Chapter 1 Tittle and Topics 2 Page no

3 5 INTRODUCTON 7
4 1 6
 Introduction
8 10 OBJECTIVES 12
9 2 11 & METHODOLOGY

 Need of study
 Scope of study
 Objectives of study
 Review of literature
 Research methodology
 Limitations of study
13 15 COMPANY PROFILE 17
14 3 16
18 20 THEORTICALLY 23
19 4 21 FRAME WORK
22
24 26 DATA ANALYSIS 29
25 5 27 & INTERPRETATION
28
30 32 FINDINGS & SUGGESTIONS 33
31 6  Findings
 Suggestions
 Conclusion

34  Annexure 36
35 7  Biblography

37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61 INTRODUCTION

INTRODUCTION

ABOUT RATIO ANALYSIS

The ratio analysis is the most powerful tool of financial analysis. Several ratios calculated from the
accounting data can be grouped into various classes according to financial activity or function to be
evaluated.
1
2 DEFINITION:

“The indicate quotient of two mathematical expressions “and as “The relationship between two or
more things. “It evaluates the financial position and performance of the firm.
As started in the beginning many diverse groups of people are interested in analyzing financial
information to indicate the operating and financial efficiency and growth of firm. These people use
ratios to determine those financial characteristics of firm in which they interested with the help of
ratios one can determine.
1
2
3
 The ability of the firm to meet its current obligations.

 The extent to which the firm has used its long-term solvency by borrowing funds.

 The efficiency with which the firm is utilizing its assets in generating the sales revenue.

 The overall operating efficiency and performance of firm.

The information contained in these statements is used by management, creditors, investors and others
to form judgment about the operating performance and financial position of firm. Uses of financial
statement can get further insight about financial strength and weakness of the firm if they properly
analyze information reported in these statements. Management should be particularly interested in
knowing financial strength of the firm to make their best use and to be able to spot out financial
weaknesses of the firm to take suitable corrective actions. The further plans firm should be laid down
in new of the firm’s financial strength and weaknesses. Thus financial analysis is the starting point for
making plans before using any sophisticated forecasting and planning procedures. Understanding the
past is a prerequisite for anticipating the future.
 NEED OF THE STUDY

The prevalent educational system providing the placement training at an industry being a part of the
curriculum has helped in comparison of theoretical knowledge with practical system. It has led to note
the convergences and divergence between theory and practice.
The study enables us to have access to various facts of the organization. It helps in understanding the
needs for the importance and advantage of materials in the organization, the study also helps to
exposure our minds to the integrated materials management the various procedures, methods and
technique adopted by the organization. The study provides knowledge about how the theoretical
aspects are put in the organization in terms of described below

 To pay wages and salaries.

 For the purchase of raw materials, spares and components parts.

 To incur day-to-day expenses.

 To meet selling costs such as packing, advertising.

 To provide credit facilities to customers.

 To maintain inventories and raw materials, work-in-progress and finished stock.

 Scope of the study

The scope of the study is limited to collecting financial data published in the annual reports of the
company every year. The analysis is done to suggest the possible solutions. The study is carried out for
4 years (2006– 10).

Using the ratio analysis, firms past, present and future performance can be analyzed and this study has
been divided as short term analysis and long term analysis. The firm should generate enough profits
not only to meet the expectations of owner, but also to expansion activities.

OBJECTIVE’S OF STUDY

1. To study and analyze the financial position of the Company through ratio analysis.

2. To suggest measures for improving the financial performance of organization.

3. To analyze the profitability position of the company.

4. To assess the return on investment.

5. To analyze the asset turnover ratio.

6. To determine the solvency position of company.

7. To suggest measures for effective and efficient usage of inventory.

REVIEW OF LITERATURE

FINANCIAL ANALYSIS

Financial analysis is the process of identifying the financial strengths and weakness of the firm. It
is done by establishing relationships between the items of financial statements viz., balance sheet and
profit and loss account. Financial analysis can be undertaken by management of the firm, viz., owners,
creditors, investors and others.

Objectives of the financial analysis

Analysis of financial statements may be made for a particular purpose in view.

1. To find out the financial stability and soundness of the business enterprise.
2. To assess and evaluate the earning capacity of the business
3. To estimate and evaluate the fixed assets, stock etc., of the concern.
4. To estimate and determine the possibilities of future growth of business.
5. To assess and evaluate the firm’s capacity and ability to repay short and long term loans

Parties interested in financial analysis

The users of financial analysis can be divided into two broad groups

Internal users.

1. Financial executives
2. Top management

External users
1. Investors
2. Creditor.
3. Workers
4. Customers
5. Government
6. Public
7. Researchers

Significance of financial analysis

Financial analysis serves the following purpose:

To know the operational efficiency of the business:

The financial analysis enables the management to find out the overall efficiency of the firm. This
will enable the management to locate the weak Spots of the business and take necessary remedial
action.

Helpful in measuring the solvency of the firm:

The financial analysis helps the decision makers in taking appropriate decisions for strengthening
the short-term as well as long-term solvency of the firm.

Comparison of past and present results:

Financial statements of the previous years can be compared and the trend regarding various
expenses, purchases, sales, gross profit and net profit can be ascertained.

Helps in measuring the profitability:

Financial statements show the gross profit, & net profit.

Inter‐firm comparison:
The financial analysis makes it easy to make inter-firm comparison. This comparison can also be
made for various time periods.
Bankruptcy and Failure:
Financial statement analysis is significant tool in predicting the bankruptcy and the failure of the
business enterprise. Financial statement analysis accomplishes this through the evaluation of the
solvency position.

Helps in forecasting:
The financial analysis will help in assessing future development by making forecasts and preparing
budgets.
METHODS OF ANALYSIS:

A financial analyst can adopt the following tools for analysis of the financial statements.
These are also termed as methods of financial analysis.
A. Comparative statement analysis
B. Common-size statement analysis
C. Trend analysis
D. Funds flow analysis
E. Ratio analysis

NATURE OF RATIO ANALYSIS

Ratio Analysis is a powerful tool of financial analysis. A ratio is defined as "the indicated
quotient of mathematical expression" and as "the relationship between two or more things". A ratio is
used as benchmark for evaluating the financial position and performance of the firm. The relationship
between two accounting figures, expressed mathematically, is known as a financial ratio. Ratio helps
to summarizes large quantities of financial data and to make qualitative judgment about the firm's
financial performance.

The persons interested in the analysis of financial statements can be grouped under three head
owners (or) investors who are desired primarily a basis for estimating earning capacity. Creditors who
are concerned primarily with Liquidity and ability to pay interest and redeem loan within a specified
period. Management is interested in evolving analytical tools that will measure costs, efficiency,
liquidity and profitability with a view to make intelligent decisions.

STANDARDS OF COMPARISON
The ratio analysis involves comparison for an useful interpretation of the financial statements.
A single ratio in itself does not indicate favorable or unfavorable condition. It should be compared
with some standard. Standards of comparison are:

1. Past Ratios
2. Competitor's Ratios
3. Industry Ratios
4. Projected Ratios

Past Ratios: Ratios calculated from the past financial statements of the same firm.
Competitor's Ratios: Ratios of some selected firms, especially the most progressive and successful
competitor at the same point in time.
Industry Ratios: Ratios of the industry to which the firm belongs.
Projected Ratios: Ratios developed using the projected financial statements of the same firm.

