SEC MSRD CASE NO. MSRD-MID-2020-2R&L INVESTMENTS, INC, VENTURE SECURITIES, INC. WILFRED RACADIO (President), ADORA AGUILAR (Associated Person), LORETO BALABIS (Salesman), TERESITA MOSENABRE (Settlement Head)

Exchange Securities and Commission

MARKETS AND SECURITIES REGULATION DEPARTMENT SPECIAL HEARING PANEL

IN THE MATTER OF:

R & L INVESTMENTS, INC. X

SEC MSRD CASE NO. MSRD-MID-2020-2

VENTURE SECURITIES, INC

ADORA AGUILAR (Associated Person) WILFRED RACADIO (President) LORETO BALABIS (Salesman) TERESITA MOSENABRE (Settlement Head

Respondents. X -X

June 11, 2021

To:

ASSISTANT DIRECTOR ADAN EVAN O. PASCUA Markets and Securities Regulation Department Securities and Exchange Commission Secretariat Building, PICC Complex Roxas Boulevard, Pasay City. BmtzNuY W NEctIVtO/yns NiCou 6764 Ayala Avenue, Makati City LORETO BALABIS 8th Floor STI Holdings Center CS(WO

8th Floor STI Holdings Center. 8th Floor STI Holdings Center. 6764 Ayala Avenue, Makati City WILFRED RACADIO 6764 Ayala Avenue, Makati City. VENTURE SECURITIES, INC. UEc'D BM 6-11M MAn R&uy 8th Floor STI Holdings Center 8th Floor STI Holdings Center, TERESITA MOSENABRE 6764 Ayala Avenue, Makati City. 6764 Ayala Avenue, Makati City. ADORA AGUILAR da Y I W

5th Floor, SGV II Building. 6758 Ayala Avenue, 1200 Makati City. HERRERA TEEHANKEE & CABRERA Counsel for Respondents -JERo ju Q!5 CHRAAPHER PASCUM

GREETINGS:

issued in the above-entitled case, the original of which is now on file with the Commission. Please take notice that on June 11, 2021, a Decision, copy hereto attached, was

SHP Chairman NG. FACUN

Securities and Commission Exchange P 1N

SECURITIES AND EXCHANGE COMMISSION REPUBLIC OF THE PHILIPPINES DEPARTMENT OF FINANCE PASAY CITY

MARKETS AND SECURITIES REGULATION DEPARTMENT SPECIAL HEARING PANEL

IN THE MATTER OF:

R & L INVESTMENTS, INC.

SEC MSRD CASE NO. MSRD-MID-2020-2

TERESITA MOSENABRE (Settlement Head VENTURE SECURITIES, INC. WILFRED RACADIO (President) ADORA AGUILAR (Associated Person) LORETO BALABIS (Salesman)

Respondents.

X

DECISION

Regulation Code ("SRC") and its 2015 Implementing Rules and Regulations ("2015 SRC Adora Aguilar, Loreto Balabis and Teresita Mosenabre for violations of the Securities Rules" or "SRC-IRR"), as follows: "Venture Securities"J) a corporation duly organized and existing under and by virtue of the laws of the Republic of the Philippines with office address at 8th Floor STI Holdings Center, 6764 Ayala Avenue, Makati City and its officers and employees, namely, Wilfredo Racadio, personnel of the Markets and Securities Regulation Department ("MSRD") of the Securities and Exchange Commission (the "Commission") charging Venture Securities, Inc. ("VSI" or 2020 of the Investigation and Review Committee ("IRC") composed of officers and Before the Special Hearing Panel ("SHP") is a Formal Charge dated September

Charges against Venture Securities

2) Rule 30.2.1.2.3. Capabilities 1) Rule. 30.2.1. Ethical Standards Rules

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7) Rule 52.1.6. Customer Account Information Rule 3) Rule 30.2.1.2.4. Information About Clients 4) Rule 48.2 - Prohibitions on Extension of Credit in relation to Rule 48.1 - Margin 5) Rule 50 - Purchases and Sales in Cash Account 6) Rule 52.1.1: Books and Records Rule

Charges against Mr. Wilfredo Racadio (VSI President)

8) Rule 52.1.1. Books and Records Rule 9) Rule52.1.6. Customer Account Information Rule 3) Rule 30.2.1.2.3. Capabilities 5) Rule 30.2.6. Supervision 7) Rule 50 - Purchases and Sales in Cash Account 1) Section 51 in relation to Section 26 of the SRC 2) Rule. 30.2.1. Ethical Standards Rules 4) Rule 30.2.1.2.4. Information About Clients 1 Rule 48.2 - Prohibitions on Extension of Credit in relation to Rule 48.1 -- Margin

Charges against Ms. Adora Aguilar (VSI Associated Person)

8) Rule 52.1.6. Customer Account Information Rule 5) Rule 30.2.6. Supervision 6) Rule 34 - Segregation and Limitation of Functions of Members, Brokers and Dealers 7) Rule 52.1.1. Books and Records Rule 2) Rule 30.2.1. Ethical Standards Rules 3) Rule 30.2.1.2.3. Capabilities 4) Rule 30.2.1.2.4. Information About Clients 1) Section26 in relation to Section 54 of the SRC

(VSI Salesman) Charges against Mr. Loreto Balabis

3) Rule 30.2.1.2.3. Capabilities 4) Rule 30.2.1.2.4. Information About Clients 5) Rule 52.1.6. Customer Account Information Rule 2) Rule 30.2.1. Ethical Standards Rules 1) Section 26 in relation to Section 54 of the SRC

(VSI Settlement Head) Charges against Ms. Teresita Mosenabre

2) Rule 52.1.1. Books and Records Rule 1) Section 26 in relation to Section 54 of the SRC

ANTECEDENT FACTS AND PROCEEDINGS

Case No. MP-2019-001 ordered the Capital Markets Integrity Corporation ("CMIC') to take On 14 November 2019, the Securities and Exchange Commission in SEC En Banc

