ANSAL PROPERTIES AND INFRASTRUCTURE LIMITED

PROHIBITION ON INSIDER TRADING OF SECURITIES

(SECTION 195 OF THE COMPANIES ACT, 2013)

Section

Provisions of Sections Checklist

195(1) No person including any director or key managerial personnel of a company shall enter into insider trading.Provided that nothing contained in this sub-section shall apply to any communication required in the ordinary course of business or profession or employment or under any law.

Explanation.—For the purposes of this section,—(a) “insider trading” means—

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

There will be a contravention of the provisions of Section 195 of the Companies Act, 2013, if ATLEAST ONE of any of the Sub Points within Section -“A” AND ATLEAST ONE of any of the Sub-points within Section-“B” OR the conditions as specified under Section-“C” are “YES” YES NO

Section- “A”Whether the concerned person is:

a) Director in Companyor

b) Whole Time Director (WTD)

Orc) CEO/CFO

Ord) Managing Director

Ore) Company Secretary

Orf) Any other officer

Section-“B”

(i) Whether any of the following acts in relation to the securities of the Company is done by the aforesaid concerned person(either on his own behalf or on someone else’s behalf i.e. as an agent) as mentioned in Section-“A”:-

a) Subscribing

b) Buying

c) Selling

d) Dealing

OR

ANSAL PROPERTIES AND INFRASTRUCTURE LIMITED

(ii) an act of counselling about procuring or communicating directly or indirectly any non-public price-sensitive information to any person;

(b)“price-sensitive information” means any information which relates, directly or indirectly, to a company and which if published is likely to materially affect the price of securities of the company.

YES NO

Whether the concerned person has entered into an agreement in relation to any securities of the Company (either on his own behalf or on someone else’s behalf i.e. as an agent) for doing any of the following:-

a) Subscribing

b) Buying

c) Selling

d) Dealing

AND

(ii) whether the concerned person Is reasonably expected to have access to any non-public price sensitive information(as defined in the “provision to Section column”)

Section-“C”

(i) Whether the concerned person(s) as mentioned in Section A has counseled any other person, directly or indirectly, about procuring any non-public information of company, which if published, may materially affect the price of securities of the company

OR(ii) Whether the concerned

person has Communicated directly or indirectly any non-

YES NO

public information of company, which if

ANSAL PROPERTIES AND INFRASTRUCTURE LIMITED

195(2) If any person contravenes the provisions of this section, he shall be punishable with imprisonment for a term which may extend to five years or with fine which shall not be less than five lakh rupees but which may extend to twenty-five crore rupees or three times the amount of profits made out of insider trading, whichever is higher, or with both.

published, may materially affect the price of securities of the company

AND

Whether the aforesaid Communication is not in the ordinary course of business or profession or employment or under any law.

In case of contravention i.e. if the conditions as specified above are satisfied, the concerned person as mentioned in Section-A shall be punishable with:-

(i) Imprisonment of upto 5 years or

(ii) Fine between Rs. 500,000 and 25,00,00,000 or

(iii) 3 times of the profits made out of the insider trading.

Date: 26.03.2014