TIME SERIES ANALYSIS

The easiest way to evaluate the performance of a firm is to compare its present ratios with
past ratios. When financial ratios over a period of time are compared, it is known as the time series
analysis or trend analysis. It gives an indication of the direction of change and reflects whether the
firm's financial performance has improved, deteriorated or remind constant over time.
CROSS SECTIONAL ANALYSIS
Another way to comparison is to compare ratios of one firm with some selected firms in the
industry at the same point in time. This kind of comparison is known as the cross-sectional analysis. It
is more useful to compare the firm's ratios with ratios of a few carefully selected competitors, who
have similar operations.

INDUSTRY ANALYSIS

To determine the financial conditions and performance of a firm. Its ratio may be compared
with average ratios of the industry of which the firm is a member. This type of analysis is known as
industry analysis and also it helps to ascertain the financial standing and capability of the firm & other
firms in the industry. Industry ratios are important standards in view of the fact that each industry has
its characteristics which influence the financial and operating relationships.

Research Methodology

Research Design
In view of the objects of the study listed above an exploratory research design has been adopted.
Exploratory research is one which is largely interprets and already available information and it lays
particular emphasis on analysis and interpretation of the existing and available information.

 To know the financial status of the company.

 To know the credit worthiness of the company.
 To offer suggestions based on research finding.

Data Collection Methods

Primary Data
Information collected from internal guide and finance manager. Primary data is first hand information.

Secondary Data
Company balance sheet and profit and loss account. secondary data is second hand information.

Data Collection Tools

To analyze the data acquire from the secondary sources “Ratio Analysis”The scope of the study is
defined below in terms of concepts adopted and period under focus.
First the study of Ratio Analysis is confined only to the Amarraja Batteries Limited.
Secondly the study is based on the annual reports of the company for a period of 4 years from 2006-07
to 2009-10 the reason for restricting the study to this period is due time constraint.
 LIMITATIONS

 The study was limited to only four years Financial Data.

 The study is purely based on secondary data which were taken primarily from Published annual
reports of IIFL Finance Limited.
 There is no set industry standard for comparison and hence the inference is made on general
standards.
 The ratio is calculated from past financial statements and these are not indicators of future.
 The study is based on only on the past records.
 Non availability of required data to analysis the performance.
 The short span of the time provided also one of limitations.
CHAPTER-3
. Company Profile

THE JOURNEY OF IIFL

IIFL group, comprising the holding company IIFL Holdings Ltd. and its subsidiaries, is one of India’s
leading financial services player - providing a broad range of financial products and services to a
substantial and diversified client base. IIFL’s businesses mainly comprise of Loans and Mortgages,
Wealth and Asset Management and Capital Market related activities
The group has more than 19,000 employees, 1600+ branches and 1,200 + partner locations
catering to more than 40 Lakh customers. The group also has several subsidiaries in major global
financial centers.
IIFL owns and manages the website www.iifl.com, which is one of India’s leading online
destinations for personal finance, stock markets, economy and business. IIFL’s CRISIL and ICRA
Rating for long term is rated as ICRA (AA). The Group has a consistent and uninterrupted track
record of profits and dividends since its listing in 2005. The Company is listed on both exchanges
and also trade in the derivatives segment.

Our Genesis - Who We Are

IIFL is a financial services conglomerate which was
started by a group of passionate entrepreneurs
in 1995. The genesis of IIFL lies in the power of
dreaming big and believing in your dreams.
IIFL was a pioneer in the retail broking industry with
its launch of 5paisa trading platform which
offered the lowest brokerage in the industry and the
freedom from traditional ways of transacting.
Our strength has been to continuously innovate and
reinvent ourselves. IIFL’s evolution from an
entrepreneurial start-up in 1995 to a full range
diversified financial services group is a story of
steady growth by adapting to the dynamic business
environment, without losing focus on our core
domain of financial services.
Today, IIFL Holdings Limited (Bloomberg Code: IIFL
IN, NSE: IIFL, BSE: 532636) is India’s leading
integrated financial services group with diverse
operating businesses, mainly, Non Banking and
Housing Finance, Wealth and Asset Management,
Financial
 Advisory and Broking, Mutual Funds
and Financial Product Distribution, Investment
Banking, Institutional Equities, Realty Broking and
Advisory Services.
IIFL serves more than 4 million satisfied customers
across various business segments and is
continuously building on its strengths to deliver
excellent service to its expanding customer base.
5542 cr ($808 mn) NETWORTH 19000 +WORKFORCE
1600 CUSTOMER STRATEGY

Our Strategyu

BUSINESS PEOPLE
CCUSTOMER siness Strategy
STRATEGY STRATEGY
STRATEGY Customer Strategy
CCCCCCCU
• Continuosly •Attract
Drive Stickness
assimilate, analyse through initial
exceptionally
& apply knowledge quality
talented &&driven
research
to power superior services
financial decision people
Maintain cutting
• Focus on core • priority
edge Ensure
Competencies in conducive
technology
Financial Services environement
Wide multi-model to
• Ensure de-risk network servicing as
work in with trust
business through one&stop shop to
multiple products & customer
diverse revenue empowerment
streams
HISTORY OF PROGRESS
P
ttegy
OUR PORTFOLIO
IIFL GROUP BUSINESSES
 Loans and Mortgages
 Home Loans
 LAS
 Small and Medium Enterprises Financing
 Gold Loans
 Commercial Vehicles
 Micro Finance
 Third Party Distribution
 Insurance
 Mutual Funds

 Wealth Management
 Advisory
 AIFs
 Family office trusts
 Asset Management
  Credit Solutions
 Estate Planning

 Capital Markets related activities

 Retail Broking
 Institutional Broking
 Investment Banking
 Other Ventures
 Real Estate

A FINANCIAL POWER HOUSE

AWARDS & ACCOLADES
BOARD OF DIRECTORS
VISION, VALUES & CULTURE
Our Vision
“To become the Most Respected Company in the
Financial Service Space in India”
We have come this far solely based on our core
values serving as a moral compass in all our
dealings. Fairness, Integrity and Transparency - FIT is
the driving force behind all that we do hereat IIFL. We
only work with people who fit into our professional
ethos. Our constant endeavor is to deliver befittingly
on all fronts to all our stakeholders.

The Core Values at IIFL are:-

 F-Fairness- Fairness in our transactions with all
stakeholders including employees,customers,
and vendors, bereft of fear or favour
 I-Integrity- Integrity and honesty of the utmost
nature, in letter, in spirit, and in all our dealings
with people, internal or external
 T-Transparency- Transparency in all our dealings
with stakeholders, media,investors, and the
public at large

Our Culture
Owner’s
Mindset
(OM)
What

distinguishes IIFL from other organizations is the fact

that all employees are driven by the
Owner’s Mindset. This is a privilege as well as a
responsibility.
 OM is the DNA and culture of our organization
 Everyone behaves like an owner and not as an
employee of the organization and comes up with
ideas, which may not be related to the core
function of the person, sometimes general in
nature, for the benefit of the organization and its
employees and sometimes for better
performance of other departments, businesses.
 Whenever an employee faces a problem, he or
she faces it like an owner and strives to find a
solution to it.

