Policy Statement / Code of Conduct

All directors and employees are expected to understand the Code of Conduct as set forth below and abide by them to the best of their abilities in order to set the highest ethical practices and encourage the spirit of compliance across all levels in the organization.

  1. Follow the Code of Conduct by strictly adhering to the rules and procedures as approved by the Board.
  2. Strive and work diligently for providing extraordinary services to the valuable members of the Company and strengthen the operations of the Company
  3. Ensure shareholders satisfaction through excellent product and services; and place priority for redressing investor grievances and encouraging fair business practice, so that the clearing house becomes an engine for the growth of the securities market.
  4. Ensure that affairs of the Company are being carried out prudently with high business ethics in compliance to all applicable regulatory frameworks including but not limited to provisions of the Securities Act, 2015(Act), the Futures Market Act, 2016, the Clearing House (Licensing & Operations) Regulations, 2016 (Regulations), the Companies Act 2017, and other applicable rules, regulations, codes, guidelines, circulars and directions issued by the Commission from time to time.
  5. The directors and senior management officers shall participate in the formulation and execution of strategies in the best interest of the clearing house and contribute towards pro-active decision making; and shall not support any decision in the meeting of the Board which may adversely affect the interest of investors and shall report forthwith any such decision to the Commission;
  6. The directors and employees are required to ensure efficient and effective use of Company’s resources and give benefit of their experience and expertise to the clearing house and provide assistance in strategic planning and execution of decisions.
  7. The directors and senior management officers shall endeavor to ensure that the clearing house takes steps commensurate to honor the time limit stipulated by the Commission for corrective action.
  8. The directors and senior management officers endeavor to analyze and administer the clearing house issues with professional competence, fairness, impartiality, efficiency and effectiveness.
  9. No director and employee shall engage in any act involving moral turpitude, dishonesty, fraud, deceit, or misrepresentation or any other act prejudicial to the administration of the clearing house.
  10. The directors and employees must maintain the highest standards of personal integrity, truthfulness, honesty and fortitude in discharge of their duties in order to inspire public confidence and shall not engage in acts discreditable to their responsibilities.
  11. No funds or assets of the Company shall be established or maintained that is not reflected on the books and records of the Company.
  12. No transaction shall be effected and no payment shall be made by or on behalf of the Company with the intention or understanding that the transaction or payment is other than as described by the Company from time to time.
  13. The directors and employees shall adhere to the information security policies and procedures and shall not disclose confidential information, including commercial secrets, technologies advertising and sales promotion plans, unpublished price sensitive information, unless such disclosure is expressly approved by the board of directors or required by law.
  14. The directors and senior management officers shall submit the necessary disclosures/statement of holdings/ dealings in securities or futures contracts as required by the clearing house or the Commission from time to time as per their regulations or Articles of Association or any directives of the Commission;
  15. Unless otherwise required by law, maintain confidentiality and shall not divulge/disclose any information obtained in the discharge of their duty and no such information shall be used for personal gains;
  16. All directors and Senior Management must perform their duties in an independent and objective manner and avoid activities that may impair, or may appear to impair, their independence or objectivity or official duties.
  17. In any dealings with NCSS Elements, government officials, or other persons/entities, no officer or employee of the Company shall request, accept, or give any significant thing of value, the purpose or result of which could be to influence the bona fide business relationship between the Company and such persons or entities.
  18. Employees are restricted to engage in investment and trading of listed securities in Capital Market of Pakistan.
  19. The Company expects all employees to maintain good discipline at all times in order to promote a healthy atmosphere needed for the smooth conduct of business activities. Accordingly, employee must avoid all such acts deemed to indiscipline and / or misconduct as per Office Rule Book.
  20. Every director of the NCCPL shall endeavor to ensure that all items of the agenda of a meeting are properly discussed and if not, the said matter may be discussed in the next meeting to be is held within reasonable timeframe as the board of directors may determine for considering the remaining items; and endeavor to have the date of next meeting fixed at each board meeting in consultation with other members of the Board.
  21. The independent directors, in addition to the above stated clauses, shall ensure compliance of following clauses:
    1. Endeavor to attend all the board meetings and they shall be liable to vacate office if they do not attend fifty percent of the total meetings of the board of directors in a calendar year.
    2. Participate constructively and actively in the committees of the board in which they are chairpersons or members.
    3. Strive to attend the general meetings of the NCCPL; where they have concerns about the running of the NCCPL or a proposed action, ensure that these are addressed by the board and, to the extent that they are not resolved, insist that their concerns are recorded in the minutes of the board meeting;
    4. Keep them well informed about the affairs and matters of the clearing house and the external environment in which it operates.
    5. Pay sufficient attention and ensure that adequate deliberations are held before approving related party transactions and assure them that the same are in the interest of the NCCPL.
    6. Ascertain and ensure that the clearing house has an adequate and functional grievance resolution mechanism and to ensure that the interests of a person who uses such mechanism are not prejudicially affected on account of such use.
    7. Report concerns about unethical behavior, actual or suspected fraud or violation of the code of conduct of the NCCPL and acting within its authority, assist in protecting the legitimate interests of the NCCPL, shareholders and its employees.
  22. All NCCPL directors, employees, officers, executives shall abide by Conflict of Interest policy for directors and Conflict of Interest policy for employees; respectively.
  23. All NCCPL Employees and Directors shall be strictly prohibited from disclosing the fact to the customer / client that a Suspicious Transaction Report or related information is being or has been reported to Financial Monitoring Unit.


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