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SRC and Rule 33.1.1.26.3 of the SRC-IRR. over the operations of R&L Investments, Inc. ("R&L"), pursuant to Section 33.1 (d) of the

payment of their share proceeds. of R&L rendering it incapable of meeting the demands of its client security holders and the The Take Over Order was issued due to the deterioration of the financial condition

Mosenabre on December 9 and 12, 2019. investigation of the incident to determine the various violations of the securities laws proceedings were conducted on 9 December to 12 December 2019. The IRC conducted a conference with VSI, Wilfredo Racadio, Adora Aguilar, Loreto Balabis and Teresita possibly committed and to institute, among others, the appropriate administrative charges against all the responsible persons, including VSI, its officers and employees. IRC separately to VSI, R&L, Marlo Moron and Julieto Sulapas, and the investigative Pursuant to the direction, MSRD created the IRC. Hence, subpoenas were issued by Consequently, the Commission directed the MSRD to conduct a thorough

resolved and decide matters relative to the case. On 5 February 2020, the SHP composed of the undersigned was created to hear,

respondents on 7 September 2020. dated September 2020 against the Respondents. The Formal Charge was received by the After conducting the investigation, the IRC formally instituted the Formal Charge

Briefly, the Formal Charge alleges that: 1. The deterioration of the financial condition of R&L was brought about by the fraudulent through EQ Trades1 from R&L to the Julieto Sulapas account in VSI; schemes allegedly committed by one Marlo Moron that resulted in the loss of allegedly Php700 million worth of client shares of R&L due to the unauthorized transfers

2 The CMIC report regarding VSI reveal that the transaction volume amounted to

SU026 and SU027) amounted to approximately 15% (buying) and 13% (selling) transaction of VSI for 2012 to 2019, with peak transactions of 25% buying (2016) and 21% selling (2016-2017). roughly 14% (buying) and 20% (selling) of all transactions of VSI clients for the period of 2012 to 2019, and even reaching to as high as 27% buying (2016) and 35% selling transactions (2017). As to value, the Julieto Sulapas accounts (Customer Account

3 The transactions of Julieto Sulapas in his VSI account amounting to

Customer Account Information Form ("CAIF") as of October 2017. Php4,602,939,508.50 and Sell Transactions worth Php5,302,514,824.70) per account ledger of Julieto Sulapas were grossly disproportionate to his declared total net worth, liquid net worth and annual income of less than Php 1 Million as reflected in his Php9,905,454,333.20 (which can be broken down into Buy Transactions worth

one broker to another broker. 1 EQ Trades are transactions for the transfer of equity securities or shares of stock from

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4 The account ledger of Julieto Sulapas reveals that Julieto Sulapas approximately had

2,800 buy transactions from 2012 to 2019 but Julieto Sulapas only made cash payments five times during the same period.

5 Respondent Balabis did not personally meet Julieto Sulapas at the time the latter

simply gave Marlo Moron a blank CAIF (without verification of the contents of the Julieto Sulapas CAIF). opened an account with VSI and did not see Julieto Sulapas fill out the CAIF himself but

6. Respondent Balabis did not make any inquiry or verification as to the transactions of

Worth and annual income declared in the CAIF amounting to PhP 1,000,000.00. from 2012 to 2019, per CMIC Report) in relation to the total net worth, liquid net Julieto Sulapas, despite the large amounts involved (roughly PhP 10 billion in total

7. The Associated Person Adora Aguilar likewise did not conduct any inquiry, verification and review of the Julieto Sulapas account transactions.

8. Respondent Mosenabre, as the settlement officer of VSI, did not make any inguiry intc authorized person of Sulapas is at the same time the settlement officer of R&L. the Julieto Sulapas EQ trade transactions knowing that Marlo Moron who is the

9. There are EQ Trades involving the Julieto Sulapas account without written request

and/or with unsigned requests. 10. Julieto Sulapas indicated in his CAIF that he does not have any other account with other broker dealers notwithstanding his existing account with R&L. 11. Respondent Aguilar did not require Julieto Sulapas to correct his answers in the CAIF Sulapas has an account with R&L. as to the existence of an account with other brokers even if she knew that Julieto

12. Marlo Moron was allowed by Respondents as authorized person of Julieto Sulapas to transact relating to the latter's account with VSI despite knowledge that Moron is a trading floor assistant/settlement clerk in R&L where the subject EQ Trades originated.

13. VSI officers relied on the confirmation of Marlo Moron as the alleged settlement officer of R&L for transactions that Marlo Moron himself instructed on behalf of Julieto Sulapas.

14. Certain "transfer in" requests in the account of Julieto Sulapas lack the signature of Sulapas.

15. The lack of action in the part of VSI, including its Associated Person Adora Aguilar and Salesman Loreto Balabis, revealed the lack of satisfactory internal control procedures in the "transfer in" transactions that ultimately led to the successful execution of the fraudulent schemes of Marlo Moron to the detriment of the clients of R&L Investments, Inc.

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16. VSI failed on its duty to be duly informed about the identity of Sulapas, including the client's financial situation, investment experience and objectives 17. The annual income of Julieto Sulapas is only Php 1 million but he was allowed to transact beyond his financial capability. 18. There were lapses in employing effective compliance functions in VSI by the Associated Person Adora Aguilar: 19. Respondent Aguilar was remiss on her duty to check all executed trades and other Sulapas as a margin account and comply with all the requirements of the SRC and SRC- transactions of the company for her failure to properly identify the account of Julieto IRR.