Application of Mind (AOM)

Keep the objective of the task at hand and the overall

objective of the organization in mind all the time
 Don’t simply follow rules / procedures without
understanding the logic.
  When in doubt, ask questions and seek
clarity.With OM and AOM everyone in the
organization feels that work is fun. It’s less
tedious and more enjoyable.

ESSENTIAL OF ENTREPRENEURSHIP/

SPIRIT OF ENTREPRENEURSHIP

Energy
How well we execute a task, depends on the kind of
energy we put into completing thetask
Execution
It’s the Execution that has made all the difference
between winning and losing organizations
Efforts
From an organization’s perspective, it’s not the
NUMBER of hours you spend at work that matter but
the QUALITY of work or efforts that you put into those
hours matters
Ethics
Every company has its own values and code of
conduct. It is important that every employee
understands the culture of an organization and fits
into it
Excellence
Doing things right the first time saves time, effort
and resources. Completing a task 100% and with full
energy and motivation is not sufficient. We need to
do things the RIGHT way.

CORPORATE STRUCTURE
1. IIFL Holdings Limited (IIFL)
IIFL Holdings Limited (formerly India Infoline Limited)
is the holding company of IIL. IIFL Holdings Limited is
registered as an Investment Advisor under the SEBI
(Investment Advisors)
Regulations, 2013 and Merchant Banker under SEBI
(Merchant Bankers) Regulations, 1992.
2. India Infoline Finance Limited (IIFFL)
A systemically important non deposit accepting, non
banking financial company (NBFC) registered with
RBI. IIFL offers broad suit of lending and other
financial products such as mortgage loan, gold loan,
loan against securities, commercial vehicle and
health care finance to retail and corporate clients:
3. IIFL Home Finance Limited (IHFL)
IIHFL is a wholly owned subsidiary of India Infoline
Finance Limited. This Company is registered with
National Housing Bank and is engaged in the
business of housing finance.
4. IIFL Insurance Brokers Limited (IIBL)
IIIBL is a wholly owned subsidiary of IIFL Holdings
Limited. It is registered with Insurance Regulatory
Development Authority as Direct Broker for providing
insurance broking services.
5. IIFL Management Services Limited (IMSL)
The Company was corporate insurance agent and
had discontinued its business upon the
group entity becoming direct insurance broker in
November 2008.
6. IIFL Commodities Limited (ICL) (Formerly
known as India Infoline Commodities Limited)
IICL is a wholly owned subsidiary of IIFL Holdings
Limited. IICL is engaged in business of Commodities
broking and holds trading and clearing membership
of commodity exchanges i.e. Multi Commodity
Exchange of India Ltd (MCX), National Commodities
and Derivatives Exchange Limited (NCDEX), National
Spot Exchange Limited
7. IIFL Wealth Management Limited (IIFLW)
IIFLW is a public limited company incorporated under
the Companies Act, 1956. IIFLW is registered with
SEBI as Portfolio Manager. It provides Portfolio
Management Services to the high net worth clients
(HNI segment). It acts as wealth managers,
investment manager, assetmanager, financial
consultants, management consultants, advisors and
provides consultancy,
advisory, counseling services, financial services and
facilities of every description and to manage and
mobilize funds and assets of various companies,
mutual fund, individual Investors,
firms, associations and other corporate bodies,
private and institutional investors. The Company is
registered with SEBI having Stock Broker, Research
Analyst, Depository Participant,
Investment Advisor and Portfolio Management
License and registered with AMFI as a distributor of
mutual funds.
8. IIFL Securities LIMITED (Formerly known as
India Infoline Limited)
India Infoline Limited is one of India’s premier
providers of financial services. The Company offers
advice and execution platform for the entire range of
financial services covering
products ranging from Equities and derivatives,
Commodities, Portfolio management, Fixed deposits
and other small savings instruments.
9. IIFL Distribution Services Ltd (Formerly
known as IIFL Distribution Services Private
Limited)
IIFL Distribution Services Limited (“the Company”) is
a public limited company incorporated under the
Companies Act, 1956 and is a wholly owned
subsidiary of IIFL Wealth Management
Limited. The Company is engaged in distribution of
mutual funds and also engaged in providing
manpower services to its associate companies.
10. IIFL Investment Adviser and Trustee
Services Ltd. (Formerly known as IIFL Trustee
Services Ltd.)
IIFL Investment Adviser and Trustee Services Limited
(formerly known as IIFL Trustee Services Limited)
(“the Company”) is a public limited company
incorporated under the Companies Act,
1956 and is a wholly owned subsidiary of IIFL Wealth
Management Limited. The Company is registered
with SEBI as an Investment Advisor and inter alia
provides Investment Advisory services. The Company
is mainly engaged into undertaking and carrying on
the office or offices
and duties of Trustee, custodian trustee, executor,
administrator, liquidator, receiver, attorney or
nominee of, or for funds and assets of all holders
including corporate bodies, high net worth
individuals (HNI’s), Hindu Undivided Family (HUFs),
Private or Public Trusts, Mutual Funds, offshore funds,
pension funds, superannuation funds, provident
funds, venture capital funds,
private equity funds and to hold the property in trust
for the benefit of the beneficiaries of the Trust.
11. IIFL Wealth Finance Ltd. (Formerly known
as Chephis Capital Markets Ltd.)
IIFL Wealth Finance Limited (formerly Chephis Capital
Markets Limited) (“the Company”) is a public limited
company incorporated under the Companies Act,
1956 and is a systemically important non-deposit
accepting Non-Banking Financial Company (“NBFC
ND-SI”) registered
with the Reserve Bank of India (RBI) under section
45-IA of the Reserve Bank of India Act, 1934 having a
valid certificate of registration dated March 18, 1998
bearing registration no. B-
13.00361 enabling the Company to carry on business
as Non-Banking Financial Company, andprimarily
engaged in the financing and related activities. IIFL
Wealth Management Limited acquired 100% equity
shares capital of the Company on February 13, 2016.
The Company offers broad suite of financial products
such as loan against securities, loan against
property/
mortgage loans, etc. to Corporate and High Net
worth clients and the Company is registered with
Insurance Regulatory and Development Authority of
India (IRDA) having license of
Composite Corporate Agency.
12. IIFL Alternate Asset Advisors Ltd.
IIFL Alternate Asset Advisors Limited (“the
Company”) is a public limited company incorporated
under the Companies Act, 1956. The Company is
engaged in the business of arranging and distribution
of various classes of assets including financial
products, real estate, wealth management and
private asset management. The Company was acting
as Investment Manager to IIFL Venture Fund, IIFL
Private Equity Fund and IIFL Opportunities Fund,
Category I, II and III-Alternative Investment Funds
registered with SEBI and IIFL Real Estate Fund
(Domestic) – Series 1, a scheme launched by India
Infoline Venture Capital Fund. The Company has
ceased its investment managing activities from 1st
March, 2014. The Company acts as
Investment Manager to schemes of Alternative
Investment Fund and has registration from SEBI for
Portfolio Management Services, Alternative
Investment Fund and Registration from
Real Estate Regulatory Authority for Real Estate
Agent Service. 13. IIFL Trustee Ltd. (IITCL)
IIFL Trustee Limited (formerly India Infoline Trustee
Company Limited) (‘Company’) is a public limited
company incorporated under the Companies Act,
1956. The Company is a 100% subsidiary of IIFL
Wealth Management Limited and it acts as a Trustee
to IIFL Mutual Fund and IIFL Alternative Investment
Funds.
14. IIFL Asset Management Ltd. (IIAML)
IIFL Asset Management Limited (formerly India
Infoline Asset Management Company Limited) (“the
Company”) is a public limited company incorporated
under the Companies Act, 1956. The Company is
registered with Securities and Exchange Board of
India (SEBI) under the SEBI (Mutual Funds)
Regulations, 1996 (‘the Regulations’) and acts as an
investment manager to ‘IIFL Mutual Fund’. Pursuant
to Regulation 24(b) of the Regulations, SEBI gave its
No Objection to the Company to undertake
Investment Management and Advisory Services to
pooled assets including Alternative Investment Funds
/ Offshore Funds and to undertake Portfolio
Management Services. Pursuant to the same, the
Company acts as an Investment Manager to the
Alternative Investments Funds and Venture Capital
Fund. The Company has
also obtained Portfolio Management services license
from Securities Exchange Board of India (SEBI) and
carries out the said services. The Company has also
obtained IIFL Real Estate
Investment Trust registration certificate from SEBI.
15. IIFL Asset Management (Mauritius) Limited
[Formerly known as IIFL Private Wealth
(Mauritius) Ltd.]
The Company is a wholly owned subsidiary of IIFWL,
it is incorporated in Mauritius. It is engaged in
distribution and advisory services for financial
products. The Company is registered with Securities
& Exchange Board of India as Category II Foreign
Portfolio Investors and has holds Collective
Investment Manager License and Investment Advisor
License Investment Distribution of Financial Products
and is also AMFI Registered Mutual Fund Advisory
(ARMFA).
16. IIFL Private Wealth (Suisse) SA.
The Company is a wholly owned subsidiary of IIFWL.

