presumed to be both material and not to have been disclosed
to the public.

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MCB Bank Limited

2.15. “Tipping” of Information to Others

A director, officer or employee who improperly reveals material nonpublic information to

another person can e held lia le for the trading activities of his or her “tippee” and any
other person with whom the tippee shares the information. The penalties discussed
hereinafter apply whether or not an insider benefits financially from such trades and
whether or not an insider knew or intended that another person would trade in the relevant
security on the basis of the information revealed.

A director, officer or employee is not permitted to disclose material nonpublic information

concerning an issuer of securities, which information was o tained through such director’s,
officer’s or employee’s relationship with MCB Bank, to another person who may
subsequently use that information to his or her profit. To reduce the chances of inadvertent
tipping of material nonpublic information, except as required by law, no such information is
to be disclosed to anyone except MCB Bank directors, personnel and representatives (such as
accountants, attorneys and agents) who have a valid business reason for receiving such
information (i.e., who have a “need to know” the information in order to serve the usiness
purposes of MCB Bank). Such information should be regarded as particularly sensitive,
confidential information.

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 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

CHAPTER 3: PROHIBITION OF “INSIDER TRADING”

All Employees and Directors can trade in MCB Bank’s shares as permissible under the pertinent
laws, regulations and MCB Bank’s Policy on Prohi ition of Insider Trading.

3.1. List of Insiders

List of all the insiders should be maintain and regularly updated as per format provided in
Annexure-I. Nominated Group Coordinators will be responsible to collect all the required
information of employees in prescribed format and submit the same to Compliance & Controls
Group. Further, they are also responsible to communicate to the CCG as and when there are any
changes in annexure-I.

However for CEO and directors, Annexure-I should be obtained by the Company Secretary office
and they are responsible for updation and maintenance.

All employees should prioritize dealings in securities of MCB Bank and its clients and they
should not disclose or recommend on the basis of non-public price sensitive information
obtained through association with MCB Bank; to connected or unconnected third parties or
connected persons of MCB Bank.

All employees should further ensure that their investment and trade activities do not distract
them from performing their duties during business hours. Treasury front Office / Capital
Market Division staff is not allowed to use Mobile Phone in the deal room / official premises
during business hours with an exception to attend emergency personal call(s) strictly outside
the deal room (as applicable). Moreover it is to be ensured that deal(s) is/are conducted
through official recorded line(s) in the official premises / deal room only.

Connected persons must not acknowledge to being an “insider” to a third party or any other
person who does not have the same inside information (even another employee).

MCB Bank’s employees should not indulge in trading of the shares, on the asis of inside /
Material Non-public information, of those companies which are clients of MCB Bank
especially those with whom the employee has a direct (customer - banker) relationship, or
any other company where in the employee may have access to insider / non-public
information due to such association with MCB Bank or by virtue of conducting analyses /
research on such companies.

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MCB Bank Limited

No Employee of MCB Bank shall submit multiple applications for new issues, where this
would be contrary to the terms of issue or where MCB Bank is acting as an issuer, sponsor, or
broker to reduce the risk of Insider Trading.

All Employees must report in writing to Compliance & Controls Group CCG without any delay
with a copy to their respective Head/ Group Head, if they are in receipt of any inside
information which does not directly / indirectly relate to their job responsibilities, and also
notify CCG through Annexure-I if any of their personal dealing account transaction has
potential to give rise to conflict of interest.

3.2. UNDERTAKING - FOR SHARES / SECURITIES OF MCB AND ITS CLIENTS

LISTED ON STOCK EXCHANGE(S)

Employees and directors of MCB Bank are required to follow the “Policy on Prohi ition of
Insider Trading” and confirm y providing the undertaking that he/she has read all terms and
conditions as specified in the Policy and that he / she has not dealt / recommended to deal in
any transaction either for personal or for the benefit of any other person on the basis of inside
information or has not disclosed such information to any third party including employee of MCB
Bank other than in the normal course of business such as credit appraisals. There, the “inside”
nature of information should be specifically mentioned.

These undertakings should be provided as per the format stated in Annexure-II of the Manual
and the same will be forwarded to CCG on yearly basis within one month of proceeding next
year i.e. 31st January 20XX for January to December 20XX.

However, the Directors and CEO will forward the signed undertaking to the Company Secretary
as per timeline defined above.

Director, CEO, or an Executive of MCB Bank Limited or their Spouse(s) shall not deal in the
shares of MCB Bank in any manner during the closed period to reduce the risk of insider
trading. Company Secretary shall advise MCB Bank’s directors, chief executive and other
executives about the closed period at the time of circulating agenda and working papers for the
Board meetings.

Except in accordance with the regulation(s) of SECP, a person shall not sell any listed securities
that he or his principal does not own for his own account or for the account of another person
and/or otherwise as stated in the Section 77 of Securities Act 2015

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 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

3.3. SIX MONTHLY SHAREHOLDING DISCLOSURES

All employees must provide MCB’s shareholding details for self, spouse(s), dependent lineal
ascendants and descendants invariably to CCG. Similarly all Directors must provide MCB’s
Shareholding details for self, spouse(s), dependent lineal ascendants and descendants
invariably to the company secretary.

