Interim Order dated December 04, 2019 In the matter of Front Running: Various Funds of Fidelity Group

Under Sections 11 (1), 11 (4), 11B (1) and 11D of the Securities and Exchange Board of India Act, 1992 In Re: Securities and Exchange Board Of India (Prohibition of Fraudulent and Unfair Trade Practices Relating To Securities Market) Regulations, 2003 In respect of: S. No. Name of the Entity PAN 1 Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda) DFAPD6039C 2 Ms. Alka Dhadda BBIPD5396J 3 Ms. Arushi Dhadda DFAPD6005J

In the matter of Front Running: Various Funds of Fidelity Group

Background 1. Securities and Exchange Board of India’s (hereinafter referred to as “SEBI”) surveillance system had generated alerts for possible instances of front running by the entity Ms. Alka Dhadda (hereinafter referred to as “Alka”) during the period May – August, 2019. 2. Based on the aforesaid alert, SEBI conducted a preliminary examination for the period May 29, 2019 to August 23, 2019 (hereinafter referred to as “Examination Period”) to look into the possible violations of provisions of Securities and Exchange Board of India Act, 1992 (hereinafter referred to as “SEBI Act”) and various regulations framed thereunder including SEBI (Prohibition of Fraudulent and Unfair Trade Practices Relating to Securities Market) Regulations, 2003 (hereinafter referred to as “PFUTP Regulations”) by certain entities including Alka.

Interim Order in the matter of Front Running: Various Funds of Fidelity Group

SEBI’s Examination 3. SEBI’s preliminary examination brought out the following: 3.1. Alka had placed and executed orders before the orders of various entities of Fidelity Group, named in Table 1 (hereinafter referred to as “Big Client”) and subsequently squared off her positions when the orders of Fidelity Group entities were placed in the market. 3.2. Ms. Arushi Dhadda (hereinafter referred to as “Arushi”) had placed and executed orders before the orders of Fidelity Asian Values PLC and subsequently squared off her positions when the orders of Fidelity Asian Values PLC were placed in the market. 3.3. A total of 18 entities of Fidelity Group were identified which had common scrip days with Alka and Arushi. Out of these 18 entities, Alka and Arushi had front running instances with the following 11 entities of Fidelity Group / Big Clients who had transacted through various Trading Members: Table 1

Sl. Big Client Name Trading Member No. 1. Fidelity Funds - Emerging Markets HSBC Securities & Capital Markets (India) Pvt. Ltd. J .P. Morgan India Pvt. Ltd. 2. Fidelity Investment Services Ltd. A/C UBS Securities India Pvt. Ltd Fidelity 3. Fidelity Asian Values Plc Goldman Sachs (India) Securities Pvt. Ltd. 4. Fid Funds Mauritius Ltd. Macquarie Capital Securities (India) Pvt. Ltd. IIFL Securities Ltd. 5. Fidelity Funds Asia Pacific Dividend Fund ICICI Securities Ltd. 6. Fidelity Investment Services Ltd. Edelweiss Securities Ltd. 7. Fidelity Management & Research Company Citigroup Global Markets India Pvt. Ltd. 8. Fidelity Investment Trust Fidelity INT Small HSBC Securities & Capital Markets (India) Pvt. Ltd. Cap Opportunities Fund 9. Fidelity India Fund Jefferies India Private Ltd.

Sl. Big Client Name Trading Member No. 10. Fidelity Advisor Series I Fidelity Advisor Motilal Oswal Financial Services Ltd. Equity Growth Fund 11. Fidelity Funds - Emerging Markets Focus DSP Merrill Lynch Ltd. Fund 3.4. The trading pattern of Alka and Arushi suggests that they managed their trading pattern to take advantage of the impending trading activity of Fidelity Group entities by front running and thereby managed to generate profits for themselves by the price movement of scrips on account of the large buy / sell orders of Fidelity Group entities. 3.5. Mr. Avi Dhadda (hereinafter referred to as “Avi”), a relative of Alka and Arushi, was the trader for all of the 11 Fidelity Group entities mentioned in the aforesaid table and had provided trade instructions to the Trading Members for the said Fidelity Group entity. Consideration and Prima Facie Findings 4. I have perused the findings of the examination conducted by SEBI and other materials available on record. On a perusal of the same, the following issues arise for consideration: 4.1. Whether Avi was privy to the information with respect to the trading of 11 Fidelity Group entities? 4.2. Whether Mr. Avi Dhadda is related to Ms. Alka Dhadda and Ms. Arushi Dhadda? 4.3. Whether the trades executed from the trading accounts in the name of Alka and Arushi via internet based trading facility of Arihant Capital Markets had ‘front run’ the orders of the 11 Fidelity Group entities? 4.4. If the answer to the aforesaid question is in affirmative, who all are responsible for the front running activity and what are the relevant provisions of SEBI Rules and Regulations that have been violated by them? 4.5. What directions, if any, should be issued in the extant matter? 5. I now proceed to deal with the merits of case on a prima facie basis.

Issue No. 1 - Whether Avi was privy to the information with respect to the trading of 11 Fidelity Group entities? 6. I have taken note of the 11 Fidelity Group entities and their respective Trading Members as mentioned in the aforesaid Table 1. I note from the correspondence between National Stock Exchange of India Ltd. and the said 11 Trading Members that on the query raised by the Exchange as to the details of employees or officers who were aware / involved in placing of trades on behalf of the Fidelity Group entities, all the Trading Members (emails dated August 19, 2019, August 20, 2019, August 23, 2019, November 19, 2019, November 20, 2019 and November 21, 2019) have stated that Avi was the trader for all of 11 Fidelity Group entities and had provided trade instructions to the Trading Members. A sample query is reproduced herein below: Exchange: Details of Employees or Officers who were aware / involved in placing trades on behalf of the FIDELITY FUNDS – EMERGING MARKETS on below trade date in the given scrip. Trade_date Symbol June 19, 2019 GODREJCP

Trading Member – HSBC – We have been given to understand by the client, FIDELITY FUNDS – EMERGING MARKETS (AAACF3101C) that Avi Dhadda (Trader) and Nick Price (Fund Manager) were involved in placing trades with HSBC ON 19 June 2019 for Symbol – ‘GODREJCP’. 7. In light of the above discussion, it can be prima facie concluded that Avi was privy to the information when the 11 Fidelity Group entities would place the order for buy / sell in a particular scrip as he was the trader dealing with the respective Trading Member on behalf of the 11 Fidelity Group entities for the said trades. I further note that the decision of the Fidelity Group entities to acquire shares or sell its shares / information about its possible trades, is confidential information of the concerned entities. To put it differently, the said information is non-public information. Therefore, it is also prima facie further concluded that Avi was in possession of information of the impending trades of Fidelity Group entities which was not available in the public domain. Issue No. 2 - Whether Mr. Avi Dhadda is related to Ms. Alka Dhadda and Ms. Arushi Dhadda?

Mr. Avi Dhadda - Ms. Alka Dhadda 8. It is observed from the KYC details of Alka that her email id is avidhadda92@gmail.com, which is matching with the name of the trader of Fidelity Group i.e. Mr. Avi Dhadda. Further, her husband’s name is Mr. Virender Dhadda and her address is of Jaipur. It is also observed from the details of the PAN of Mr. Avi Dhadda (DFAPD6039C) as available on the Income Tax Department’s website that the said PAN is registered in the name of Mr. Vaibhav Dhadda and the jurisdiction details of the said PAN is of Jaipur. The passport details of Mr. Vaibhav Dhadda reveals that his parents are Mr. Virender Dhadda and Ms. Alka Dhadda. Additionally, the matrimonial website (www.jainshubhbandhan.com) profile mentions Mr. Vaibhav Dhadda as son of Mr. Virender Dhadda and Ms. Alka Dhadda. 9. In view of the above discussion, it is prima facie established that Mr. Avi Dhadda is also known as Mr. Vaibhav Dhadda and is the son of Ms. Alka Dhadda. It is also noted from the material available on record that both Mr. Avi Dhadda and Ms. Alka Dhadda have Hong Kong Permanent Identity Cards.

Mr. Avi Dhadda - Ms. Arushi Dhadda 10. It is observed from the nomination details filed in the account opening form of Ms. Arushi Dhadda with ICICI Bank Ltd. that Ms. Alka Dhadda has been mentioned as ‘mother’ of Ms. Arushi Dhadda. Further, from her PAN details, it is observed that Mr. Virender Dhadda is her ‘father’. Thus, Ms. Arushi Dhadda is the daughter of Ms. Alka Dhadda and Mr. Virender Dhadda. Hence, Ms. Arushi Dhadda is the sister of Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda).