20. The Julieto Sulapas account does not comply with the Rules and Regulation of the Wilfred Racadio as the representative of VSI. Commission on margin accounts as enumerated under Rules 48.1 and 48.2 of the 2015 SRC-IRR. Despite such non-compliance, the credit line agreement was still signed by

21. Assuming arguendo that the account is indeed a cash account, the account ledger of purchases within T+3. Julieto Sulapas submitted by VSI however shows that Julieto Sulapas did not settle his

23. There are discrepancies on the number of shares between the Stock (In) CM, the Julieto 24. VSI failed to maintain and keep current complete set of its books and records in 22. Certain "transfer out" in the account of Julieto Sulapas lacks written request. Sulapas ledgers and the EQ Trade Form in the Julieto Sulapas account ledgers with VSI. violation of the SRC and its IRR. 25. VSI does not have a clear customer acceptance policies and procedures that were applied to Julieto Sulapas. 26. Respondent Wilfredo Racadio, as President, has failed to perform his duty to oversee the day-to-day operations of VSt. 27. Section 51 of the SRC makes Wilfredo Racadio jointly and severally liable with VSI officers and employees.

SRC-IRR as indicated in the Formal Charge. procedures, internal control procedures, record-keeping, and anti-money laundering procedures; and, (v) Respondents did not commit the alleged violations of the SRC and the requirements under the relevant laws and rules; (ii) vSI found nothing suspicious or irregular in the transactions of Mr. Sulapas in his account; (iii) Mr. Sulapas maintained a Cash Account with VSI; (iv) VSI maintains proper customer acceptance and KYC and Affirmative Defenses, that: (i) the creation of the Julieto Sulapas account followed the allegations of the charge, except those admitted and alleged the facts common to all Special The Respondents filed their Answer to the Formal Charge denying the material

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during the conference by themselves and/or as represented by counsel. A clarificatory conference was held on February 24, 2021. Both parties appeared

papers within ten (10) days from February 24, 2021 and to furnish each other with copies thereof. During the conference, the parties were directed to submit their respective position

submitted for resolution. position paper of the other party to file their comments/replies thereto. After the lapse of said date, with or without the position paper or comments/replies, the case was deemed Both were likewise given a period of five (5) days from receipt of the respective

allegations. Both parties also filed their comments/reply against each other's position submitted their respective position papers both substantially reiterating their arguments in their previous submissions and submitted additional documents to support their paper. Complainant and Respondents in compliance with the aforementioned order,

In its Position Paper, Complainants alleged and maintained the following:

Charge required under Section 10 of the Rules of Court. 1. The Respondents failed to specifically deny the material allegations in the Formal

the day to day operations of the Company. 2. Mr. Racadio is liable under Section 52 of the SRC since he has the duty to oversee

responsible officers and employees of VSI, including Mr. Racadio. the relevant laws and rules. the Company. In addition, the Take Over Order dated 14 November 2019 issued by the Commission effectively assigned to MSRD the authority to file administrative cases against 30.2.1.2.4.1, 30.2.1.2.4.3 and 30.2.1.2.4.6 is untenable. As President of the Company, he is an agent of the broker dealer (VSI) with the duty to oversee the day-to-day operations of 4. The creation of the Julieto Sulapas account did not follow the requirements under 3. The claim of Mr. Racadio that he cannot be held liable under SRC Rule 30.2.1.1.

5. Julieto Sulapas is not an active day trader.

6. The Julieto Sulapas Accounts in VSI are not Cash Accounts.

Sulapas accounts, and; control procedures, record-keeping, and anti-money laundering procedures on Julieto 7. VSI did not maintain proper customer acceptance and KYC procedures, internal

Charge. 8. Respondents committed violations of the SRC and the SRC-IRR in the Formal

On the other hand, Respondents in their Position Paper insisted and alleged, that:

the respondents from the alleged violations of the SRC and its IRR. 1. The Formal Charge failed to allege the ultimate facts showing any culpability of

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relevant laws and rules. 2. The Creation of the Julieto Sulapas account followed the requirements under the

account. 3. VSI found nothing suspicious or irregular in the transactions of Mr. Sulapas in his

4. Mr. Sulapas maintained a cash account with VSI.

internal control procedures, record-keeping, and anti-money laundering procedures. 5. VSI maintains proper customer acceptance and know-your-client procedures,

as indicated in the Formal Charge. 6. Respondents did not commit the alleged violations of the SRC and the SRC-IRR

In its comments, Complainant alleged that:

Respondents in their position paper pertaining to allegation of ultimate facts relates to civil cases and not applicable in administrative cases. 1. The cases cited (Ramitere v. Montinola and Zuniga-Santos.v. Santos-Gran) by the

which includes all the evidence and thorough explanations of the findings of the IRC. ultimate facts, the same have already been cured by the position paper of Complainant 2. Even if granting arguendo that the Formal Charge omitted to state the full

however, involves an administrative action from the determination of violations of laws, rule, regulations, circulars and orders that may have been violated by the Respondents. extant case since it involved an adjudicative action wherein the Commission was tasked to determine the rights and obligations of the opposing parties. The instant proceeding. 3. The Makati Stock Exchange v. Campos case is likewise not applicable in this

same were already found and discussed in its Formal Charge and Position Paper. Complainant countered that the allegations are untenable and without merit since the 4. With regard to the other allegations of Respondents in their Position Paper

In their reply, Respondents countered and argued that:

their factual allegation in their answer. already submitted in their Position Paper the documents and affidavits that would support 1. Respondents sufficiently denied the allegations of fact in the Formal Charge and

Racadio under the SRC and its IRR. 2. Complainant has failed to specify and establish the basis for the liability of Mr.

relevant laws and rules. 3. The creation of the Julieto Sulapas account followed the requirements under the

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Sulapas in his account to be suspicious or irregular. 4. Complainant failed to provide any basis for VSI to find the transactions of Mr.