17. IIFL INC.

The Company is a wholly owned subsidiary of IIFLW. It
is incorporated in USA and engaged in providing
financial services. It is registered as Investment
Advisor with Securities and Exchange Commission,
US and as Foreign Portfolio Investor in India with
Securities & Exchange Board of India.
18. IIFL Private Wealth Management (Dubai)
Ltd.
The Company is a wholly owned subsidiary of IIFWL.
It is incorporated in Dubai. It is regulated by Dubai
Financial Services Authority and is engaged in
Advising on Financial Products or Credit and
Arranging Credit or Deals in Investment.

19. IIFL Private Wealth Hong Kong Ltd.

The Company is a wholly owned subsidiary of IIFWL.
It is incorporated in Hong Kong and engaged in
dealing and advising securities.
20. IIFL (Asia) Pte. Ltd. (IIFAPL)
Is a subsidiary of IIFL Wealth Management Limited
and Holding Company of IIFL Capital Pte. Ltd and IIFL
Securities Pte.Ltd.
21. IIFL Capital Pte Ltd.
It is the wholly owned subsidiary of IIFAPL
incorporated in Singapore and is a Licensed Fund
Manager.
22. IIFL Securities Pte Ltd.
It is the wholly owned subsidiary of IIFAPL. The
Company is incorporated in Singapore and it deals in
securities and exempt financial advisor and has
received Capital Market Service (CMS)
License from the Monetary Authority of Singapore.
23. India Infoline Media and Research Services
Limited (IIMRSL)
IIMRSL is a wholly owned subsidiary of IIFL Holdings
Limited. It is carrying on the business of media,
research and financial content services.
24. 5paisa Capital Limited (5paisa)
5Paisa is a wholly owned subsidiary of IIFL. 5paisa is
a Trading Member of BSE Limited and National Stock
Exchange of India Limited.
25.5paisa P2P Limited (5paisa P2P)
5paisa P2P Limited is a public limited company
incorporated under the Companies Act, 2013and is a
wholly owned subsidiary of 5paisa Capital Limited. . It
proposes to engage in Non-
Banking Financing Activities.

26. IIFL Facilities Services Limited (Formerly

IIFL Real Estate Limited) (IFSL)
IFSL is a wholly owned subsidiary of IIFL. The
Company is engaged in business of leasing of
property for its group companies and intermediation
in buying, selling of properties.
27. IIFL Asset Reconstruction Limited (IIFLARC)
IFLARC is a subsidiary of IIFL. It proposes to engage
in asset reconstruction and securitization business.
28. India Infoline Foundation
It is a Section 8 company under the Companies Act,
2013 and is engaged in CSR activities.
29. IIFL Wealth (UK) Ltd
It is a wholly owned subsidiary of IIFL. The Company
is incorporated in London and engaged in
providing financial services.
30. IIFL Capital Inc
The Company is a wholly owned subsidiary of IIFL. It
is engaged in the business of Advisor and Financial
Services.
31. Samasta Microfinance Limited
Samasta Microfinance Limited is a subsidiary of India
Infoline Finance Limited registered with RBI and
engaged in the business of Microfinance activities.
32. Ayusha Dairy Private Limited
Ayusha Dairy Private Limited is a Wholly-owned
Subsidiary of Samasta Microfinance Limited.
Currently, there are no operations in this Company.
33. Clara Developers Private Limited
Clara Developers is the Wholly-owned Subsidiary of
India Infoline Finance Limited.

34. IIFL Capital (Canada) Limited

IIFL Capital (Canada) Limited is a Wholly-owned
Subsidiary of IIFL Wealth Managemen Limited.
Currently, there are no operations in this Company.
IIFL Capital (Canada) Limited is
seeking exempt market Dealer License from Ontario
Securities Commission.
IIFL GROUP CODE OF CONDUCT
1. PREAMBLE
(i) This Code of Conduct is a statement of the IIFL’s
commitment to integrity and the highest standards of
ethical practices.
(ii) It defines the standards of conduct that is
expected of all employees in order that the right
decisions are taken in performing roles and
responsibilities across various functions in the
company.
(iii) The Code is intended to be the charter for day-to-
day work to enable employees to make the right
decisions and, therefore, serves to
a) Underline the fundamental commitment to
compliance with regulatory guidelines and laws of
the land.
b) Set forth basic parameters of ethical behaviour.
c) Establish a system for detection and reporting of
known or suspected ethical or violations of
regulation.
(iv) Since we are committed to continuous reviewing
and updating of policies and procedures, this Code is
also subject to modifications.
(v) The principles enshrined under the Code are
inclusive in nature and the various circulars or
directions issued by the management of IIF Group
and must be read along with and constitute a part
and parcel of this Code.