Issue No. 3 - Whether the trades executed from the trading accounts in the name of Alka and Arushi via internet based trading facility of Arihant Capital Markets had ‘front run’ the orders of the 11 Fidelity Group entities? 11. Before proceeding further, I would like to refer to the definition of ‘front running’. Hon’ble Supreme Court of India (hereinafter referred to as “SC”) while adjudicating the appeal in the matter of SEBI vs. Shri Kanaiyalal Baldevbhai Patel and Ors. dated September 20, 2017, 2012, referred to the same and observed as follows: “As per the Major Law Lexicon by P Ramanatha Aiyar (4th Edition 2010), ‘front running’ is defined as under: Front running - Buying or selling securities ahead of a large order so as to benefit from the subsequent price move. This denotes persons dealing in the market, knowing that a large transaction will take place in the near future and that parties are likely to move in their favour. The illegal private trading by a broker or market-maker who has prior knowledge of a forthcoming large movement in prices. (Investment) The Black’s Law Dictionary (Ninth Edition) defines the term ‘front running’ as under: Front running, n. Securities.

A broker’s or analyst’s use of nonpublic information to acquire securities or enter into options or futures contracts for his or her own benefit, knowing that when the information becomes public, the price of the securities will change in a predictable manner. This practice is illegal. Front-running can occur in many ways. For example, a broker or analyst who works for a brokerage firm may buy shares in a company that the firm is about to recommend as a strong buy or in which the firm is planning to buy a large block of shares. Nancy Folbre – In the world of financial trading, a front-runner is someone who gains an unfair advantage with inside information. SEBI has defined front-running in one of its circular (CIR/EFD/1/2012 dated May 25, 2012) in the following manner- Front-running; for the purpose of this circular, front running means usage of non-public information to directly or indirectly, buy or sell securities or enter into options or futures contracts, in advance of a substantial order, on an impending transaction, in the same or related securities or futures or options contracts, in anticipation that when the information becomes public; the price of such securities or contracts may change.” 12. I now proceed to examine the trades executed in the trading accounts of Alka and Arushi maintained with Arihant Capital Markets Ltd. in the above perspective.

Alka 13. During the examination period, the trades executed from the trading account of Alka was analysed and it was observed that out of 108 common scrip trading days, in 68 instances, it was observed that when a bulk buy order was about to come from one of the 11 Fidelity Group entities, buy trades were executed from the trading account of Alka, just prior to the buy order of Fidelity Group entity and when a bulk sell order was about to come from one of the 11 Fidelity Group entities, sell trades were executed from the trading account of Alka, just prior to the sell order of Fidelity Group entity. 14. The gist of the said 68 instances (42 buy instances and 26 sell instances) of the aforesaid trading pattern is given below: Table 2 Trade Symbol Big Front Front Big Big date Client Runner Runner order order activity buy qty sell qty buy qty sell qty 29-May-19 GUJGASLTD Buy 57192 57192 243494 0 30-May-19 POWERGRID Buy 90000 90000 160660 0 30-May-19 REDINGTON Buy 26365 26365 49472 0 31-May-19 CONCOR Buy 20000 20000 47808 0 31-May-19 INTELLECT Buy 1000 1000 9940 0 31-May-19 REDINGTON Buy 75022 75022 125305 0 03-Jun-19 CONCOR Buy 30000 30000 49472 0 04-Jun-19 CONCOR Buy 7253 7253 92487 0 04-Jun-19 INFY Buy 60000 60000 467313 0 06-Jun-19 AXISBANK Buy 150000 150000 500000 26300 06-Jun-19 CONCOR Buy 47858 47858 119058 0 10-Jun-19 CONCOR Buy 20000 20000 33363 0

Trade Symbol Big Front Front Big Big date Client Runner Runner order order activity buy qty sell qty buy qty sell qty 11-Jun-19 CONCOR Buy 3514 3514 95779 0 12-Jun-19 HGS Buy 1000 1000 1875 0 13-Jun-19 SRTRANSFIN Buy 110000 110000 160674 0 18-Jun-19 GODREJCP Buy 421376 421376 618828 0 19-Jun-19 GODREJCP Buy 68506 68506 187745 0 24-Jun-19 SRTRANSFIN Buy 148614 148614 84366 0 25-Jun-19 SRTRANSFIN Buy 144867 144867 214201 0 26-Jun-19 GODREJCP Buy 30833 30833 324360 0 28-Jun-19 JBCHEPHARM Buy 5360 5360 21974 0 01-Jul-19 CONCOR Buy 45555 45555 157679 0 02-Jul-19 EMBASSY Buy 80000 80000 187200 0 03-Jul-19 INFY Buy 313156 313156 600432 0 08-Jul-19 ICICIGI Buy 17611 17611 31818 0 10-Jul-19 POWERGRID Buy 319209 319209 96489 0 11-Jul-19 SRTRANSFIN Buy 90001 90001 140819 0 15-Jul-19 CONCOR Buy 10000 10000 91117 0 17-Jul-19 GODREJCP Buy 130256 130256 443342 0 18-Jul-19 SHEMAROO Buy 56690 56690 9451 0 19-Jul-19 BIOCON Buy 100000 100000 824982 0 22-Jul-19 SHEMAROO Buy 15991 15991 17184 0 24-Jul-19 HINDOILEXP Buy 10000 10000 23202 0 25-Jul-19 SHEMAROO Buy 2000 2000 4351 0 26-Jul-19 ICICIGI Buy 3493 3493 8958 0 29-Jul-19 ICICIGI Buy 15575 15575 29104 0 29-Jul-19 GUJGASLTD Buy 14626 14626 103685 0 31-Jul-19 GUJGASLTD Buy 40000 40000 83832 0 01-Aug-19 INFY Buy 110000 110000 50000 0 05-Aug-19 ICICIGI Buy 20000 20000 102955 0 05-Aug-19 PNBHOUSING Buy 15776 15776 79730 0 07-Aug-19 ICICIGI Buy 14418 14418 170591 0 Table 3 Trade date Symbol Big Front Front Big Big Client Runner Runner order order activity buy qty sell qty buy qty sell qty 04-Jun-19 ESSELPACK Sell 45285 45285 0 122235

06-Jun-19 CASTROLIND Sell 75000 75000 0 364053 07-Jun-19 CASTROLIND Sell 100174 100174 0 514725 10-Jun-19 ICICIGI Sell 51184 51184 0 68206 10-Jun-19 ICICIPRULI Sell 168853 168853 0 417959 11-Jun-19 ICICIGI Sell 59317 59317 0 91308 11-Jun-19 ICICIPRULI Sell 77189 77189 0 158067 13-Jun-19 GSPL Sell 165431 165431 0 120297 13-Jun-19 HDFC Sell 21739 21739 0 328384 13-Jun-19 HDFCBANK Sell 6012 6012 0 132284 14-Jun-19 GSPL Sell 69351 69351 0 141234 14-Jun-19 LTI Sell 30000 30000 0 31387 17-Jun-19 GSPL Sell 68307 68307 0 327192 17-Jun-19 LTI Sell 22659 22659 0 4978 24-Jun-19 HDFC Sell 10000 10000 0 15541 01-Jul-19 CASTROLIND Sell 257473 257473 0 368684 02-Jul-19 LTI Sell 14428 14428 0 49545 04-Jul-19 LTI Sell 42038 42038 0 84366 11-Jul-19 INFY Sell 114772 114772 0 300000 15-Jul-19 TATACOMM Sell 37770 37770 0 58700 17-Jul-19 GODREJCP Sell 130256 130256 0 150000 01-Aug-19 CONCOR Sell 70000 70000 0 254411 05-Aug-19 CONCOR Sell 20000 20000 0 114982 05-Aug-19 HDFC Sell 40000 40000 0 123617 06-Aug-19 LICHSGFIN Sell 90000 90000 0 16000 07-Aug-19 CONCOR Sell 18735 18735 0 2190 23-Aug-19 FRETAIL Sell 15000 15000 0 449733 15. A few illustrations are given below to explain the trading pattern of the trades executed from the trading account of Alka around the trading activity of the 11 Fidelity Group entities while the details of all the 68 instances are placed at Annexure- 1: 15.1.

Scrip of Shriram Transport Finance Company Ltd. (SRTRANSFIN): On June 13, 2019, buy orders were placed from the trading account of Alka for 1,10,000 shares between 12:54:40 pm and 2:22:46 pm. The buy start price was ` 1,045 and end buy price was ` 1,085 (i.e. at an average price of ` 1068.81). The buy order for 1,60,674 shares was placed by the Fidelity Asian Values Plc. between 1:12:26 pm and 3:00:33 pm. The buy start price was ` 1,059.20 and end buy price was ` 1,080 (i.e. at an average price of ` 1081.40). As soon as Fidelity Asian Values Plc. started buying, Sell orders were put for 1,10,000 shares between 1:13:12 pm and 2:26:01 pm from the trading account of Alka. The sell start price was ` 1,065 and sell end price was ` 1,095 (i.e. at an average of ` 1081.36). The entire trade had a positive square off difference of ` 13,80,534. Thus, from the above, it can be seen that the buy orders from the trading account of Alka started before the impending buy order of the Fidelity Group entity. Further, as and when the buy order of Fidelity Group entity is placed in the system, because of the sudden surge in demand for a considerable quantity, there is an upward movement in the price of the scrip and correspondingly, sell trades are getting executed from the trading account of Alka.