5. Certain actions have already been'barred by prescription.

keeping, and Anti-Money Laundering Procedures on the part of VSI. acceptance and know-your-client procedures, internal control procedures, record- 6. Complainant has failed to demonstrate the absence of proper customer

Respondents to due process. 7. Complainant's presentation of Mr. Sulapas affidavits violates the rights of

alios acta as embodied under Section 31, Rule 130 of the Rules of Court; and, Affidavit cannot be used against Respondents in this case under the doctrine of res inter 8. The statements of Mr. Sulapas in his Sinumpaang Salaysay and Supplemental

violations of the SRC and the SRC-IRR as indicated in the Formal Charge. 6. Complainant has failed to show that Respondents committed the alleged

THE ISSUES

Based on the pleadings submitted, the issues presented are summarized as follows:

of the SRC 3 I. Whether or not certain actions have already been barred by prescription 2. II. Whether or not Mr. Racadio is a control person within the purview of Section 51

Securities Regulation Code and its 2015 Implementing Rules and Regulations: III. Whether or not the Respondents violated the following provisions of the

B. Sec. 52.1.6. Customer Account Information Rule A. Sec. 30.2.1.2.4. Information About Clients C. Rule 48.2 - Prohibitions on Extension of Credit in relation to Rule 8.1 . D. Rule 50 - Purchases and Sales in Cash Account E. Rule 34. Segregation and Limitation of Functions of Members, Margin

H. Sec.26 in relation to Sec. 54 of the Securities Regulation Code K. 30.2.1. Ethical Standards Rules G. Sec. 52.1.1. Books and Records Rule F Sec. 51 in relation to Secs. 26 of the Securities Regulation Code 30.2.6. Supervision Rule Sec. 30.2.1.2.3. Capabilities Brokers and Dealers.

2 Paragraph 2.50, pages 17&18 of Respondents Reply. 3 Paragraphs 3.16 page 10 and par. 4.62 page 32 of Respondents Answer. Paragraph 2.81 pages 22-23 of the Respondents Position Paper and paragraph 2.7-2.17 of Respondents Reply.

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Code and its Implementing Rules and Regulations. 4 any culpability of the Respondents for the alleged violations of the Securities Regulation IV. Whether or not the Formal Charge failed to allege the ultimate facts showing

Formal Charge. 5 V. Whether or not the Respondent sufficiently denied the allegations of facts in the

THE RULING

on prescription raised by the Respondents and the issue on whether Mr. Racadio is covered by the definition of Control Person under Section 51 of the SRC, especially that this has been raised by Respondent Racadio Before resolving the main issue, it is important to determine at the outset the issue

have already been barred by I. Whether or not certain actions prescription

penalties would be limited on actions that have yet to prescribe. 6 whose period are not fixed in this Code or in other laws must be brought within five years from the time the right of action accrues. Thus, the Commission's authority to impose of exchange brokers in the obligation in which they take part by reason of their office shall prescribe after three years while Article 1149 of the Civil Code states that all other actions penalties on actions that have already been barred by prescription. To support their arguments, they cited Article 945 of the Code of Commerce which provides that the liability Respondents argued that prescription bars the Commission from imposing

administrative liabilities. Iaw pertain to the prescriptive period for the enforcement of civil liabilities and not on The argument of Respondents is misplaced. It appears that the cited provisions of

of the complainant. Thus: period for the filing of administrative complaints for violations of the law and that an administrative complaint shall only be barred if it is clear that there is laches on the part Tanco-Gabaldon, et al.,7 has pointed out that the SRC does not provide for a prescriptive The Supreme Court in the case of Citibank N.A. and the Citigroup Private Bank v.

settled principle of law that laches is a recourse in equity, which is, applied only in the absence of statutory law. And though laches applies even to imprescriptible imposed against persons or entities violating the Code, its rules or SEC orders. Just likewise omitted to provide for the period until when complaints for administrative liability under the law should be initiated. On this score, it is a well- as the SRC did not provide a prescriptive period for the filing of criminal actions, it "Section 54 of the SRC provides for the administrative sanctions to be

% Paragraph 2.50, pages 17&18 of Respondents Reply 7 G.R. No. 198444, 4 September 2013 4 Pages 2-7 of the Respondents Position Paper 5 Paragraphs 4, 4.1-4.6 of the Complainant's Position Paper.

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not established. is addressed to the sound discretion of the court and, being an equitable doctrine, its application is controlled by equitable considerations." In this case, laches was actions, its elements must be proved positively. Ultimately, the question of laches

September 2020 a Formal Charge against the Respondents. Hence, the filing of this action is not barred by prescription nor laches. transactions pertaining to Julieto Sulapas account with VSI. Subsequently, the IRC filed on investigation after knowing about the deterioration of the financial condition of R&L and discovered that the circumstances surrounding the incident is associated with the In this case, the Commission through the IRC immediately conducted an

purview of Section 51 of the SRC II. Whether or not Mr. Racadio is a control person withinthe

Section 51 of the SRC, he is jointly and severally liable with VSI officers and employees. * his duty to oversee the day to day operation of the company. This involves, among others, the supervision and evaluation of the acts of other officers and employees of VSI. Applying Complainant asserted that Mr. Racadio being the President of VSI failed to perform

Mosenabre "by or through stock ownership, agency or otherwise or in connection with an agreement or understanding". 51.1 of the SRC because he does not control Ms. Aguilar, Mr. Balabis, and/or Ms. On the other hand, Respondent Racadio contends that he is not covered by Section

registered persons. 10 operation of VSI as its President does not include controlling all the actions of the Mr. Racadio also claims that his primary duty to manage the business and

Respondent Racadio's argument is wrong.

thus: Section 51 of the SRC provides the joint and several liability of control persons,

ownership, agency or otherwise, or in connection with an agreement or understanding Section 51 describes a controlling person as "every person who, by or through stock facts by reason of which the liability of the controlled person is alleged to exist. regulations of the Commission thereunder, shall also be liable jointly and severally with and to the same extent as such controlled persons to any person to whom such controlled person is liable, unless the controlling person proves that, despite the exercise of due diligence on his part, he has no knowledge of the existence of the more other persons, controls any person liable under this Code or the rules or Secondary Liability. 51.1. Every person who, by or through stock ownership, agency, or otherwise, or in connection with an agreement or understanding with one or Section 51. Liabilities of Controlling Persons, Aider and Abettor and Other

10 Paragraph 2.8 page 4 of Respondents Reply 1st sentence. Paragraph 20 page 17 of the Formal Charge and paragraph 5.4 of Complainant Position Paper. 9 Paragraph 2.81 page 22 1st sentence Respondents Position Paper, paragraph 3.16 page 10 and paragraph 4.62, page 32 1st sentence of Respondents Answer.