Disclosure of shareholdings in MCB Bank’s shares / securities as required a ove shall e

provided to CCG on the prescribed format (Annexure-III), latest by last day of the month
following the end of Half Year i.e. July 31st and January 31st. same will be forwarded by CCG to
the Company Secretary’s office and Financial Control Group for their required actions.

For Directors and CEO and their spouse(s), dependent lineal ascendants and descendants,
disclosure requirement for MCB shareholding shall be ensured by the office of Company
Secretary.

3.4. FREQUENCY OF FINANCIAL REPORTING

Corporate Affairs shall immediately disseminate to the SECP and the stock exchange on which
its shares are listed all material information relating to the business and other affairs of the
MCB bank that will affect the market price of its shares.

Information including but not limited to any material change in the nature of business of the
Bank; information regarding any joint ventures, merger or acquisition or any material contract
entered into or lost; purchase or sale of significant assets; franchise, brand name, goodwill,
royalty, financial plan, etc.; any unforeseen or undisclosed impairment of assets due to
technological obsolescence, etc.; delay or loss of production due to strike, fire, natural
calamities, major breakdown, etc.; issue or redemption of any securities; a major change in
borrowings including projected gains to accrue to the company; any default in repayment or
rescheduling of loans; change in directors, Chairman or CEO of the listed company and other
affairs of the MCB bank that will affect the market price of its shares, shall be immediately
disseminated to the SECP and the stock exchange on which MCB’s shares are listed as soon as
any decision about above referred matters or any other significant issue is taken by the board
or a significant matter requiring disclosure has come into the knowledge of company’s
management.

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3.5. DISCLOSURE OF INTEREST BY A DIRECTOR, CEO, OR EXECUTIVE

Director, CEO or Executive of MCB Bank or their spouses and the substantial shareholders sell,
buy or transact, whether directly or indirectly, in shares of the bank of which he is a director,
CEO or Executive, as the case may be, he shall immediately notify in writing to the Company
Secretary of such transaction. Such director, CEO or executive, as the case may be, shall also
deliver a written record of the price, number of shares, form of share certificates, i.e., whether
physical or electronic within the Central Depository System, and nature of transaction within
two days of effecting the transaction. The Company Secretary is required to immediately
forward the same to the Exchange for its dissemination to all concerned. The notice of the
director, CEO or Executive, as the case may be, shall also be presented by the Company
Secretary at the meeting of the board of directors immediately subsequent to such transaction.
Also in the event of default by a director, CEO or Executive to give a written notice or deliver a
written record / information relating to such transaction, the Company Secretary shall place the
matter before the board of directors in its immediate next meeting.

It is required to advise the directors about the closed period at the time of circulating agenda
and working papers for the board meetings, along with sending intimation of the same to the
stock exchanges.

In view of above and as required under the above referred clauses of Pakistan Stock Exchange
Limited (PSX) Regulations, following are hereby advised to ensure:

a) Timely communication of complete information to the Exchange for its dissemination to

all concerned.
b) Placement of details of transactions in the subsequent Board Meetings duly highlighted
the default(s), if any, for their consideration and necessary action.
c) Immediately submission of relevant extracts of the Minutes of Board of Directors
Meeting to the Exchange for record purposes.

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MCB Bank Limited

Chapter 4 SANCTIONS

An individual who uses or allows the use of information obtained as a result of his or her
relationship with MCB Bank but which is not available to the general public in order to engage
in any financial transaction or to further a private interest may be subject to prosecution. The
consequences of insider trading violations can be staggering for the individuals.

a) Detailed lia ility and repercussions will e as per Section 159, “Offences and Penalties”
of Securities Act 2015 and Guidelines on Prohibition of INSIDER TRADING of SECP.
b) However Senior Management or the Board will address violations to the Policy as
appropriate.
c) An act of Insider Trading will be considered as a breach of Code of Conduct Guidelines of
MCB Bank, hence will be subject to disciplinary action(s) as per Bank’s applica le
policies.

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Chapter 5 ROLE OF COMPLIANCE

Compliance & Controls Group (CCG) will perform the following duties:

1. Maintenance of data regarding shareholding of all employees, whereas for directors

same shall be maintained at the Company Secretary’s office. However the details of
shareholding will be shared with Company Secretary’s office and Financial Controls
Group for their necessary actions.

2. CCG will maintain follow-up with respective Groups to maintain and update list of
INSIDERS.

3. Maintain secrecy of all information received, except when disclosure is required by law
or permitted under the Bank’s policy.

4. Maintain records in accordance with the Bank’s Record Retention Policy.

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 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

ANNEXURE-I
LIST OF INSIDERS
(To be submitted by all Groups)

Dated ___________________

To
Compliance & Controls Group,
MCB Bank Limited,
10th Floor MCB Tower,
Karachi.