15.2. Scrip of Tata Communications Ltd. (TATACOMM): On July 15, 2019, sell orders were placed from the trading account of Alka for 37,700 shares between 9:42:46 am and 2:08:49 pm. The sell start price was ` 495.85 and sell end price was ` 492 (i.e. at an average of ` 493.77). The sell order for 58,700 shares was placed by Fidelity Asian Values Plc. between 2:12:01 pm and 2:12:23 pm. The sell start price was ` 492.40 and sell end price was ` 490 (i.e. at an average of ` 490.06). As soon as Fidelity Asian Values Plc. started selling, Buy orders were put for 37,700 shares between 2:12:17 pm and 2:12:23 pm from the trading account of Alka. The price at which the buy trades were executed was ` 490. The entire trade had a positive square off difference of ` 1,42,449. Thus, from the above, it can be seen that the sell orders from the trading account of Alka started before the impending sell order of the Fidelity Group entity. Further, as and when the sell order of Fidelity Group entity is placed in the system, there is a downward movement in the price of the scrip because of the sudden surge in the number of shares available for sale vis-à-vis demand for the same and correspondingly, buy trades are getting executed from the trading account of Alka.

16. In view of the aforesaid discussion, a prima facie trading pattern is established during the examination period based on the trades executed from the trading account of Alka, wherein the buy / sell trades are executed depending on the impending buy / sell orders of the Fidelity Group entities. Arushi 17. During the examination period, the trades executed from the trading account of Arushi were analysed and it was observed that on 6 instances trades were executed from the trading account of Arushi and during the said 6 instances, Fidelity Group entity had also executed trades in the market. Out of aforesaid 6 instances, on 3 instances when a buy order was about to come from one of the Fidelity Group entities, namely Fidelity Asian Values Plc, buy trades were executed from the trading account of Arushi, just prior to the buy order of Fidelity Asian Values Plc. 18. The gist of the said 3 buy instances of the aforesaid trading pattern is given below: Table 4 Trade date Symbol Big Front Front Big Big client Runner Runner order order activity buy qty sell qty buy qty sell qty 29-May-19 GICHSGFIN Buy 3,000 3,000 11,912 0 29-May-19 GUJGASLTD Buy 3,000 3,000 2,43,494 0 31-May-19 INTELLECT Buy 5,108 5,108 9,940 0 19. One illustration is given below to explain the trading pattern of the trades executed from the trading account of Arushi around the trading activity of Fidelity Asian Values Plc. while the details of all the 3 instances are placed at Annexure- 2: 19.1.

Scrip of Gujrat Gas Ltd. (GUJGASLTD): On May 29, 2019, buy order was placed from the trading account of Arushi for 3,000 shares at 11:53:39 am. The buy price was ` 183.95. The buy order for 2,43,494 shares was placed by the Fidelity Asian Values Plc. between 12:04:38 pm and 12:08:02 pm. The buy start price was ` 180 and end buy price was ` 186 (i.e. at an average price of ` 183). As soon as Fidelity Asian Values Plc. started buying, sell order was put for 3,000 shares at 12:08:01 from the trading account of Arushi. The sell price was ` 186. The entire trade had a positive square off difference of ` 6,143. Thus, from the above, it can be seen that the buy order from the trading account of Arushi was placed before the impending buy order of Fidelity Asian Values Plc. Further, as and when the buy order of Fidelity Asian Values Plc. is placed in the system, because of the sudden surge in demand for a considerable quantity, there is an upward movement in the price of the scrip and correspondingly, sell trade was executed from the trading account of Arushi. 20. In view of the aforesaid discussion, a prima facie trading pattern is established during the examination period based on the trades executed from the trading account of Arushi, wherein the buy trades are executed depending on the impending buy orders of Fidelity Asian Values Plc.

21. The above trading pattern shows that the tranches of the order of the first leg of Alka and Arushi have been placed on or before the time of last tranche of the order placed by Fidelity Group entity. 22. The next issue that arises for determination is whether the aforesaid trading patterns of Alka and Arushi can be classified as front running? I note from the definitions of front running quoted in preceding paragraphs that it is a conduct of using non-public information to directly or indirectly, buy or sell securities, in advance of a substantial order, on an impending transaction, in the same or related securities. Thus, the essential ingredients to establish front running are as follows: 22.1. The information regarding a substantial impending transaction in a particular security, is not publically available; 22.2. The order in securities was placed (directly or indirectly) by the front runner during the entire period of placement of impending substantial order of the Big Client and not just before the placement of substantial order, while in possession of the aforesaid non-public information.

Since orders above the minimum lot size (particularly for large orders) are often placed in smaller tranches so as to have minimum impact on the price, the front runner can gain from placing his order(s) at any time before the last tranche of the Big Client’s order. In other words, all the tranches of the order of the first leg of the front runner that have been placed on or before the time of last tranche order placed by Big Client(s), would qualify as front running transactions. Conversely any tranche of the first leg of the order put by the front runner subsequent to the last trench of the order of the Big Client will be excluded from being qualified as front running trade, though the earlier tranches of the front runner will still qualify as front running trades. 23. I prima facie note from the material available on record that the information of impending trades of the Fidelity Group entities was known to only few employees of the Fidelity Group and the respective Trading Members. It has already been prima facie held in the preceding paragraphs that information regarding possible trades of the Fidelity Group entities is confidential in nature and as such the said information cannot be said to be in the public domain.

Thus, it can be prima facie held that Avi being the trader on behalf of the Fidelity Group was in possession of non-public information of the impending trades of the Fidelity Group entities. 24. For the second ingredient, as noted in the preceding paragraphs, the placement of first leg of orders of Alka and Arushi in relation to the orders of the Fidelity group, prima facie, establishes that the trades of Alka and Arushi is in the nature of front running trades. 25. Further the following circumstantial evidence corroborates the fact that Alka and Arushi has opened the bank and trading accounts for the purpose of, prima facie, front running trades as held above: 25.1. Opening of Trading Account – It is noted from the material available on record that the trading account in question in the name of Alka was opened with Arihant Capital Markets Ltd. on May 23, 2019, which is close to the period when the trades as mentioned in Tables 2 and 3 were executed. Similarly, it is noted from the material available on record that the trading account in question in the name of Arushi was opened with Arihant Capital Markets Ltd. on May 23, 2019 which is close to the period when the trades as mentioned in Table 4 were executed.

The e-mail id given by Alka and Arushi is mentioned as avidhadda92@gmail.com indicating that the communication of trades in that account would go to Avi. 25.2. Opening of Bank Account and Fund Transfers – It is noted from the material available on record that the ICICI Bank account (678201502110) in the name of Alka, linked to the aforesaid trading account was opened on May 23, 2019 which is close to the period when the trades as mentioned in Tables 2 and 3 were executed. Further, Alka already has an account with ICICI Bank (678201005024). Moreover, the nominee registered with this account is Mr. Vaibhav Dhadda (alias Avi). Alka had received funds of ` 49,000 from Mr. Vaibhav Dhadda (alias Avi) as per narration of entry in bank statement on May 23, 2019 which is the same day when the bank account was opened. Similarly, it is noted from the material available on record that the ICICI Bank account (678201502111) in the name of Arushi, linked to the aforesaid trading account was opened on May 23, 2019 which is close to the period when the trades as mentioned in Table 4 were executed. It also coincides with the date of opening of ICICI Bank account (678201502110) which is in the name of Alka.

It is noted that Arushi is shown as “student” in the KYC of the trading account. Arushi had received funds of ` 2,00,000 from Alka as per narration of entry in bank statement on May 23, 2019 which is the same day when the bank account was opened. From the KYC of bank account of ICICI Bank Ltd., it is noted that the gross income of Alka is nil. Moreover, it is noted from the ICICI Bank account (678201502111) statement of Arushi that a sum of ` 15,00,000/- was credited in the said account on August 17, 2019 by Alka during the period of prima facie, front running trades. 25.3. Placement of Orders – It is observed from the material available on record that the trades from the trading account of Alka maintained with Arihant Capital Markets Ltd. were executed using internet based trading facility of the Trading Member. An analysis of the IP addresses used for accessing such internet facility from Arihant Capital Markets Ltd. was done. The location was traced using IP addresses given in connection log submitted by the Trading Member. As per the said analysis, it was observed that there are 51 unique IP addresses starting with 182, 157, 61 and 118. The IP starting with 182, 61 and 118 are located in Hong Kong and IP starting with 157 is from Jaipur.