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regulations of the Commission thereunder" with one or more other persons controls any person liable under this Code or the rules or

determination of a controlling person. Control is rather an indefinable concept that has been variously defined. However, the 2015 SRC Rules defined control as follows: From the foregoing, it appears that there is no fix and exclusive criteria in the

an entity, but has any of the following powers: the parent entity owns, directly or through subsidiaries and/or associates, more than fifty percent (50%) of the voting power of an entity. It also exists when the parent entity owns fifty percent (50%) or less of the voting power of 3.1.8. Control is the power to determine the financial and operating policies of an entity in order to benefit from its activities. It is presumed to exist when

3.1.8. I. Over more than fifty percent (50%) of the voting rights by virtue of an agreement with other investors; 3.1.8.2. To govern the financial and operating policies of the entity under a statute or agreement: 3. 1.8.3. To appoint or remove the majority of the members of the board of directors or equivalent governing body; or

equivalent governing body. (Emphasis ours) 3.1.8.4. To cast the majority of votes at meetings of the board of directors or

securities, by agency, by statute or agreement or otherwise. the financial and operating policies of an entity whether through the ownership of voting In other words, the term "control" means the possession of the power to determine

intended to include actual control. Hence, persons with authority to control the corporation's financial and operating policies would be considered as controlling persons thereof. In Section 51, when reference is made to 'control', it is understood that the term is

duties and responsibilities. the SRC and its IRR. They should be presumed to be controlling persons if they are corporations, majority shareholders, directors, or officers or all such persons who have the authority to control the organizational affairs, employees or personnel as well as to certain 51 if he occupies a status or position that ordinarily bestows authority to control any person liable/violator or with respect to the matter or affairs that produced violation of Therefore, a person should be presumed to be a controlling person under Section

patterned or adopted from another state, thus: Inc.,11 the Honorable Supreme Court had the occasion to explain the construction of a law In addition, in the case of Carolina Industries, Inc., v. CMS Stock Brokerage,

adopted from another State and such statute has previously been construed by those of the United States, decisions of United States courts construing similar laws are entitled to great weight. Generally speaking, when a statute has been "We have previously stated that in case of laws patterned after or adopted from

11 G.R. No. L-46908 May 17, 1980

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with the construction so given it." the courts of such State or country, this statute is deemed to have been adopted

American law and jurisprudence are highly persuasive in construing the coverage of a control person under Section 51. On the basis of the foregoing, since the SRC is patterned from the United States

for control person liability against individuals associated with brokerage firms, including the individual owners, directors, officers, and supervisors,12 thus: Based on the following American jurisprudence, the courts have upheld the claims

fraud perpetrated by the broker); broker-deaier, that the individual directors controlled the broker charged with the violations and managed the broker-dealer corporation in such a manner as to be culpable participants in the :Padgett v. Dapelo, 791 F. Supp. 438 (S.D.N.Y. 1992), affd without broker associated with the firm had engaged in various violations of the Securities Exchange Act, and stated that the arbitrators could have concluded, based on their activities as directors of the opinion, 992 F.2d 320 (2d Cir. 1993) (court upheld an arbitration award imposing joint and several liability on a corporate broker- dealer and its individual directors based on allegations that a : Pollack v. Laidlaw Holdings, Inc., 1995 WL 261518 (S.D.N.Y. directors of a broker-dealer were control persons of the primary director of the firm, as well as the broker for the plaintiffs' accounts); Pittsburgh,"38 F. Supp. 2d 771 (D. Minn. 1999) (officers and directors of an investment firm could be held liable as control 1995) (plaintiffs sufficiently alleged that individual officers and violator, who was the president, chief executive officer, and a stated for control person liability against firm's individual majority owner, who also served as chairman of its board of directors and chief executive officer); at investment advising firm who exercised discretion over investment advice, oversight, and administrative services that firm provided to clients): persons); colorable showing that the individual serving as vice president and treasurer of a brokerage firm was potentially liable as a controlling person for a salesperson's securities fraud); 2011) (claim stated for control person liability against executives : S.E.C. v. Fitzgerald, 135 F. Supp. 2d 992 (N.D. Cal. 2001) (claim . Piper Jaffray Companies Inc. v. National Union Fire Ins. Co. of (court upheld a finding of control person liability against the owner of a brokerage firm based on his stake and active role in the firm) Roberts, Inc., 979 F.2d 1356 (9th Cir. 1992) (plaintiff made a .S.E.C. v. First Jersey Securities, Inc., 101 F.3d 1450 (2d Cir. 1996) In re J.P. Jeanneret Associates, Inc., 769 F. Supp. 2d 340 (S.D. N.Y. San Mateo County Transit Dist. v. Dearman, Fitzgerald and

12 Control Persons" May Be Liable for Stock Broker Misconduct, Daniel Broxup, August 19, 2017.

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broker-dealer properly alleged to be control person). Penn. 1986): Management, Inc., 572 F. Supp. 1475 (D. Mass. 1983) (an officer, director, and 20% shareholder of investment advisor and a gave them the responsibility, and hence the means, of supervising" two account executives): . In Margaret Hall Foundation, Inc. v. Atlantic Financial under Section 20(a) against three. individuals who occupied businessman who allegedly created broker/dealer could have controlled its brokers even though other defendants technically 1981) (held that plaintiffs had sufficiently pled causes of action positions within the brokerage firm's corporate structure "that on his failure to supervise the firm's registered representative): owned corporation); be a controlling person of a securities underwriter and broker- (court found that a complaint sufficiently alleged that the president of a brokerage firm was liable as control person based : Lazzaro v. Manber,701 F.Supp. 353 (E.D.N.Y. 1988) (private of control person status against a member of the executive market maker): dealer); 1990) (court found that the plaintiffs had stated a sufficient claim committee for a firm serving as clearing broker for a securities corporation alleged to have manipulated securities in its role as : Binder v. Gordian Securities, Inc., 742 F. Supp. 663 (N.D. Ga. 1990) (action upheld against individual officer/director alleged to Leavey v. Blinder, Robinson & Co., Inc., 1986 WL 10556 (E.D. ..Epstein v. Haas Securities Corp., 731 F. Supp. 1166 (S.D. N.Y. Metzner v. D.H. Blair & Co., 689 F. Supp. 262 (S.D.N.Y. 1988) Savino v. E. F. Hutton & Co., Inc., 507 F. Supp. 1225 (S.D.N.Y.