2. APPLICABILITY OF THE CODE

(i) This Code of Conduct is applicable to all the
Employees and officers of India Infoline Limited and
its Group Companies [“IIFL Group”].
(ii) IIFL Group expects all its employees and officers
to act in accordance with high professional and
ethical standards. You must be, and be seen to be,
committed to integrity in all aspects of your activities
and comply with all applicable laws, regulations and
internal policies.
(iii) In accepting a position with IIFL Group or any of
its subsidiaries, each of you become accountable for
compliance with the law, with the IIFL Group Code of
Conduct (‘the Code’), and with policies of your
respective businesses.
(iv) The standards of the Code are not necessarily
prescribed by the regulators - they are something,
which a well respected institution must have in place
and adhere to on an ongoing basis. We therefore
expect a high level of ethical conduct.
(v) While covering a wide range of business practices
and procedures, these standards cannot and do not
cover every issue that may arise, or every situation
where ethical decisions must be made, but rather set
forth key guiding principles that represent IIFL
Group’s policy.
3. VALUES
(i) Fairness, Integrity and Transparency (FIT) is the
driving force behind all that we do here at IIFL. We
only work with the people who fit into our
professional ethos.
a) Fairness
Fairness in our transactions with all stakeholders
including employees, customers, and vendors, bereft
of fear or favour.
b) Integrity
Integrity and honesty of the utmost nature, in letter,
in spirit, and in all our dealings with people, internal
or external.
c) Transparency
(i)Transparency in all our dealings with stakeholders,
media, investors, and the public at large.
(ii) We have come this far solely based on our core
values serving as a moral compass in all our
dealings. Our constant endeavour is to deliver
befittingly on all fronts to all our stakeholders. We are
resolute in the observance of these values and will
let go of any growth opportunities that deem unfit.
4. PROTECTION OF PROPRIETARY INFORMATION
(i) Any information concerning the Company’s
business, its customers, suppliers, etc., which is not
in the public domain and to which the employees or
officers has access or possesses such information
must be considered confidential and held in
confidence unless specifically authorized to do so
and when disclosure is required, as a matter of law
and shall not be used by him or her for his or her
personal gain or
advantage.
(i) Unauthorized use or distribution of proprietary
information violates the internal policies of IIFL Group
and could be illegal. Such use or distribution could
result in negative consequences for both IIFL Group
and the individuals involved, including potential legal
and disciplinary actions.
(ii) Acts of ignorance that could lead to leakage of
such proprietary information, especially through
electronic means – like e-mails, web uploads,
removable media (e.g. CD/DVD/pen drive) etc., may
lead to investigation and probe against the
employees.
(iii) It is your responsibility to protect proprietary and
confidential information (sensitive in nature)
pertaining to the Company or its customers in a
manner commensurate with its classification as per
the principles enunciated in the Information Security
Policy, Standards & Procedures of IIFL Group .
(iv) IIFL Group reserves the rights to monitor its
employees’ activities on IIFL companies owned
assets.
(v) We, at IIFL Group, respect the proprietary rights of
other companies and their proprietary information
and require you also to observe such rights.
5. MAINTAINING BUSINESS RELATIONSHIPS AND
FAIR COMPETITION
(i) IIFL Group is committed in dealing with external
stakeholders such as customers, competitors,
suppliers, and any related agency that is based on
the principles of fair competition, compliance with
laws and regulations of the land, and in the spirit of
honesty and integrity of our corporate values.
(ii) While maintaining a competitive outlook in the
market, we practice the following:
a) Following transparency in all of our business
dealings
b) Conducting business in accordance with applicable
laws and regulations
c) Respecting the confidentiality, privacy and
intellectual property of external stakeholders
d) Transfer of accurate and complete information
from and to our customers while complying with
internal proprietary policies, data protection laws and
any contractual obligations
e) Avoiding conflict of interest in business dealings
for the customer whose assets we manage. This
includes having controls to minimise and resolve
potential conflicts
f) Fair hearing to any concerns from our customers
while acting promptly on the resolution. If the
complaint involves data privacy or an accounting or
auditing matter, special measures will be followed.
g) In terms of supplier relationship, the IIFL Group
protocols on pricing quotation, SLAs, quality of
services or goods or any other related matter will be
followed in compliance with internal and external
rules or be subject to other internal restrictions or
disclosure obligations under securities or other laws.
6. FAIR DEALING:
(i) You must respect fair business practices in
jurisdictions where you operate and endeavour to
deal fairly with IIFL Group's customers, suppliers,
competitors as well as internal customers. You should
not take unfair advantage of anyone through
manipulation, concealment, abuse of confidential
information, misrepresentation of material facts, or
any other unfair dealings.
(ii) To maintain the spirit of fair dealings with any
external body, You shall refrain from the following:
a) Engaging with any third party known to be
involved in manipulative or concealing market
practices (fixing prices, allocating sales markets,
exclusive dealing with vendors) or with
activities that threaten public order or safety.
b) Payment, acceptance, offer, or authorisation of
money, gifts, or any other forms of bribe and
corruption with the customers.
c) Offering of anything of value to external
stakeholders that could be construed as requiring or
influencing any official decision and would give an
impression of either obtaining or retaining business,
suggesting that any business or service may be
withdrawn or awarded in return for other business or
securing an improper advantage vis-a-vis other
organizations in the market.
7. MAINTAINING TRANSPARENCY AND CO-
ORDINATION WITH GOVERNMENT REGULATORS
(i) All employees are expected to be responsive, fair
and transparent with officers from regulatory,
legislative or administrative bodies. The IIFL Group
maintains a candid and
proactive relationship with its regulators.
(ii) Utmost co-operation with the regulators and
thorough understanding of the regulators’ mission,
perspective and processes in alignment to IIFL Group
internal policies and procedures is of key importance.
(iii) IIFL Group is committed to following applicable
laws, rules, and regulations of all localities, states,
and countries where we do business, is not only the
right thing to do, it helps maintain and protect our
reputation.
(iv) This includes appropriately communicating
significant corporate developments and actions to
relevant regulators.
(v) Responses to regulatory information requests
should be completed accurately within the agreed
time frame as per the internal policy guidelines and
external regulations and must be safeguarded for
delays, if any, by keeping the internal and external
authorities in loop.
(vi) All employees are also required to co-operate
and report (and not withhold or misrepresent any
information) for any violations of regulations, laws,
internal processes, contract requirements, guidelines,
etc., in any investigation as an involved party,
witness or in terms of role responsibility.
(vii) It is prohibited to disclose any aspect of
investigation to any persons (either within our
outside the organization) and maintain confidentiality
of the situation.
(viii)Making false statements, misleading internal or
external auditors, investigators, legal counsel, other
employees, regulators or other governmental entities
can result in severe
penalties.
(ix) As an employee, you are expected to support this
commitment and to serve IIFL Group best interest by:
a) Being responsible for ensuring that conduct in our
activities are in accordance with the principles
mentioned in the regulatory bulletins, circulars,
advisories, manuals, checklists, and other guidance
inclusive of statutory compliance and risk
management guidelines.
b) Discourage lobbying activities that attempts to
influence or defeat the legislation on behalf of the
IIFL Group.
c) On suspicion of any untoward activities relating to
conduct and relationship with regulators, promptly
bringing to the notice of the compliance officials.
8. CHARITABLE CONTRIBUTIONS, CIVIC
ACTIVITIES & SPONSORSHIPS
Any personal activities related to charitable and/or
educational activities should not interfere or in any
way conflict with your work or with the IIFL Group in
any manner. When associated
with a charity or civic activities in your personal
capacity, it has to be ensured that there is no implied
or presumed support of the IIFL Group.
9. PARTICIPATING IN TRADE ASSOCIATIONS,
CONFERENCES AND SPEAKING ENGAGEMENTS
Meetings at professional gatherings, trade
associations or conferences activities should not