The trades as mentioned in Tables 2 and 3 were executed from the IP addresses starting with 182, 61 and 118. It is noted from records that Avi who has a Honk Kong Permanent Identity Card is an employee of Fidelity Group and he works from Hong Kong. Similarly, it is observed from the material available on record that the trades from the trading account of Arushi maintained with Arihant Capital Markets Ltd. were executed using internet based trading facility of the Trading Member. An analysis of the IP addresses used for accessing such internet facility from Arihant Capital Markets Ltd. was done. The location was traced using IP addresses given in connection log submitted by the Trading Member. As per the said analysis, it was observed that there are 10 unique IP addresses starting with 182, 157 and 61. The IP starting with 182 and 61 are located in Hong Kong and IP starting with 157 is from Jaipur. The trades as mentioned in Table 4 were executed from the IP address starting with 182 and as stated above, Avi works from Hong Kong. 25.4. Particulars of the Trading – The particulars of the trading, as shown in the illustration in preceding paragraphs shows that if the Fidelity Group entity is about to place a buy order, then buy orders are placed from the trading account in the name of Alka just prior to it and if the Fidelity Group entity is about to place a sell order then sell orders are placed from the trading account in the name of Alka just prior to the order of Fidelity Group entity.

Similarly, buy orders were placed from the trading account of Arushi prior to the impending substantial buy order of the Fidelity Group entity. Moreover, the instances of trades from the trading account in the name of Alka are 68 in number within a short period of time (approximately 3 months) and are not isolated instances i.e., transactions are repeated in nature on different dates. In the same vein, it is noted that 6 trades were executed from the trading account of Arushi, out of which 3 trades had the aforesaid pattern. Thus, 50% of the trades from the Arushi’s trading account had a common pattern. 25.5. Trading History of Alka and Arushi – It is noted from the trading history of Alka and Arushi that trades from their account were executed in the securities market from May 29, 2019 onwards. Further, prior to May 29, 2019, none of the entities have any instances of trading in any other security/contract through any trading account. 26. The cumulative effect of the aforesaid factors coupled with the mother – son relationship between Alka and Avi and brother – sister relationship between Avi and Arushi, based on a preponderance of probabilities, prima facie leads to a conclusion that the trades executed from the trading accounts in the name of Alka and Arushi would not have been entered into, had Avi / Alka / Arushi not been in possession of the non-public information of the impending trades of the Fidelity Group entities.

The front running activity of Alka / Avi / Arushi has resulted in the encashment of benefit to the tune of ` 1,85,75,843 in the trading account of Alka and ` 28,500 in the trading account of Arushi. 27. In light of the aforesaid discussion, it can be prima facie held that the trades executed from the trading accounts in the name of Alka and Arushi via internet based trading facility of Arihant Capital Markets Ltd. had ‘front run’ the orders of 11 Fidelity Group entities. Issue No. 4 - If the answer to the aforesaid question is in affirmative, who all are responsible for the front running activity and what are the relevant provisions of SEBI Rules and Regulations that have been violated by them? 28. The following has already been prima facie noted in the preceding paragraph: 28.1. Mr. Avi Dhadda is the son of Ms. Alka Dhadda and brother of Ms. Arushi Dhadda. 28.2. ICICI Bank Ltd. bank accounts were opened in the name of Alka and Aarushi on the same day immediately before the trading began from the trading accounts maintained with Arihant Capital Markets Ltd. 28.3. Alka had received money from Avi in the banking account linked with the trading account maintained with Arihant Capital Markets Ltd. Further, it is noted that Arushi had received ` 2 lakh in her banking account on the day it was opened from Alka and in Alka’s bank KYC, under the heading “Gross Annual Income”, it is shown as “nil”.

Moreover, Alka had transferred ` 15,00,000/- to Arushi on August 17, 2019. 28.4. Trading accounts in the name of Alka and Arushi were also opened around the same time, May 23, 2019. Further, trading in both these accounts started on May 29, 2019 i.e. at the same time when front running instances were observed. 28.5. No trades were executed ever by Alka and Arushi in any security from any other trading account except the ones with Arihant Capital Markets Ltd. 28.6. The front running trades were executed based on internet based trading facility and the same were executed from Hong, Kong. It is noted from the particulars of Alka’s passport that she has visited Hong Kong between May 28, 2019 to August 8, 2019. It is noted from the trade details executed from the trading account of Alka that trades were executed subsequent to her arrival in India from Hong Kong. 28.7. Majority of trades that were executed from the trading accounts of Alka and Arushi were in the scrips in which Fidelity Group entities were investing and Avi was the trader. 28.8. Avi works from Hong Kong in the capacity of a professional trader and has a Hong Kong Permanent Identity Card.

29. From the above, especially the fact that Alka and Arushi who have no prior experience of trading deciding to open the accounts prior to the prima facie front running trades, on the same date in the same Bank, while Arushi being a student without any evidence of source of income and the fact that some of the trades happened in their accounts from Hong Kong where Avi who is a professional trader is located while Alka and Arushi were in India, prima facie shows that Avi had access to the trading accounts of Alka and Arushi. It is further prima facie held that he has front run various entities of Fidelity Group by placing orders through the trading accounts of Alka and Arushi. Thus, prima facie he is liable for the front running trades executed from the trading accounts in the name of Alka and Arushi maintained with Arihant Capital Markets Ltd.

30. I further note from the following factors that both Alka and Arushi were also part of the scheme / device of Avi to front run the trades of the Big Clients: 30.1. KYC documents of bank account opening form and trading account shows that prima facie they have been signed by Alka and Arushi. The very fact that both were over 18 years of age and prima facie signed the aforesaid documents shows that they were aware of their actions. 30.2. Alka and Arushi who have never traded before May 29, 2019 and had no investment experience, opened trading accounts and had given the email id of Avi. Further, their trades were mostly concentrated in the scrips in which the Big Clients were trading. The same indicates that they were aware that trades will be executed from their trading accounts as per the scheme / device of Avi who was the trader for the Big Clients. 30.3. Alka’s gross annual income is nil and inspite of having one ICICI Bank Account, she opened another ICICI Bank account which was linked to her trading account. On the account opening day she had received ` 49,000 from Avi. The same indicates her complicity in the entire scheme / device of Avi.

Similarly, Arushi who is a student, had received a substantial amount in her bank account which is linked to her trading account from Alka, whose gross annual income is zero, on the bank account opening day. Further she had received ` 15,00,000/- from Alka during the examination period. 31. In view of the aforesaid, it can be prima facie held that Alka and Arushi by opening trading accounts and bank accounts and by giving access to Avi of their trading accounts, have played an active part / participated in the scheme / device to front run the trades of the Big Clients. Thus, prima facie Alka and Arushi are also liable for the front running trades executed from their trading accounts. 32. The next issue that arises for determination is whether the prima facie conduct of Avi, Alka and Arushi of front running the orders of Fidelity Group entities have resulted in prima facie violations of any provisions of securities laws. In this regard, I would like to reproduce the text of regulation 4 (2) (q) of PFUTP Regulations. The same reads as follows: “4 (2) Dealing in securities shall be deemed to be manipulative, fraudulent or an unfair trade practice if it involves any of the following:— … (q) any order in securities placed by a person, while directly or indirectly in possession of information that is not publically available, regarding a substantial impending transaction in that securities, its underlying securities or its derivative; “ 33. In the instant matter, it has already been prima facie held that the trades mentioned in the Tables 2, 3 and 4 were executed when Avi was in possession of the non-public information with respect to the substantial impending transaction of various Fidelity Group entities.

Further, the role of Alka and Arushi in the aforesaid scheme has been brought out in the preceding paragraphs. Hence, their conducts are prima facie fraudulent in nature. 34. I, further note that the conducts of Avi, Alka and Arushi have prima facie defrauded the market as general investors have suffered because of their prima facie front running activity. For instance, as shown in the illustration in the preceding paragraphs, when the front runner started buying, the price was ` 1,045. In view of the trades of the Front Runner, the price of scrip have reached ` 1,059.20 when the Big Client started buying. But for the trades of the front runner, the Big Client would have purchased in tranches at lesser price. In view of this when the general investors placed their buy orders, they have to place their buy orders at higher price which but for the price increase contributed by the front runner would have been at lesser price. Similar is for the sell trades of Big Client. If the front runner would not have sold considerable shares before the Big Client started selling, the Last Traded Price would have been set at a higher price.