of the capital market. that is - to afford the public protection from their investments and to protect the integrity The United States, no doubt, shares the same interest as the Philippine Government

2014, which provides: control over the Corporation and its employees. His authority over them is evident in Article HII, Section 3 of VSI Amended By-Laws approved by the Commission on October 15, Moreover, Mr. Racadio as the President of VSI, exercised supervision, direction and

their own number. He shall have the following powers and duties: Section 3. The president shall be elected by the Board of Directors from

XXX

other officers of the Corporation; whenever and wherever the same is not expressly limited by such orders, resolutions and instructions, and exercise general supervision over all the instructions of the Board of Directors, and according to his own discretion of the Corporation, conducting the same according to the orders resolutions and (b) Have direct and active management of the business and operations

Page 13 of 216

XX

and see to it that their respective duties are properly performed: (Emphasis Supplied) official trust, and to exercise general superintendence and direction over all the agents , emplovees and other subordinate personnel of the Corporation. or wages , and require certain guarantees or bonds in such amount as he may determine to secure the faithful discharge by certain employees or agents of their the agents , employees and other subordinate personnel of the Corporation prescribe their duties and fix or change from time to time their respective salaries (d) To appoint and at his discretion remove or suspend any or all of

followed. the officers, agents, employees and other subordinates including the registered persons of ensure that their respective duties are properly performed and the rules are appropriately VSI which involve oversight of a subordinate with a power to hire and fire them in order to Accordingly, Mr. Racadio has the power of supervision, direction and control over all

trustees or officers of a corporation. The Court held: Collection, Social Security System,13 had the occasion to explain the liability of directors, Finally, the case of Immaculada L. Garcia vs. Social Security Commission Legal and

severally for all damages resulting therefrom suffered by the corporation, its stockholders or members and other persons. affairs of the corporation or acquire any personal or pecuniary interest in conflict with their duty as such directors, or trustees shall be liable jointly and who willfully and knowingly vote for or assent to patently unlawful acts of the corporation or who are guilty of gross negligence or bad faith in directing the directors, trustees, or officers, provides: "Section 31 of the Corporation Code, stipulating on the liability of "SEC. 31. Liability of directors, trustees or officers. -- Directors or trustees

officer, and employee of a corporation are generally not held personally liable for obligations incurred by the corporation. general rule applied is that obligations incurred by the corporation, acting through its directors, officers and employees, are its sole liabilities. A director, of any other legal entity to which it may be related. A corporation is a juridical entity with legal personality separate and distinct from those acting for and in its behalf and, in general, from the people comprising it. Following this, the separate and distinct from that of the persons composing it as well as from that Basic is the rule that a corporation is invested by law with a personality

shield or perpetrate fraud, to carry out other similar unjustifiable aims or intentions, or as a subterfuge to commit injustice and so circumvent the law. Thus, Section 31 of the Corporation Law provides: and the lifting of the corporate veil. This situation might arise when a corporation is used to evade a just and due obligation or to justify a wrong, to valid grounds that can exist to warrant the disregard of its independent being Being a mere fiction of law, however, there are peculiar situations or

13 G.R. No. 170735, December 17, 2007

Page 14 of 216

an officer, may be held solidarily liable with the corporation in the following instances: Taking a cue from the above provision, a corporate director, a trustee or

1 When directors and trustees or, in appropriate cases, the officers of a corporation-

its stockholders or members, and other persons. affairs; (b} c a} are guilty of conflict of interest to the prejudice of the corporation, act in bad faith or with gross negligence in directing the corporate vote for or assent to patently unlawful acts of the corporation;

2. When a director or officer has consented to the issuance of watered stocks or who, having knowledge thereof, did not forthwith file with the corporate secretary his written objection thereto. 2

3. When a director, trustee or officer has contractually agreed or stipulated to hold himself personally and solidarily liable with the Corporation.

4. When a director, trustee or officer is made, by specific provision of Iaw, personally liable for his corporate action. (Emphasis ours)

such controlled persons to any person to whom such controlled person is liable. he failed to perform his duties and responsibilities mandated by the SRC and its IRR as will be discussed in the ruling below, falls exactly under the fourth situation. In this case. Section 51.1 of the SRC imposes a joint and several liabilities of a control person for any act or omission pertaining to the violation of the SRC and its IRR to the same extent as In this case, the situation of Mr. Racadio, as a director and President of VSI when

SRC because he does not control Ms. Aguilar, Mr. Balabis, and/or Ms. Mosenabre does not have a legal leg to stand on. Taken altogether, Mr. Racadio's claim that he is not covered by Section 51.1 of the

discussions on the second and main issue in the order they are presented: now consider the clashing assertions regarding the main issue. The following are the Digressing now from the prescription and controlling person aspect of this case, we

its 2015 Implementing Rules and Regulations: HII. Whether or not the respondents violated the following provisions of the Securities Regulation Code and

Balabis) A. On the Charge for violation of Racadio, Adora Aguilar and Loreto Rules 30.2.1.2.4.1, 30.2.1.2.4.3 and 30.2.1.2.4.6 of the 2015 SRC Rules (Venture Securities, Wilfred

Page 15 of 216

informed regarding its client Julieto Sulapas, which includes the client's financial situation, investment experience and objectives as exemplified by the acts of its officers and employees, as follows: 14 In the Formal Charge, Complainant alleged that VSI failed on its duty to be

1. Ms. Aguilar appears not to have knowledge on the background of Sulapas. 2. Mr. Balabis admission that he merely gave Marlo Moron a blank Customer Account Information Form ("CAIF") which was allegedly filled out by Sulapas Without his presence.