SUBJECT: List of INSIDERS* as Prescribed by SECP under Section 131 (2) of Securities Act 2015
as per guidelines under Insider Trading Manual.
As per the provisions of the aforementioned manual, and in accordance with the definition of
INSIDER as provided under relevant regulations, the required information is provided below:

Sr. No. Name of Insider(s)* Identification No. Designation or Relationship with Remarks
(CNIC / NTN etc.) MCB Bank

All information mentioned herein is provided to the best of our knowledge. We shall
continue reporting of above information as per the provisions of Insider Trading Manual and
inform CCG in case of any change in the details provided above.

Name of Group: _________________________________________________________

Signature: __________________ Signature: ____________________

Division Head Group Head

*List for Names of Directors, Company Secretary, CEO, CFO, Managing Agent, External Auditors
of MCB Bank and other related concerns as defined under definition of INSIDERS in the
Securities Act, 2015. shall be maintained at Company Secretary’s Office.

NOTE: Groups should report to CCG as and when there is any change in above data.

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MCB Bank Limited

ANNEXURE II

UNDERTAKING

Date______________

To
Compliance & Controls Group,
MCB Bank Limited,
10th Floor MCB Tower,
Karachi.

SUBJECT: UNDERTAKING* - FOR SHARES / SECURITIES OF MCB BANK LIMITED AND ITS
CLIENTS LISTED ON STOCK EXCHANGE(S)…UNDER POLICY ON PROHIBITION OF INSIDER
TRADING**.

I Hereby Confirm That,

1. I have not traded in the shares / securities of MCB Bank Limited (MCB) and companies
which are clients of MCB (collectively as company/ies), with whom the Bank has direct
customer - banker relationship on the basis of any Inside / Unpublished Price Sensitive
Information.

2. I have not disclosed any material non-public information related to MCB or any Other
Company including clients of MCB to any other person including an employee of the
Bank.

3. I shall not, at any time during one year from the last working day at MCB Bank Limited:

a. Either on my own behalf or on behalf of any other person, deal in securities of a

company listed on a stock exchange on the basis of any unpublished price
sensitive information.
b. Communicate any unpublished price sensitive information to any person, with
or without such person’s request for such information, except as required in the
ordinary course of business or under any law.
c. Counsel or procure any other person to deal in securities of any company on the
basis of unpublished price sensitive information.

4. I have read and understood the provisions of the policy document and applicable laws
referred to in the Policy on Prohibition of Insider Trading and undertake to comply with
the same. I further undertake that I shall comply with the above stated provisions at
least for one succeeding year from the last working day at MCB Bank Limited.

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 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

I will further ensure annual submission of this undertaking to you as instructed in the Policy on
Prohibition of Insider Trading latest by 31st January of the year following the period under
reporting (Preceding Year: January 1st to December 31st)

_____________________________
(Signature)
Name
Employee Number (as applicable)
Designation and Department and Group Place of Posting
CNIC Number
Contact Number (Office & Cell No) Email Address

* Such Undertakings for Directors and CEO shall be sent to the Company Secretary.
** Policy document is available on MCB Internal Portal
(http://home.mcb.com.pk/compliance/Policies)

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 COMPLIANCE & CONTROLS GROUP
MCB Bank Limited

ANNEXURE-III
SIX MONTHLYSHAREHOLDING DISCLOSURES

Dated: ____________________

To
Compliance & Controls Group,
MCB Bank Limited,
10th Floor MCB Tower,
Karachi.

SUBJECT: DECLARATION OF SIX MONTHLY SHAREHOLDING OF MCB BANK LIMITED BY

SELF, SPOUSE(S), DEPENDENT LINEAL ASCENDANTS AND DESCENDANTS - UNDER Insider
Trading Manual

I, ___________________________an Employee of MCB Bank Limited (MCB), held / hold shares of MCB,
including that of my close relatives i.e. spouse(s), dependent lineal ascendants and descendants,
during the under mentioned reporting period:

Please tick one:

January 1st till June 30th, year____________
July 0l't till Decembe31st", year__________

NUMBER OF
SHARES OF
NO OF SHARES SOLD MCB BANK
CDC (S)/PURCHASED (P)/ LTD. HELD AS OF
PERSONS IN WHOSE ACCOUNT OPENING BONUS (B) SHARES
RELATIONSHIP REPORTING CNIC NUMBER
NAME SHARES ARE NO. / FOLIO BALANCE EARNED DURING THE PERIOD 30TH
HELD NUMBER** PERIOD* JUNE / 31ST
DECEMBER
S =
P =
BS=

* Number of shares should state all shares sold, purchased, bonus shares earned during selected
reporting period
** Provision of Folio Number is mandatory

All information provided therein is correct to the best of my knowledge. I will ensure six
monthly submission of this declaration to Compliance & Controls Group as per the provisions
of the Insider Trading Manual.

___________________
(Signature)
Employee Name:
Employee Number:
Designation/Department/Group: Place of Posting:
Contact Number (Office & Cell No) Email Address:

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