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CODE OF INTERNAL PROCEDURES AND CONDUCT FOR REGULATING, MONITORING AND REPORTING OF TRADING BY INSIDERS TH (Effective from 15 May 2015) Definitions 1.1 Act means the Securities and Exchange Board
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Start by gathering all relevant information: Before you begin filling out the code of internal procedures, ensure you have all the necessary information and documentation related to your organization's processes, policies, and regulations. This may include company guidelines, industry standards, legal requirements, and input from various stakeholders.
02
Define the purpose and scope: Clearly establish the purpose and scope of the code of internal procedures. Determine what areas or processes it will cover and what goals it aims to achieve. This will help provide a clear direction for the development and implementation of the code.
03
Identify key areas and processes: Break down the code into different sections or modules based on the various areas and processes within your organization. This could include sections related to finance, human resources, quality control, risk management, IT, and more. Assign responsible individuals or teams for each section.
04
Define policies and guidelines: Within each section, define the policies and guidelines that need to be followed. This involves specifying the rules, procedures, and best practices that should be adhered to in order to ensure compliance, efficiency, and effectiveness in each area. These policies should be clear, concise, and easy to understand.
05
Include templates and forms: Provide standardized templates and forms that employees can use to support the implementation of the procedures outlined in the code. These templates can help streamline processes, maintain consistency, and facilitate documentation and reporting.
06
Establish communication channels: It is essential to establish effective communication channels for employees to seek clarification, report concerns, or provide feedback related to the code of internal procedures. This can be done through regular team meetings, suggestion boxes, email communication, or dedicated platforms for documentation and collaboration.
07
Train employees: Conduct training sessions or workshops to educate employees about the code of internal procedures and its significance. Ensure that all employees understand their roles and responsibilities in adhering to the code and the consequences of non-compliance.
08
Regularly update and review: Codes of internal procedures should not be static documents. They need to be regularly reviewed and updated to keep pace with organizational changes, evolving regulations, and industry trends. Make it a part of your organizational culture to periodically review and improve the code based on feedback and lessons learned.

Who needs code of internal procedures?

01
Organizations: Every organization, regardless of its size or industry, can benefit from having a code of internal procedures. It provides guidelines and structure for employees, helps ensure consistency in decision-making and execution, and promotes compliance with legal and regulatory requirements.
02
Management: Code of internal procedures is particularly valuable for management teams as it helps establish a framework for effective governance, risk management, and operational control. It provides a basis for monitoring and assessing performance, identifying areas for improvement, and ensuring strategic objectives are met.
03
Employees: Employees at all levels within an organization need a code of internal procedures to understand the expectations and requirements for their respective roles. It helps provide clarity, consistency, and a common understanding of how things should be done. It also promotes fairness, transparency, and accountability within the organization.
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The code of internal procedures is a set of guidelines that govern an organization's internal operations and activities.
Certain organizations, particularly those in regulated industries, are required to file their code of internal procedures with the appropriate regulatory bodies.
The code of internal procedures is typically filled out by the organization's compliance or legal team, and should include detailed information about the company's policies and procedures.
The purpose of the code of internal procedures is to ensure that an organization operates in a compliant and ethical manner, and to prevent fraud, corruption, and other misconduct.
The code of internal procedures should include information about the organization's policies on areas such as bribery, conflicts of interest, and data protection.
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