3. Julieto Sulapas indicated in his CAIF that he does not have any other account with other broker dealers notwithstanding his existing account with another broker, R&L Securities. Ms. Aguilar admitted during the investigative proceedings that she knew that Julieto Sulapas has an account with R & L, but she did not require him to correct this fact in the CAIF.

4. Admission of Ms. Aguilar that there was no verification made for the disclosed source of income of Julieto Sulapas in his declared business, (JS Lumber). 5. The annual income of Julieto Sulapas based on his CAIFs and account ledgers is only Php 1 million but he was allowed to transact beyond his financial capability.

6. Mr. Racadio duty to oversee the day to day operations of Venture Securities implemented. The commission of foregoing acts of the officers and employees show the failure of Wilfred Racadio to implement the necessary procedures for include the duty to put in place reasonable procedures in identifying the true and full identity of its clients and to ensure that such procedures are being KYC

about clients on the following reasons: 15 Balabis cannot be found liable for the SRC-IRR rules cited relating to the information For their part, Respondents argued that VSI, Mr. Racadio, Ms. Aguilar, and Mr.

trader who is fully aware of his transactions in the market; Sulapas who primarily gave instructions for his account. During this period, VSI never encountered any issues with Mr. Sulapas on settling his account. This gave VSI the confidence to consider Mr. Sulapas as a knowledgeable and responsible 1. VSI and its employees were able to determine the trading pattern of Mr. Sulapas based on his numerous buy and sell transactions from 2012 to 2019. It was Mr.

situation, investment experience, and investment objectives. More importantly, VSI found that Mr. Sulapas can sustain funding for his transactions almost entirely from his trading activities. This can be seen from the fact that he only made a few deposits into his account from 2012-2019. Mr. Sulapas' EQ Trade transactions into 2. Based on his trading pattern, VSI was able to gauge more accurately his financial

15 Pages 35-36 of Respondents Answer 14 Pages 19-20 of the Formal Charge

Page 16 of 216

his account also form a small portion of his buying and selling transactions with V

and sell transactions given that he can sustain funding for his transactions almost entirely from his trading activities; 3. The trading pattern established by Mr. Sulapas as well as his dealings with VSI background, and investment objectives compared to what he initially provided information, VSI determined that he has the financial capacity for his numerous buy from 2012-2019 gave VSI a better idea of his financial situation, investment upon account opening and to what he indicates in the CAIF. Based on this

provided his government issued identifications; 4. VSI was also able to satisfactorily determine the identity of Mr. Sulapas when he went to the office of VSI to open his account, accomplished his CAIF, interviewed on his financial situation, investment background, and investment objective, and

Furthermore, the failure on the part of Mr. Sulapas to update his CAIF did not render the transactions he entered into as fraudulent; 5. Ms. Aguilar repeatedly required Mr. Sulapas to correct and update his information in his CAIF. Ms. Aguilar, however, cannot commit a felony or offense just to make sure that the CAIF reflects the correct information. Instead, VSI had duly noted that Mr. Sulapas maintained an account with another broker dealer.

buy and sell transactions. In addition, since Mr. Racadio is not a registered person, he cannot be made liable under Rule 30.2.1.2.4.1, Rule 30.2.1.2.4.3, and Rule 30.2.1.2.4.6 of the SRC-IRR; and, 6. As the president of VSI, Mr. Racadio:placed reasonable procedures in identifying implemented. He ensured that VSI obtain as much information about Mr. Sulapas and his trading activities. He ensured that the determination of his financial is aware whether it was Mr. Sulapas who was personally executing his numerous the true and full identity of clients and to ensure that such procedures are capacity is not merely limited to what is stated in the CAIF, but also based on his trading pattern, and on his dealings with VSI. He also made sure that the Company

situation, investment experience and investment objective of Mr. Sulapas; 7. The foregoing discussion shows that VSI, Mr. Racadio, Ms. Aguilar, and Mr. Balabis had taken more than reasonable steps to determine the identity, financial

We reject the Respondents arguments.

Clients" or the Know Your Client Rule (KYC) read as follows: In the context, the particular SRC Rules violated pertaining to "Information About

Sec. 30.2.1.2.4. Information About Clients

information about his financial situation, the registered person shall make the about their financial situation, investment experience and investment objectives regarding the services to be provided pursuant to SRC Rule 52.1.6 and other applicable laws. If a client refuses to disclose reasonable 30.2.1.2.4.1. A registered person should seek from his clients, information

Page 17 of 216

the client. necessary estimate based on his initial evaluation of the information given by

XXX XXX XXX

situation, investment experience, and investment objectives. Sec. 30.2.1.2.4.3. A registered person shall take all reasonable steps to establish the true and full identity of each of his clients, their financial

be aware of through the exercise of due diligence, the registered person shall 30.2.1.2.4.4. Having regard to information disclosed by a client and other circumstances relating to the client which the registered person is or should and suitable in all circumstances pursuant to Suitability Rule under SRC Rule ensure that such recommendation or solicitation for that client is reasonable 30.2.4

XXX XX

the commercial or economic risk; Provided, however, that in relation to an is the investment company or account, not those who hold a beneficial interest originating the instruction in relation to a transaction, the person who stands investment company, or discretionary account, the person referred to above therein. Sec. 30.2.1.2.4.6. A registered person should be reasonably satisfied about the identity, address to gain the commercial or economic benefit of the transaction and/or bears and contact details of the person ultimately responsible for XXX XXX XXX