Thus, the general investors (sellers) would not have got a depressed price for their sell trades. Moreover, by front running trades, they have prima facie sent misleading and distorted price and volume signals to the market participants. 35. In view of the aforesaid, it can be prima facie held that Avi, Alka and Arushi have violated regulations 3 (a), 3 (b), 3 (c), 3(d), 4(1) and 4(2)(q) of PFUTP Regulations. The text of the said regulations, except 4(2)(q), is reproduced below: 3. Prohibition of certain dealings in securities No person shall directly or indirectly— (a) buy, sell or otherwise deal in securities in a fraudulent manner; (b) use or employ, in connection with issue, purchase or sale of any security listed or proposed to be listed in a recognized stock exchange, any manipulative or deceptive device or contrivance in contravention of the provisions of the Act or the rules or the regulations made there under; (c) employ any device, scheme or artifice to defraud in connection with dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange; (d) engage in any act, practice, course of business which operates or would operate as fraud or deceit upon any person in connection with any dealing in or issue of securities which are listed or proposed to be listed on a recognized stock exchange in contravention of the provisions of the Act or the rules and the regulations made there under.

4. Prohibition of manipulative, fraudulent and unfair trade practices (1)Without prejudice to the provisions of regulation 3, no person shall indulge in a manipulative, fraudulent or an unfair trade practice in securities markets. Issue No. 5 - What directions, if any, should be issued in the extant matter? 36. As a regulator of the capital markets, SEBI has the duty to safeguard the interests of investors and protect the integrity of the securities market. Since the conduct of Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda as mentioned above does not prima facie appear to be in the interest of investors and the securities market, necessary action has to be taken against them immediately, else it may lead to loss of investors’ trust in the securities market. Considering the facts and circumstances of this case and such a fraudulent conduct as prima facie found in this case, I am convinced that this is a fit case where, pending detailed examination, effective and expeditious preventive and remedial action is required to be taken by way of ad interim ex –parte order to protect the interests of investors and preserve the safety and integrity of the securities market.

Such action needs to be taken to prevent any further harm to investors. 37. I note that for the reasons recorded herein below, immediate action is called for against Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda) (PAN: DFAPD6039C), Ms. Alka Dhadda (PAN: BBIPD5396J) and Ms. Arushi Dhadda (PAN: DFAPD6005J): 37.1. The directions are preventive in nature as Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda) continues to be employed with the Fidelity Group and has access to non-public information. Considering his prima facie actions in the extant matter, there is a high probability that he might misutilise the confidential information pertaining to the trades of the Fidelity Group. Thus, there is an imminent threat of front running activity. The same will result in distortion of price and volume in the scrip resulting in loss to the general investors. In other words, considering the investment by Fidelity Group entities is ongoing, the probability of Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda) causing future harm is high. So urgent preventive steps are required to be taken. 37.2. The balance of convenience is to impose suitable directions against Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda so as to maintain a level playing field in the market for the general investors.

37.3. Further, one of the directions that can be passed against Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda, subject to the adjudication of the allegation on the merits in the final order, under Sections 11 (1), 11 (4) and 11B of SEBI Act is that of direction to disgorge the wrongful gains of ` 1,86,04,343 as discussed in preceding paragraphs. With the initiation of quasi-judicial proceedings, it is possible that Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda may divert the wrongful gains made from the front running trades. The same may result in making the final order in the matter becoming infructous. Non-interference by the Regulator at this stage would therefore result in irreparable injury to interests of the securities market and the investors. It therefore becomes necessary for SEBI to take urgent steps of stopping the debits from all the bank accounts of all the aforesaid named entities. Order 38. In view of the aforesaid discussions, I am of the view that for the reasons recorded herein below, immediate action is called for against Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda) (PAN: DFAPD6039C), Ms. Alka Dhadda (PAN: BBIPD5396J) and Ms. Arushi Dhadda (PAN: DFAPD6005J).

39. In view of the foregoing, pending conclusion of enquiry, in order to protect the interests of the investors and the integrity of securities market, I, in exercise of the powers conferred upon me under Sections 11 (1), 11 (4), 11B (1) and 11D read with Section 19 of the SEBI Act, direct Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda) (PAN: DFAPD6039C), Ms. Alka Dhadda (PAN: BBIPD5396J) and Ms. Arushi Dhadda (PAN: DFAPD6005J) as under : 39.1. Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda are restrained from buying, selling or dealing in the securities market or associating themselves with securities market, either directly or indirectly, in any manner whatsoever till further directions. 39.2. Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda shall cease and desist from undertaking any activity in the securities market, directly or indirectly, in any manner whatsoever till further directions. 39.3. Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda are directed to provide a full inventory of all assets held in their name, jointly or severally, whether movable or immovable, or any interest or investment or charge on any of such assets, including details of all bank accounts, demat accounts and mutual fund investments, immediately but not later than 5 working days from the date of receipt of this order.

39.4. Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda are directed not to dispose of or alienate any assets, whether movable or immovable, or any interest or investment or charge on any of such assets, held in their name, jointly or severally, including money lying in bank accounts except with the prior permission of SEBI. 39.5. Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda are directed to open an escrow account with a nationalised bank, jointly and severally and deposit the amount of ` 1,86,04,343 which has been prima facie found to be unlawful gain in this Order, within 15 days from the date of service of this order. The escrow account/s shall shall be an interest bearing escrow account and shall create a lien in favour of SEBI. Further, the monies kept therein shall not be released without permission from SEBI. 39.6. The banks including ICICI Bank Ltd. where Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda are holding bank accounts, jointly or severally, are directed to ensure that till further directions, except for compliance of direction at paragraph 39.5, no debits are made in the said bank accounts without the permission of SEBI.

The banks are directed to ensure that all the above directions are strictly enforced. On production of proof by any of the persons, mentioned above, that the said money is deposited in the escrow account, SEBI shall communicate to the banks to defreeze the accounts. 39.7. The Depositories are directed to ensure that till further directions, except for compliance of direction at paragraph 39.5, no debits are made in the demat accounts, of Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda held jointly or solely. 39.8. The Registrar and Transfer Agents are also directed to ensure that till further directions, except for compliance of direction at at paragraph 39.5, the securities / units held in the name of Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka

Dhadda and Ms. Arushi Dhadda, jointly or severally, are not transferred / redeemed. 40. This Order is without prejudice to the right of SEBI to take any other action that may be initiated against Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda in accordance with law. 41. The prima facie observations contained in this Order are made on the basis of the material available on record. In this context, Mr. Vaibhav Dhadda (alias Mr. Avi Dhadda), Ms. Alka Dhadda and Ms. Arushi Dhadda, may within 21 days from the date of receipt of this Order, file their reply, if any, to this Order and may also indicate whether they desire to avail an opportunity of personal hearing on a date and time to be fixed on a specific request to be made in that regard. 42. The above directions shall take effect immediately and shall be in force until further orders. 43. A copy of this order which render findings on prima facie evidence, shall be served upon all recognised Stock Exchanges, Depositories, Registrar and Share Transfer Agents to ensure compliance with the above directions and shall be sent to Securities and Futures Commission, Hong Kong and Fidelity Group for information.

Enclosures: Annexure 1: Trade details of Alka Dhadda Annexure 2: Trade details of Arushi Dhadda

