Law: Securities and Exchange Ordinance, 1969

Section: 15

Securities and Exchange Ordinance (XVII of 1969)--S. 15(E)---Insider trading---Scrutiny and examination of trading data of Automated Trading System of Stock Exchange, revealed that funds under the management of the company, traded heavily through its funds---Different funds administered by the company made a cumulative gain on sale of shares---Company, in response to notice, submitted its reply, wherein it was contended that company had no inside information regarding the sale of shares---Company had contended that the subject off market deal was offered by another company; and that it had no information regarding the identity of the seller---Said contention appeared to have no rational basis, as the structuring of such outsized deals usually required substantial time---Trading in question did not meet the standards of trading practices that was expected of a major participant in the market which had created doubts and suspicions and resulted in initiation of proceedings by the Commission---Transactions were structured in a way which had given impression of Insider dealing---Such dubious trading patterns and timing of trades, could lead to believe by the Regulator as interference in the fair and proper functioning of the market---Company was a well-reputed and prestigious Asset Management Company of the country; and high standards of conduct and compliance was expected of it---Company was reproached and censured for conduct, which did not commensurate with high standards of comfortment expected of the company--- Company was also warned to abstain from trading in such questionable manner in future, which created suspicions and doubts of insider dealing--- Management of the company was directed to ensure compliance of the laws in letter and spirit. ORDER IMRAN INAYAT BUTT, DIRECTOR/HOD (MSCID).---This Order shall dispose of the proceedings pertaining to the Show Cause Notice bearing No.1(3)INS/MSW/SMD/ 2012/AMIML-01 dated January 5, 2012 ("Notice") under section 15(E) of the Securities and Exchange Ordinance, 1969 ("Ordinance") served on Messrs Al Meezan Investment Management Limited ("AMIML") ("Respondent") through its Chief Executive. 2. The facts leading to…

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