interfere or in any way conflict with your job duties or
with the IIFL Group in any manner and
may not be undertaken without the approval of the
authorised personnel. There may be instances of
contact with competitors for which you must follow
the rules related to fair competition referenced in this
Code and company policies.
10. POLITICAL ACTIVITIES & CONTRIBUTIONS
(i) No employee shall take an active part in politics,
represent in a political party and contest for election
anywhere outside the IIFL Group and shall not involve
other employees, clients, suppliers, vendors or any
other party with whom the company does business.
(ii) Employees may not contribute or solicit political
contributions, the IIFL Group Companies’ funds or
assets, resources to any political candidate, party, or
similar organization; unless such contribution is
expressly permitted by law/ regulation / directive and
has been pre- approved by the appropriate
authorized representative of the IIFL Group. Under no
circumstances will the IIFL Group directly or indirectly
reimburse any employee for their individual
contributions.
(iii) Volunteering of personal services during IIFL
Group working hours on behalf of a candidate,
lobbying or engaging in any outreach to public
officials, including attempts to influence
legislation, government agencies, etc. is prohibited.
11. WORKPLACE CONDUCT
(i) Respect for Individuals and Fair behaviour and
Employment Practices
a) All employees are expected to practice our Code
of Conduct and maintain professionalism, integrity,
mutual respect and fairness in our daily course of
business and relationship with colleagues or any
other point of contact (internal or external).
b) All Employees must treat their colleagues and
business associates with dignity and respect,
irrespective of caste, creed, gender, religion / region,
nationality, appearance or any disability.
c) Employees must not use abusive and offensive
language or any kind of gestures with their
colleagues or business associates.
d) Employees must not engage in any activity that is
likely to result in disturbing the peace and harmony
of the workplace.
e) We aspire to be a meritocratic organization
wherein employees continuously and consistently
strive to demonstrate excellence and initiative.
f) We, therefore, are committed to providing
employees with the best opportunities to realize their
potential and an environment where diversity is
embraced.
g) At all times, we must treat our teammates with
respect, share the responsibility for our successes
and accept accountability for our failures.
h) Employees are prohibited from creating situations
which are threatening, intimidating, hostile,
spreading false rumours or display abusive behaviour
in the workplace. We should strive to maintain a
disciplined, ethical, healthy and productive work
environment and resolve any conflicts in an amicable
manner.
i) Respectful workplace concerns escalated by
employees and/ or customers will be taken seriously
and dealt with promptly.
j) You should refrain from favouritism and making
business decisions on emotions. All employees
should also honestly disclose any information on
family or relatives who work at the IIFL Group.
k) No employee shall use his position or influence
directly or indirectly, to secure employment for his
son, daughter or any other member of his family in
any private undertaking having official dealings with
the company (this will include the IIFL Group
borrowers, contractors, consultants and vendors).
l) As an IIFL Group, we seek to maintain an inclusive
diversity of our staff across branches and
departments and recruit, develop and retain highly
qualified, diverse and dedicated individuals for our
workforce. The equal employment opportunity
principles are based on fair employment regulations
and non-discriminatory practices at workplace.
(ii) Harassment and Discrimination
a)Harassment is an undesirable verbal or physical
behaviour that interferes with work or creates an
intimidating, hostile or offensive work environment.
Examples include:
 Public or private tirades or bullying by a
supervisor, subordinate, or peer Severe or
 repeated insults related to personal or professional
competence
 Threatening or insulting oral or written comments
 Deliberate desecration of religious, racial, ethnic, or
national symbols
 Malicious and knowingly false complaints against
others.
b) We prohibit from any discrimination (race, gender,
caste, religion, disability, marital status, pregnancy,
culture, ancestry, socioeconomic status etc.) while in
employment or advancement. The IIFL Group
promotes a work environment where employees are
valued and not discriminated on the basis of any
reason. We prohibit discrimination or harassment of
any nature that violates our policies, whether
committed by or against a manager, co-worker,
client, supplier or visitor.
c) The IIFL Group prohibits uses of its
communications, equipment, systems and services,
including e-mail services and/or intranet/Internet
services, to create a hostile, discriminatory, or
offensive work environment. This includes
downloading, transmitting, viewing or exchanging
“jokes,” pictures, stories, videos or other
communications or content which are threatening,
harassing, demeaning or offensive to any individual.
(iii) ZERO TOLERANCE POLICY
a) The IIFL Group has a “zero tolerance” policy for
any violation of the Code of Conduct. This means
that when an occurrence of a violation has been
verified, appropriate action commensurate with the
nature and pervasiveness of the violation will be
taken.
Employees who violate the Code may be subject to
disciplinary actions, up to and including termination.
b) The following behaviours at work or activities
while using IIFL Group systems are examples of
actions that are prohibited and can result in
disciplinary action:
Sending or posting discriminatory, harassing, or
threatening messages or images through the IIFL
Group internal mails and/or through internet or any
other mode of communication.
 Using the IIFL Group time and resources for
personal gains.
 Unauthorised use of employee code including
password of self or any other employees/staff.
Sharing of user ID /password of each other. (Both
the employees involved shall be held equally liable
for any disciplinary actions) Copying, pirating, or
downloading software and electronic files without
permission.
 Engaging in unauthorized transactions that may or
may not incur a cost to the organization.
 Participating or carrying out any activity that may
damage the image or reputation of the IIFL Group.
 Participating in the viewing or exchange of
pornography or obscene materials.
 Attempting to break /hack into the computer
system of the IIFL Group and or any another
organization or person.
 Suppressing or misrepresentation of facts.
 Refusing to cooperate with investigation.
 Sending or posting chain letters, solicitations, or
advertisements not related to business purposes
or activities.
 Using the IIFL Group internet/ intranet for
promoting political causes or activities, religious
activities, or any sort of gambling.
 Destroy records that are potentially relevant to a
violation of law or any litigation or any pending,
threatened or foreseeable government
investigation or proceeding.
 Sending anonymous e-mail/SMS messages.
 Engaging in any other illegal activities.
 Working under the influence of alcohol or drugs.
 Fighting or threatening violence in the workplace.
 Spreading rumours and un-authenticated
information
 Use of foul language in any written or verbal
communications within the workplace.
 Negligence or improper conduct leading to
damage of property or properties of the IIFL Group
or customer.
 Insubordination or other disrespectful conduct with
colleagues, customers etc.
 Smoking in the workplace at non-designated areas
and Chewing of Pan Masala or any tobacco
products.
 Possession of dangerous or unauthorized
materials, such as explosives or firearms, etc., in
the workplace.
 Absenteeism, overstaying leave or leaving
workplace without permission or absence from
work without notice/ approvals.
 Unsatisfactory performance at work or loss of
confidence.
 Data theft or pilferage or any dishonest act.
 Refusing reasonable directions including moderate
changes in responsibilities that may from time to
 time be given on account of business necessity
and exigencies.
 Violation of any of the provisions of the security
policy including IT security policy of the IIFL Group.
 Failure to perform duties with utmost integrity,
honesty and diligence.
 Submitting and claiming false bills for
reimbursement. Overstating expenditure
vouchers.
 Violation of the IIFL Group Dress Code.
 Violation of the IIFL Group Mobile Phone Policy.
 Failure to carryout due diligence in any
deal/transaction to avoid any possibilities of a
fraud or money laundering.
 Refusing a reasonable request to moderate
changes in responsibilities if such a change is a
business necessity.
 Fudging or abetting fudging of attendance records.
 Poaching existing client and employees to our
competitor.
 Engaging in any other business/
employment/associations/ engagement for
commercial gains, while in the employment of the
Company without the written approvals of the
Management.
 Indulging in unauthorised/ unlawful / criminal acts,
like forging of client documents (e.g. Customer's
Insurance/ broking application form/ KYC-
supporting documents such as identity/ birth