DATE: December 4, 2019 MADHABI PURI BUCH PLACE: MUMBAI WHOLE TIME MEMBER SECURITIES AND EXCHANGE BOARD OF INDIA

Front running instances of Alka Dhadda (Annexure 1) Trade date Symbol Series Big client Big Client Pan Big client Big client Big client Big order Big order Big order Big order FR buy FR sell FR Buy Order FR client buy FR client buy FR buy FR buy FR Sell Order FR client sell FR client sell FR sell FR sell Squared off activity order start buy/ sell buy/ sell end buy qty sell qty buy/sell buy/sell qty qty Start time start time end time start end Start Time start time end time start end Difference time start time time start price end price price price price price 29-May-19 GUJGASLTD EQ Buy AAACF6980H 12:04:38 PM 12:04:38 PM 12:08:02 PM 243494 0 180 186 57192 57192 9:27:57 AM 9:27:57 AM 11:44:58 AM 176.8 185 9:50:01 AM 9:50:01 AM 12:08:01 PM 190.8 186 ₹ 2,80,231 30-May-19 POWERGRID EQ Buy AAACF4908M 3:27:01 PM 3:27:02 PM 3:27:02 PM 160660 0 191 191 90000 90000 1:03:09 PM 1:03:09 PM 1:38:25 PM 189.35 189.05 1:42:17 PM 1:42:48 PM 1:42:49 PM 189.9 189.9 ₹ 44,052 30-May-19 REDINGTON EQ Buy AAACF6980H 1:44:19 PM 1:44:19 PM 3:16:24 PM 49472 0 98.55 98 26365 26365 9:24:13 AM 9:24:13 AM 12:13:42 PM 96.1 99.1 1:44:10 PM 1:44:31 PM 1:44:31 PM 99.9 99.9 ₹ 48,982 31-May-19 CONCOR EQ Buy AAACF8751A 10:44:05 AM 10:44:05 AM 10:44:05 AM 47808 0 530.5 532 20000 20000 10:23:17 AM 10:23:17 AM 10:23:32 AM 529.8 532.95 10:29:14 AM 10:30:00 AM 10:34:42 AM 536 536 ₹ 91,729 31-May-19 INTELLECT EQ Buy AAACF6980H 2:52:15 PM 2:52:15 PM 2:52:26 PM 9940 0 256.2 258.9 1000 1000 9:16:07 AM 9:16:07 AM 9:16:07 AM 251 251.2 10:22:03 AM 10:22:03 AM 10:25:59 AM 257 257 ₹ 5,819 31-May-19 REDINGTON EQ Buy AAACF6980H 12:51:47 PM 12:51:47 PM 3:27:32 PM 125305 0 100.25 100.5 75022 75022 9:17:59 AM 9:17:59 AM 12:34:43 PM 99.25 100 12:51:41 PM 12:51:56 PM 12:51:58 PM 100.95 100.95 ₹ 74,276 03-Jun-19 CONCOR EQ Buy AAACF6980H 10:45:38 AM 10:45:38 AM 10:47:23 AM 49472 0 536.65 537.85 30000 30000 10:34:23 AM 10:34:23 AM 10:43:48 AM 533.45 537.9 10:45:28 AM 10:45:55 AM 10:45:58 AM 540 540 ₹ 1,24,733 04-Jun-19 CONCOR EQ Buy AADCF2078D 10:19:03 AM 10:19:03 AM 1:40:45 PM 92487 0 535.5 540 7253 7253 9:19:09 AM 9:19:09 AM 9:19:09 AM 534.3 535 9:33:23 AM 9:33:23 AM 9:33:23 AM 540.4 539 ₹ 33,294 04-Jun-19 ESSELPACK EQ Sell AAACF6980H 9:22:33 AM 9:22:53 AM 3:29:36 PM 0 122235 131 130 45285 45285 9:42:08 AM 9:43:41 AM 2:23:49 PM 130 130 9:16:17 AM 9:16:17 AM 2:20:34 PM 131.2 130.45 ₹ 23,699 04-Jun-19 INFY EQ Buy AAACF6980H 3:01:48 PM 3:01:49 PM 3:28:02 PM 467313 0 736.05 735.35 60000 60000 3:01:00 PM 3:01:00 PM 3:14:04 PM 736.4 734 3:05:24 PM 3:08:24 PM 3:11:52 PM 736.3 733.35 -₹ 31,846 06-Jun-19 AXISBANK EQ Buy AAATF0785F 2:10:56 PM 2:10:56 PM 2:53:18 PM 500000 26300 817.15 813.5 150000 150000 12:37:37 PM 12:37:37 PM 1:39:05 PM 815.6 815 12:50:53 PM 12:52:56 PM 1:43:28 PM 818 818 ₹ 2,59,367 06-Jun-19 CONCOR EQ Buy AAACF8751A 11:26:45 AM 11:26:45 AM 2:23:49 PM 119058 0 537.3 531 47858 47858 11:14:02 AM 11:14:02 AM 11:24:14 AM 533.85 538 11:29:58 AM 11:31:12 AM 11:31:22 AM 540 540.5 ₹ 1,88,296 06-Jun-19 CASTROLIND EQ Sell AAACF6980H 9:22:52 AM 9:22:52 AM 3:26:36 PM 0 364053 150 146 75000 75000 10:02:19 AM 10:03:29 AM 10:03:32 AM 147 147 9:16:47 AM 9:16:47 AM 9:55:19 AM 150.7 148.5 ₹ 1,67,470 07-Jun-19 CASTROLIND EQ Sell AAACF6980H 9:24:19 AM 9:24:19 AM 3:06:38 PM 0 514725 144.2 143.5 100174 100174 10:02:59 AM 10:11:22 AM 10:11:27 AM 142 142 9:17:35 AM 9:18:15 AM 9:54:56 AM 146 143.7 ₹ 1,81,242 10-Jun-19 CONCOR EQ Buy AAACF6980H 1:16:27 PM 1:16:27 PM 1:16:59 PM 33363 0 534.35 536 20000 20000 12:29:53 PM 12:29:53 PM 12:52:14 PM 532.25 534 1:15:56 PM 1:16:33 PM 1:16:44 PM 536 536 ₹ 54,722 10-Jun-19 ICICIGI EQ Sell AAACF6980H 10:11:26 AM 10:11:26 AM 12:13:52 PM 0 68206 1209.25 1193.95 51184 51184 9:45:21 AM 10:11:50 AM 12:13:52 PM 1195 1193.9 9:20:18 AM 9:20:18 AM 11:56:42 AM 1229.15 1204.75 ₹ 7,69,290 10-Jun-19 ICICIPRULI EQ Sell AAATF2091G 11:57:46 AM 11:57:46 AM 2:27:42 PM 0 417959 380.05 380 168853 168853 9:43:24 AM 9:47:04 AM 2:35:48 PM 380 376.5 9:29:44 AM 9:29:44 AM 2:33:28 PM 388.7 379 ₹ 7,00,781 11-Jun-19 CONCOR EQ Buy AAACF6980H 12:20:23 PM 12:20:23 PM 2:08:38 PM 95779 0 535.3 542 3514 3514 10:21:26 AM 10:21:26 AM 10:21:29 AM 536.45 536.5 10:31:44 AM 10:31:44 AM 10:31:44 AM 539.7 539.5 ₹ 10,585 11-Jun-19 ICICIGI EQ Sell AAACF6980H 9:24:35 AM 9:24:35 AM 2:52:20 PM 0 91308 1181.5 1140 59317 59317 9:22:23 AM 9:24:40 AM 2:39:32 PM 1172 1140 9:19:46 AM 9:19:46 AM 2:50:39 PM 1189.2 1140.1 ₹ 6,23,975 11-Jun-19 ICICIPRULI EQ Sell AAACF6980H 9:39:47 AM 9:39:47 AM 9:41:01 AM 0 158067 368.85 365 77189 77189 9:36:52 AM 9:40:36 AM 9:40:45 AM 365 365 9:15:37 AM 9:15:37 AM 9:30:20 AM 374.8 370.4 ₹ 5,67,055 12-Jun-19 HGS EQ Buy AAACF6980H 2:58:20 PM 2:58:20 PM 2:58:35 PM 1875 0 636.35 638 1000 1000 2:49:47 PM 2:49:47 PM 2:54:26 PM 636 636 2:57:58 PM 2:58:27 PM 2:58:29 PM 638 638 ₹ 2,000 13-Jun-19 GSPL EQ Sell AAACF6980H 1:41:17 PM 1:41:17 PM 1:41:51 PM 0 120297 186.75 184 165431 165431 1:40:02 PM 1:41:41 PM 2:40:31 PM 184 184 12:49:20 PM 12:49:20 PM 2:38:48 PM 190.75 185 ₹ 5,38,758 13-Jun-19 HDFC EQ Sell AAACF6980H 9:19:20 AM 9:19:20 AM 11:43:21 AM 0 328384 2177.55 2173.25 21739 21739 9:33:31 AM 9:38:03 AM 9:38:13 AM 2162 2162 9:15:42 AM 9:15:42 AM 9:28:07 AM 2178.3 2175 ₹ 2,57,098 13-Jun-19 SRTRANSFIN EQ Buy AAACF6980H 1:12:26 PM 1:12:26 PM 3:00:33 PM 160674 0 1059.2 1080 110000 110000 12:54:40 PM 12:54:40 PM 2:22:46 PM 1045 1085 1:07:31 PM 1:13:12 PM 2:26:01 PM 1065 1095 ₹ 13,80,534 13-Jun-19 HDFCBANK EQ Sell AAACF8751A 10:06:38 AM 10:06:39 AM 1:55:38 PM 0 132284 2424 2422.15 6012 6012 9:41:07 AM 9:41:57 AM 2:20:46 PM 2425 2435.8 9:18:40 AM 9:18:40 AM 2:19:59 PM 2439.15 2436.85 ₹ 60,065 14-Jun-19 GSPL EQ Sell AAACF8751A 12:14:12 PM 12:14:12 PM 2:33:07 PM 0 141234 179.9 178 69351 69351 11:38:03 AM 12:14:30 PM 12:14:38 PM 178 178 9:42:48 AM 9:42:48 AM 11:24:31 AM 185.95 182 ₹ 4,16,475 14-Jun-19 LTI EQ Sell AAACF8751A 2:02:21 PM 2:02:21 PM 2:02:59 PM 0 31387 1770.25 1762 30000 30000 2:01:29 PM 2:02:42 PM 2:03:02 PM 1762 1762 12:42:08 PM 12:42:08 PM 12:45:28 PM 1789.75 1770 ₹ 2,59,434 17-Jun-19 GSPL EQ Sell AAACF8751A 11:06:22 AM 11:06:22 AM 11:08:37 AM 0 327192 179.4 178 68307 68307 11:04:45 AM 11:09:37 AM 11:14:31 AM 179.35 182 9:25:00 AM 9:25:00 AM 11:01:41 AM 179.2 178.4 -₹ 2,27,536 17-Jun-19 LTI EQ Sell AADCF2078D 1:44:04 PM 1:44:05 PM 2:32:01 PM 0 4978 1775 1775 22659 22659 1:37:34 PM 1:38:44 PM 1:40:11 PM 1777.2 1770 1:29:18 PM 1:29:18 PM 1:34:24 PM 1785.2 1784.5 ₹ 3,39,445 18-Jun-19 GODREJCP EQ Buy AAACF6980H 11:52:24 AM 11:52:24 AM 1:41:08 PM 618828 0 666 680 421376 421376 9:21:50 AM 9:21:50 AM 1:39:27 PM 653.25 675 11:47:59 AM 11:53:00 AM 1:40:59 PM 680 680 ₹ 47,29,895 19-Jun-19 GODREJCP EQ Buy AAACF8751A 11:20:02 AM 11:20:02 AM 11:21:50 AM 187745 0 673.45 677.95 68506 68506 9:29:34 AM 9:29:34 AM 11:15:04 AM 669.95 674.1 11:15:56 AM 11:21:17 AM 11:21:37 AM 678 678 ₹ 3,83,949 24-Jun-19 HDFC EQ Sell AAACF6980H 10:52:05 AM 10:52:05 AM 10:52:27 AM 0 15541 2150.1 2147 10000 10000 10:50:32 AM 10:52:11 AM 10:52:23 AM 2147 2147 10:48:28 AM 10:48:28 AM 10:51:52 AM 2151.75 2150.3 ₹ 37,365 24-Jun-19 SRTRANSFIN EQ Buy AAACF6980H 12:03:41 PM 12:03:41 PM 12:03:58 PM 84366 0 1115.2 1116 148614 148614 9:49:41 AM 9:49:41 AM 12:10:15 PM 1085.6 1114 10:08:09 AM 10:08:09 AM 12:13:09 PM 1103.5 1116 ₹ 9,36,070 25-Jun-19 SRTRANSFIN EQ Buy AAACF9233H 12:00:37 PM 12:00:37 PM 3:29:58 PM 214201 0 1119.15 1117 144867 144867 9:16:08 AM 9:16:08 AM 2:35:27 PM 1103.95 1116.25 10:12:54 AM 11:58:05 AM 2:39:41 PM 1120 1118 ₹ 7,44,046 26-Jun-19 GODREJCP EQ Buy AAATF2091G 11:19:20 AM 11:19:20 AM 12:33:50 PM 324360 0 679.9 678.15 30833 30833 9:37:26 AM 9:37:26 AM 10:18:42 AM 677.55 678 9:44:20 AM 9:44:20 AM 10:21:31 AM 680 680 ₹ 69,445 28-Jun-19 JBCHEPHARM EQ Buy AAATF0785F 10:16:32 AM 10:16:41 AM 3:28:01 PM 21974 0 364 364.5 5360 5360 10:16:27 AM 10:16:27 AM 11:26:23 AM 361.75 364 10:18:39 AM 10:32:26 AM 11:32:29 AM 365 365 ₹ 7,947 01-Jul-19 CASTROLIND EQ Sell AAACF6980H 10:08:51 AM 10:08:51 AM 10:56:16 AM 0 368684 130.45 130.05 257473 257473 10:07:50 AM 10:08:55 AM 10:56:14 AM 130.05 130.05 9:15:12 AM 9:15:12 AM 10:37:30 AM 133.15 130.95 ₹ 3,42,500 01-Jul-19 CONCOR EQ Buy AAACF9233H 11:04:06 AM 11:04:06 AM 3:25:47 PM 157679 0 577.85 577.95 45555 45555 10:59:59 AM 10:59:59 AM 11:30:28 AM 574.7 579 11:07:40 AM 11:09:24 AM 11:46:23 AM 580 580 ₹ 1,42,056 02-Jul-19 EMBASSY RR Buy AAACF3101C 10:49:20 AM 10:49:20 AM 3:17:53 PM 187200 0 370 372 80000 80000 10:45:52 10:45:52 AM 10:47:09 AM 366.76 370 10:48:35 10:51:37 AM 10:51:58 AM 372 372 ₹ 1,86,220 02-Jul-19 LTI EQ Sell AAACF9233H 9:53:04 AM 9:53:04 AM 3:29:50 PM 0 49545 1818.25 1769 14428 14428 9:55:32 AM 9:56:07 AM 1:17:41 PM 1800 1768 9:51:36 AM 9:51:36 AM 1:16:31 PM 1825.1 1769 ₹ 1,07,278 03-Jul-19 INFY EQ Buy AAACF9233H 10:14:07 AM 10:14:07 AM 11:48:55 AM 600432 0 741.4 740 313156 313156 9:16:55 AM 9:16:59 AM 10:38:22 AM 738.75 740 9:31:22 AM 9:31:22 AM 10:45:12 AM 742.15 742 ₹ 5,39,869 04-Jul-19 LTI EQ Sell AAATF0785F 10:43:29 AM 10:43:29 AM 3:28:51 PM 0 84366 1680.1 1656.75 42038 42038 10:24:50 AM 10:27:28 AM 1:43:13 PM 1680 1650.05 10:17:36 AM 10:17:36 AM 1:40:33 PM 1702.6 1651 ₹ 2,69,796 08-Jul-19 ICICIGI EQ Buy AAATF0785F 9:44:02 AM 9:44:02 AM 10:26:42 AM 31818 0 1091.05 1085 17611 17611 9:31:09 AM 9:32:41 AM 9:33:02 AM 1081.1 1080 9:43:28 AM 9:44:02 AM 9:44:03 AM 1092 1092 ₹ 1,94,832 10-Jul-19 POWERGRID EQ Buy AAACF9668G 3:22:34 PM 3:22:34 PM 3:22:34 PM 96489 0 205 205 319209 319209 11:24:40 AM 11:24:40 AM 2:56:49 PM 203.7 205.5 11:29:36 AM 11:35:02 AM 2:59:26 PM 205 206 ₹ 3,05,090 11-Jul-19 INFY EQ Sell AAACF9233H 9:53:13 AM 9:53:13 AM 9:53:25 AM 0 300000 711.8 710.15 114772 114772 9:51:31 AM 9:53:13 AM 9:58:30 AM 710.05 713 9:30:48 AM 9:30:55 AM 9:54:05 AM 712.9 712 ₹ 1,98,042 11-Jul-19 SRTRANSFIN EQ Buy AAACF6980H 9:45:20 AM 9:45:20 AM 9:46:00 AM 140819 0 1045 1047.15 90001 90001 9:19:09 AM 9:19:09 AM 9:38:54 AM 1042.45 1043.05 9:41:26 AM 9:45:29 AM 9:45:31 AM 1049.5 1049.5 ₹ 4,48,484 15-Jul-19 CONCOR EQ Buy AAACF9668G 12:16:10 PM 12:16:10 PM 2:17:32 PM 91117 0 555 555 10000 10000 10:49:41 AM 10:49:41 AM 10:49:41 AM 555.95 556.05 10:56:34 AM 10:57:01 AM 10:57:05 AM 560 560 ₹ 39,500 15-Jul-19 TATACOMM EQ Sell AAACF6980H 2:12:01 PM 2:12:01 PM 2:12:23 PM 0 58700 492.4 490 37770 37770 1:05:43 PM 2:12:17 PM 2:12:23 PM 490 490 9:42:46 AM 9:42:46 AM 2:08:49 PM 495.85 492 ₹ 1,42,449 17-Jul-19 GODREJCP EQ Buy AAACF9233H 11:18:06 AM 11:18:06 AM 3:01:27 PM 443342 0 645 646 130256 130256 9:15:57 AM 9:15:57 AM 1:50:31 PM 634.75 649 9:20:46 AM 9:20:46 AM 1:53:36 PM 642.3 650 ₹ 5,02,317 17-Jul-19 GODREJCP EQ Sell AAATF1707F 9:43:47 AM 9:43:47 AM 9:43:47 AM 0 150000 642.3 640.5 130256 130256 9:15:57 AM 9:15:57 AM 1:50:31 PM 634.75 649 9:20:46 AM 9:20:46 AM 1:53:36 PM 642.3 650 18-Jul-19 SHEMAROO EQ Buy AAACF6980H 2:16:12 PM 2:16:12 PM 2:16:27 PM 9451 0 334.75 335 56690 56690 12:12:11 PM 12:12:26 PM 1:56:02 PM 312.1 330.05 12:49:50 PM 12:49:50 PM 2:16:23 PM 340.15 335 ₹ 10,39,076 19-Jul-19 BIOCON EQ Buy AAACF6980H 1:03:42 PM 1:03:42 PM 1:03:42 PM 824982 0 248.4 250 100000 100000 1:00:57 PM 1:00:57 PM 1:02:38 PM 246 249 1:03:29 PM 1:03:42 PM 1:05:50 PM 249.95 247 ₹ 95,395 22-Jul-19 SHEMAROO EQ Buy AAACF6980H 11:44:45 AM 11:44:45 AM 3:29:44 PM 17184 0 339.55 332.45 15991 15991 10:12:07 AM 10:12:07 AM 11:34:47 AM 323.45 331 10:25:03 AM 10:25:03 AM 11:44:49 AM 331.5 340 ₹ 1,39,337 24-Jul-19 HINDOILEXP EQ Buy AAACF6980H 3:05:09 PM 3:05:09 PM 3:05:24 PM 23202 0 124.45 125 10000 10000 3:03:22 PM 3:03:22 PM 3:03:22 PM 123.15 124 3:04:45 PM 3:05:22 PM 3:05:23 PM 125 125 ₹ 13,361 25-Jul-19 SHEMAROO EQ Buy AAATF0785F 11:43:51 AM 11:43:51 AM 1:45:11 PM 4351 0 348 352 2000 2000 9:32:48 AM 9:32:48 AM 9:32:48 AM 341.9 342 11:50:30 AM 12:43:42 PM 12:43:42 PM 350 350 ₹ 16,001 26-Jul-19 ICICIGI EQ Buy AAACF6980H 3:20:33 PM 3:20:33 PM 3:24:50 PM 8958 0 1139 1139.9 3493 3493 9:15:29 AM 9:15:29 AM 9:47:02 AM 1093.2 1100 10:21:22 AM 10:26:17 AM 10:26:57 AM 1110 1110 ₹ 45,596 29-Jul-19 ICICIGI EQ Buy AAACF8751A 10:45:33 AM 10:45:33 AM 10:47:15 AM 29104 0 1167 1169.9 15575 15575 9:25:18 AM 9:25:18 AM 10:20:06 AM 1159.95 1165.1 10:45:48 AM 10:46:30 AM 10:47:12 AM 1169.9 1169.9 ₹ 1,09,147 29-Jul-19 GUJGASLTD EQ Buy AAACF6980H 11:07:22 AM 11:07:22 AM 11:09:48 AM 103685 0 157.95 160 14626 14626 11:04:00 AM 11:04:00 AM 11:04:51 AM 155.7 158 11:06:51 AM 11:09:43 AM 11:09:46 AM 160 160 ₹ 40,263