proof).
 Trading in customer account without customer
consent.
 Fraudulent and incorrect reporting of customer
meetings or sales or business data.
 Multiple instances of being late for office/
customer meetings without reasons.
12. CODE OF CONDUCT FOR INSIDER TRADING
(i) While undertaking personal investments, it should
be borne in mind that such investments should not:
a) Affect or appear to affect your ability to make
unbiased business decisions for IIFL Group and its
subsidiaries;
b) Be contrary to IIFL Group's interests (e.g. using
proprietary knowledge obtained through the course
of employment to make investments that are not in
the best interest of the IIFL Group);
(ii) All employees should ensure strict compliance
with the code.
(iii) The code is applicable to all employees of IIFL
Group and its subsidiaries and affiliates Companies.
(iv) The code and trading restrictions are also
applicable to all connected persons like immediate
relatives, consultants for special assignments,
auditors etc engaged by the company.
(v) All employees and connected persons should
ensure confidentiality and be careful while handling
Unpublished Price Sensitive Information (UPSI). All
information should be disclosed only on ‘Need to
Know’ basis.
(vi) During the period when the employee is in
possession of UPSI, no trading is permissible by the
employees in that particular security;
(vii) Employees shall not trade in securities when the
trading window is closed, except for exercise of stock
options;
(viii)The minimum holding period of securities and
contra trade restriction applicable as mentioned in
the code available on IWIN.
(ix) The disclosure requirement is required to be
adhered by the designated persons in the prescribed
format.
(x) The code is effective from May 15, 2015 and shall
continue to be in force unless specifically amended.
(For more details refer to “Policy on Insider trading”)
13. MANAGER AND LEADER RESPONSIBILITIES
(i) As a progressive organization, managers and
leaders have a special responsibility to demonstrate
our values through their actions. As Managers and
leaders, you must foster an environment of integrity,
honesty and respect. This includes creating a work
environment that is free from discrimination,
harassment, intimidation or bullying of any kind. You
must also ensure that all aspects of the employment
relationship are free from bias and that decisions are
based upon individual performance and merit.
(ii) As a Manager or senior leader, you are therefore
additionally accountable for the following:
a) To be thoroughly familiar with the
requirements of and the procedures established by
the Code and to exemplify the highest standards of
ethical behavior
b) To ensure that team members understand that
business results are never more
important than ethical conduct and compliance with
applicable law and the IIFL Group policies.
c) To ingrain the principles of the Code and
compliance with applicable laws, regulations, and
policies into your business unit’s practices.
d) To create a culture in which team members
feel comfortable asking questions and raising ethical
concerns without fear of retaliation.
14. SEXUAL HARASSMENT
(i) Sexual harassment is any unwelcome sexually
determined behaviour, such as:
a) Physical contact and advances
b) A demand or request for sexual favours
c) Sexually coloured remarks
d) Showing pornography and
e) Any other unwelcome physical, verbal or non-
verbal conduct of a sexual nature
(ii) The IIFL Group strictly prohibits any kind of sexual
harassment and takes allegations of sexual
harassment seriously. Employees will be subject to
disciplinary measures for sexual
harassment up to and including termination. Anyone
experiencing and reporting such unwelcome
behaviour should know that the matter will be
handled with the utmost sensitivity.
(For more details refer to “Policy on Sexual
Harassment”)
15. SAFE AND HEALTHY ENVIRONMENT
(i) The IIFL Group consider safety of employees as a
primary concern and strives to provide a safe and
healthy work environment and comply with
guidelines and applicable local laws or regulations
that govern workplace health and safety.
(ii) To ensure healthy, safe and secure working
environments, we must practise the following:
i. Strive to keep their own workplace and
surroundings clean and hygienic.
ii. take all reasonable measures to avoid putting
others' lives and health at risk by preventing
workplace accidents and injuries
iii. Give customers and colleagues adequate health
and safety information.
iv. You should be alert to individuals who are on
premises of the IIFL Group without proper
authorization and report any unusual activities being
conducted within the workplace to the Unit Head or
reporting authority
v. Ensure that visitors on company premises follow
the appropriate procedures to prevent unauthorised
access to materials, information or persons
vi. Should not possess, distribute, sell, transfer or use
alcohol, drugs, firearms or other items that could
adversely affect health, safety and security in the
workplace or in the working hours
vii. Take adequate measures to protect the integrity
of computer and information systems, including
password protection.
16. COMMUNICATION WITH MEDIA
Any official communication, verbal or electronic
(which includes speeches, interviews etc.) with
media and publishing houses, blog posts, websites,
agencies, books, articles, podcasts, web casts,
videos, can be undertaken only after specific
authorization by the Corporate Communications
department of the IIFL Group. Please be alert in
situations where you may be perceived as
representing the IIFL Group and do not make any
statements on behalf of the organization unless you
have been authorized to do so. You should also be
diligent while using social media like Twitter,
WhatsApp, External Face book (Non Internal
Company), YouTube, LinkedIn, etc. You should not
post a comment, provide any recommendation, or
endorse customers or vendors (either current or
former) in the social media unless you are authorized
to do so.
17. MANAGING PERSONAL FINANCES
(i) As a financial institution, the IIFL Group business
depends on public confidence in our ability to help
manage the financial affairs of others. In general,
your personal finances are private. However,
because you represent the IIFL Group, it is important
that you manage your personal finances in an
appropriate and prudent manner, avoiding instances
of excessive indebtedness or bankruptcy. Any
improper handling of your personal finances
could undermine your credibility and the IIFL Group.
It could also cause others to question your decision-
making on the job.
(ii) You must refrain from any personal financial
transaction with fellow employees, customers or
suppliers, whether borrowing or lending. You must
not lend personal funds to, co-sign, endorse,
guarantee, or otherwise assume responsibility for the
borrowings of any customer or vendor of the IIFL
Group.
18. PROTECTION OF IIFL GROUP COMPANIES’S
ASSETS
Protecting IIFL Group Companies’s assets against
loss, theft or other misuse is the responsibility of
every employee and officer. Loss, theft and misuse of
IIFL Group Companies’s assets directly impact our
profitability. Any suspected loss, misuse or theft
should be reported to your supervisor.
19. BRIBERY AND CORRUPTION
(i) Bribery / Corruption are defined as receiving or
offering of an undue reward from / to any third party.
Employees must note that the IIFL group follows zero
tolerance approach towards bribery and corruption.
(ii) Employees must not make / receive any payment
to / from anyone including any government / public
servant for the purpose of obtaining or retaining
business or for obtaining any favorable action.
Bribing a public servant can attract severe criminal
penal consequences both for IIFL as well as for its
Employee(s) responsible for bribing under the
Prevention of Corruption Act, 1988. (For more details
refer to “Policy on Bribery and Anti-Corruption”)
20. GIFTS AND ENTERTAINMENT
Employees must not accept gifts or cash equivalent
from vendors, suppliers, customers or any such third
party, which will result in any violation of law or
commitment to mutual respect.
Acceptance of gifts that are in the nature of
promotional items with the logo of the other party
and / or of nominal value, occasional business meals,
celebratory events and entertainment, provided that
they are not excessive nor create an appearance of
impropriety, do not violate this Code.
(For more details refer to “Policy on Gifts)
21. KNOW YOUR CUSTOMER / ANTI- MONEY
LAUNDERING
(i) Employees must exercise requisite care in
selecting those with whom they conduct business.
While conducting business, Employees must adhere
to processes which are in place for checking the
credit and character of customers and counter
parties. These processes ensure adequate customer
due diligence and ongoing monitoring of their
transactions. This is also done to detect suspicious
transactions during the entire period of relationship.
(ii) Money Laundering legislations criminalize money
laundering in respect of all crimes including drug
trafficking, terrorism, theft, tax evasion, fraud,
handling of stolen goods, counterfeiting and
blackmail. It is also an offence to undertake and / or
facilitate transactions with individuals and entities
involved in criminal activities.
(For more details refer to “Policy on ANTI- MONEY
LAUNDERING”)