Front running instances of Alka Dhadda (Annexure 1) Trade date Symbol Series Big client Big Client Pan Big client Big client Big client Big order Big order Big order Big order FR buy FR sell FR Buy Order FR client buy FR client buy FR buy FR buy FR Sell Order FR client sell FR client sell FR sell FR sell Squared off activity order start buy/ sell buy/ sell end buy qty sell qty buy/sell buy/sell qty qty Start time start time end time start end Start Time start time end time start end Difference time start time time start price end price price price price price 31-Jul-19 GUJGASLTD EQ Buy AAACF6980H 11:40:40 AM 11:40:40 AM 11:40:52 AM 83832 0 174 175 40000 40000 9:22:02 AM 9:22:02 AM 9:26:05 AM 174.9 175 9:32:31 AM 9:32:31 AM 12:50:44 PM 177.35 172 ₹ 21,884 01-Aug-19 INFY EQ Buy AADCF2078D 12:08:45 PM 12:08:45 PM 12:36:34 PM 50000 0 770 772 110000 110000 9:44:43 AM 9:44:43 AM 12:52:44 PM 785.1 769 10:29:03 AM 2:56:53 PM 3:04:26 PM 770 765 -₹ 18,78,488 01-Aug-19 CONCOR EQ Sell AAACF9233H 10:20:35 AM 10:22:03 AM 2:54:42 PM 0 254411 510 510 70000 70000 11:21:39 AM 11:23:21 AM 11:23:26 AM 504 504 10:02:09 AM 10:02:09 AM 10:10:12 AM 513.25 510 ₹ 4,54,465 05-Aug-19 ICICIGI EQ Buy AAACF8751A 9:59:18 AM 9:59:18 AM 9:59:50 AM 102955 0 1168.35 1177.35 20000 20000 9:17:47 AM 9:17:47 AM 9:57:22 AM 1154.25 1170 9:58:38 AM 9:59:28 AM 9:59:31 AM 1180 1180 ₹ 2,25,502 05-Aug-19 PNBHOUSING EQ Buy AAACF6980H 11:12:04 AM 11:12:04 AM 3:21:41 PM 79730 0 704 704.95 15776 15776 10:44:29 AM 10:44:44 AM 10:58:32 AM 701 704 11:11:37 AM 11:12:28 AM 11:12:31 AM 710 710 ₹ 1,24,660 05-Aug-19 CONCOR EQ Sell AAACF8751A 12:22:49 PM 12:22:49 PM 12:28:40 PM 0 114982 498 496.05 20000 20000 12:20:09 PM 1:40:40 PM 1:47:54 PM 505.05 506 12:19:00 PM 12:19:00 PM 12:19:17 PM 498 498 -₹ 1,57,380 05-Aug-19 HDFC EQ Sell AADCF2078D 12:52:37 PM 12:52:37 PM 2:03:56 PM 0 123617 2135.5 2133.85 40000 40000 12:07:52 PM 12:21:23 PM 12:21:27 PM 2125 2125 10:29:25 AM 10:29:25 AM 11:27:13 AM 2128.75 2130 ₹ 1,90,508 06-Aug-19 LICHSGFIN EQ Sell AAATF1824H 3:02:17 PM 3:03:45 PM 3:15:20 PM 0 16000 485 485 90000 90000 10:10:58 AM 10:20:19 AM 11:14:16 AM 485 485 9:41:39 AM 9:41:39 AM 10:39:25 AM 489.4 488.4 ₹ 3,90,143 07-Aug-19 ICICIGI EQ Buy AAACF6980H 10:55:53 AM 10:55:53 AM 11:46:55 AM 170591 0 1198.85 1200 14418 14418 9:35:12 AM 9:35:12 AM 10:57:09 AM 1199 1200.05 11:21:37 AM 11:21:38 AM 11:22:23 AM 1199.85 1199.85 -₹ 4,599 07-Aug-19 CONCOR EQ Sell AAACF9668G 2:30:31 PM 2:30:35 PM 2:46:01 PM 0 2190 486.85 485 18735 18735 12:53:04 PM 12:54:33 PM 12:54:35 PM 485 485 10:49:55 AM 10:49:55 AM 12:39:25 PM 493.85 488 ₹ 94,191 23-Aug-19 FRETAIL EQ Sell AAACF6980H 2:11:13 PM 2:11:13 PM 3:29:14 PM 0 449733 384.1 395 15000 15000 2:05:35 PM 2:12:07 PM 2:12:10 PM 380 380 2:03:36 PM 2:03:36 PM 2:05:14 PM 383.9 383 ₹ 45,607 Total ₹ 1,85,75,843

Front running instances of Arushi Dhadda (Annexure 2) Trade date Symbol Series Big client Big Client Pan Big client Big client Big client Big order Big order Big order Big order FR buy FR sell qty FR Buy Order FR client buy FR client buy FR buy FR buy FR Sell Order FR client sell FR client sell FR sell FR sell Squared off activity order start buy/ sell start buy/ sell end buy qty sell qty buy/sell buy/sell qty Start Time start time end time start end Start Time start time end time start end Difference time time time start price end price price price price price 29-May-19 GICHSGFIN EQ Buy AAACF6980H 1:13:39 PM 1:13:39 PM 1:13:57 PM 11,912 0 262.35 266.5 3,000 3,000 11:12:31 AM 11:12:31 AM 11:12:31 AM 264 264.15 1:11:11 PM 1:13:56 PM 1:13:57 PM 266.5 266.5 ₹ 7,164 29-May-19 GUJGASLTD EQ Buy AAACF6980H 12:04:38 PM 12:04:38 PM 12:08:02 PM 2,43,494 0 180 186 3,000 3,000 11:53:39 AM 11:53:39 AM 11:53:59 AM 183.95 183.95 12:03:39 PM 12:08:01 PM 12:08:01 PM 186 186 ₹ 6,143 31-May-19 INTELLECT EQ Buy AAACF6980H 2:52:15 PM 2:52:15 PM 2:52:26 PM 9,940 0 256.2 258.9 5,108 5,108 2:47:41 PM 2:47:41 PM 2:50:23 PM 255.4 256 2:52:14 PM 2:52:20 PM 2:53:26 PM 258.9 257 ₹ 15,193 Total ₹ 28,500