22. MAINTAINING THE ACCURACY OF COMPANY

RECORDS AND REPORTING REQUIREMENTS
(i) Data and information relating to the IIFL Group
that is publicly disclosed or is provided to regulators
should be complete and accurate. IIFL Group is
committed to integrity of
financial reporting and complete disclosures as
mandated under applicable law and regulation.
Falsification of any information or data (i.e. mis-
statement, alteration, modification, omission or
deleting of information) related to the IIFL Group is a
serious
misdemeanour and is prohibited.
(ii) You must ensure that records, data and
information owned, collected, used and managed by
you for IIFL Group are accurate and complete.
Records must be maintained as per the applicable
record retention policy of your Company in sufficient
detail so as to reflect accurately the company's
transactions.
ETHICS & INTEGRITY
1. At IIFL, we hold ourselves to high standards of
personal and institutional integrity in
ourcinteractions with customers,
members,employees, partners, and other
stakeholders, including
2. Highest standards of ethical and moral conduct in
all their acts on duty as well as when not on duty.

3. We consider unethical or immoral conduct as a

serious violation of terms of employment, even if
committed when the individual is not at the
workplace or is not on official duty. Such cases
shall be taken seriously by IIFL. As a company, we
can live with errors and mistakes done in good
faith but can never condone lack of honesty and
integrity, even if there is no monetary damage.

4. The code of conduct is applicable to all employees

uniformly irrespective of tenure, stature and
seniority in the organization and nobody can claim
immunity from action due to deviation from ethical
standards.

IIFL CODE OF CONDUCT FOR INSIDER TRADING

IIFL Holdings Limited and its Subsidiaries

Code of Conduct for Employees and Insiders of IIFL Holdings Limited and its Subsidiary Companies
under SEBI (Prohibition of Insider Trading) Regulations, 2015

Introduction:
The Standards of Code of Conduct for employees and insiders set forth herein constitute the body of
rules and principles, which are to be followed in letter and spirit by each and every employee and
insiders of IIFL Holdings Limited [IIFLH] and its subsidiaries and Associates, (referred to as “IIFL
Group” for the purpose of this document and each of the entity is referred as “Company”) in order to
maintain highest standards of integrity, compliance, trust and confidence of the public, and good
reputation of the Company. Each employee and insider of the Company is responsible for conducting
job-related activities in a
manner that protects and enhances the Company’s reputation. He/she is also responsible for
encouraging and, where necessary, enforcing similar behavior on the part of his/her subordinates.
Employees of the Company at all levels are expected to inform and guide the employees under their
supervision and stand as an example for full compliance.
their supervision and stand as an example for full compliance.

Any misconduct that could cause legal, regulatory, and governmental or reputation risks for the
Company should be reported immediately, as far as possible, to the HOD/Compliance
Officer/Director. An employee or an insider who knowingly violates the policies and guidelines
contained herein shall be subject to action under this code as well as service rules of the Company
which may lead to disciplinary action including suspension, termination of services etc. IIFL Group
has been having Code of Conduct for employees in terms of SEBI (Prohibition of Insider Trading)
Regulations, 1992 and has been complying with the same. The said SEBI regulations have been
substituted with the new SEBI (Prohibition of Insider Trading) Regulations, 2015 issued onJanuary
15, 2015 and the clarification issued through Guidance Note issued on August 24, 2015 and April 12,
2016. Accordingly this document contains formal Policy and Code of Conduct for regulating,
monitoring and reporting of trading by Employees and insiders with reference to the SEBI
(Prohibition of Insider Trading) Regulations, 2015 as amended up to the date (hereinafter referred to
as “Regulations”). This policy and the Code of Conduct for employees shall be adhered to by all the
employees and insiders of the Company. This code of conduct (‘Code’) has been adopted by the Board
of Directors of IIFL Holdings Ltd. If administratively any minor changes are required in the Code, the
same shall be suitably implemented in consultation with the Managing Director/ Chairman /Chief
Compliance officer of the group chief Financial Officer/Company
Secretary of IIFL Holdings Limited. If at any time any employee or any insider of IIFL Group has any
question about the application of this Code of Conduct, it should be discussed in the first instance with
the Compliance Officer / HOD of respective companies. In addition to this any question of
significance, or unclear answers shall be referred to the Chief Compliance Officer of the Group.
Applicability:
1.1 i) This Code of Conduct is applicable to the following (referred as “Applicable Persons”]:

a) With respect to dealings in IIFL Group Listed Securities – All employees of IIFL
Holdings Limited, its Subsidiaries and Associates;

b) With respect to dealings in other than IIFL Group Listed Securities – All employees of Registered
market Intermediary entities of the Group (“IIFL Group Market Intermediary Entities”] namely:
(i) IIFL Holdings Limited
(ii) India Infoline Limited
(iii) 5paisa Capital Limited
(iv) India Infoline Commodities Limited
(v) IIFL Wealth Management Limited
(vi) IIFL Investment Adviser & Trustee Services Limited
(vii) IIFL Trustee Limited
(viii) IIFL Asset Management Limited
(ix) India Alternatives Investment Advisors Private Limited
(x) IIFL Capital Inc.
(xi) IIFL Inc.
(xii) IIFL Private Wealth Management (Dubai) Limited
(xiii) IIFL Private Wealth (Mauritius) Limited
(xiv) IIFL Asia Pte Ltd.
(xv) IIFL Wealth (UK) Limited
(xvi) IIFL Capital Pte. Limited
(xvii) IIFL Securities Pte Limited
(xviii) IIFL Private Wealth Hong Kong Limited
(xix) IIFL Private Wealth (Suisse) SA

c) Connected persons or persons who are in possession of or having access to Unpublished Price
Sensitive Information.

(ii) As IIFL Group entities through its separate subsidiaries/businesses are engaged in various
regulated financial services businesses in India and globally, independently servicing their respective
clients through broking, Depository Management/Investment Management of Mutual Funds,
Alternative Investment Funds, Venture Capital Funds, FPI /FII / Offshore Funds, Wealth Management
activities, Advisory, Distribution, Trustee Services etc through their separate set of staff/professionals
and requirements under the respective Regulations. The trading/investment restrictions with regard to
dealing in IIFL Holdings Limited or other IIFL Group Securities shall not be applicable to such third
party client centric activities/services rendered by such Group entities in their normal course of
business. However, the restrictions/set process on dealing in IIFL Holdings Limited or IIFL Group
Securities shall apply to the IIFL Group entities for their proprietary account dealings and IIFL Group
employee’s trades as per this Code and it should be complied with by all.