Sulapas Account on the following reasons: In this case, we noted that proper KYC measures were not implemented on Julieto

Affidavit16 dated March 8, 2021, and we quote in part as follows: blank CAIF to Marlo Moron which was filled out by Mr. Sulapas without his presence. His absence during the opening of account is further bolstered by his statement in his First, Mr. Balabis did not dispute the Complainant allegation that he merely gave

an account with Venture Securities, Mr. Sulapas has to go to its office. the trading floor of the PSE. I told Mr. Moron that in order for Mr. Sulapas to open "5. Mr. Julieto Sulapas("Mr. Sulapas") is a client that was referred by Mr. Marlo Moron ("Mr. Moron"). I am familiar with Mr. Moron because I always see him at

6. I know that Mr. Sulapas went to the Office of Venture Securities to open his account because the associated person, Ms. Adora M. Aguilar ("Ms. Aguilar") informed me of his successful account opening." (Emphasis ours)

opening of Sulapas account stated in the Respondents answer as follows: 1? This fact is also manifest in the alleged process and procedures conducted in the

"4.4 Mr. Sulapas personally visited the offices of Venture Securities on 29 May 2012 to open his account. He was interviewed by Ms. Grace

Respondent Position Paper. 16 Attached as Annex "16" of the Respondents Position Paper. 17 Page 21 of the Answer and also mentioned in par. 5-7 of Ms. Aguilar Affidavit attached as Annex 14 of the

Page 18 of 216

account opening regarding his financial situation, investment experience, and investment objectives; Machacon, Officer-in-charge of Venture at that time, prior to his

4.5 During his interview, Mr. Sulapas was introduced to Ms. Aguilar. For CAIF, and affix his signature on the signature cards;" the creation of his account, Venture Securities required Mr. Sulapas to present his government issued identification cards, accomplish a

accordance with Item III (G) (1) (a) of VSI written Supervisory Procedures and Compliance Manual18 which provides: To note, Mr. Balabis is required to conduct a face-to-face interview with a client in

be presented like driver's license, SSS/GSIS Cards, Company ID's, passport, residence certificates and other ID's which would prove the identity of the new client. The client must supply the licensed salesman/agent with a complete business and home address wherein correspondences could be sent. A fax number and telephone number where the Company could get in touch with him are also necessary. inform the client of the Company's policies regarding acceptance of new accounts, payment scheme and their rules and regulations which the client needs to know in doing business with the Company. Proper identification card shall also face interview with the client. In this interview the license salesman/agent shall client, the assigned licensed salesman/agent shall have already done a face-to- "As a matter of policy, prior to effecting any transaction for or with any

XXX XXX XXX

that information contained in the CAIF is verified to be true and correct. The licensed salesman/agent who solicited the account has to be sure

and procedures undertaken by Ms. Aguilar together with the violation of the VSI Supervisory Procedures provision, is more than substantial evidence to prove that indeed, Respondents failed to take all reasonable steps to establish the true and full identity of Mr. Sulapas, his financial situation, investment experience, and investment objectives. The absence of Mr. Balabis during the account opening coupled with the process

submitted and as indicated in Ms. Aguilar Affidavit,20 there were transactions which were evidently beyond the client's declared P1,000,000.000 financial capacity. Information Forms ("CAIF") 19 is only P1,000,000.00 and based on the documents Second, the Financial Capacity of Mr. Sulapas indicated in his Customer Account

amount well above his CAIF's stated financial capacity as follows: account, he was allowed to transact in numerous transactions (1,047 transactions) in an From the entries recorded in the ledgers21 of Mr. Sulapas pertaining to SU026

21 Submitted during the investigation also attached as Annex "4" of the Respondents Position Paper and 20 Paragraph 16 of Aguilar Affidavit dated March 8, 2021 attached as Annex "14" of the Respondents Position 19 Annexes 1 and 1A of the Respondents Position Paper 18 Page 21, Annex 12 of the Respondents Position Paper Paper Annexes "F" and "G" of Complainant's Position Paper.

Page 19 of 216

503 54 50 45 46 4 48 49 51 52 3 2 38 329 43 44 24 28 30 31 32 3 35 31 3 40 41 42 23 25 26 29 34 15 16 1 18 19 20 21 22 2 6 D 13 14 Number 4 10 11 12 1 8 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 20 12 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 Years 2012 2012 2012 2012 2012 08-Aug 03-Aug 08-Aug 03-Aug 03-Aug 06-Aug 06-Aug 26-Jul 31-Jul 31-Ju} 01-Aug 02-Aug 03-Aug 03-Aug 24-Jul 24-Jul 01-Aug 02-Aug 05-Jul 09-Jul 11-Jul 12-Jul 12-Jul 13-Jul 17-Jul 19-Ju 19-Jul 27-Jun 02-Jul 03-J 04-Jul 06-Jul 06-Jul 06-Jl 09-Ju 10-J 31-May 01-Jun 04-Jun 05-Jun 06-Jn 11-Jun 13-Jun 14-Jun 19-Jun 20-Jun 22-Jun 25-Jun 29-Jun 29-Jun 30-May 01-Jun 06-Jun 07-Jun Date BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY 40410 403 70 40371 40381 40390 40398 REF # 4030 40349 40368 40369 40279 40280 40302 40309 40311 40117 40156 40165 40201 40202 3 93 40007 4009 40047 40054 40070 40080 40235 3 9898 39917 39938 39 957 399 78 39992 40030 39684 39709 39724 39752 39782 397 96 39828 398 38 39860 398 79 39883 395 69 395 98 39621 39666 3 96 77 3 96 90 39623 396 48 TDY MC TDY CAL PGOLD CMT VMC CAL TDY TDY TDY TDY ABA CPG PIP TDY LC ABA GEO ABA PIP L PGOLD PGOLD EL ABA RFM MEG DIZ GERI BEL OPMB LC GREEN CAL CAL LCB CAL CAL N TDY LHC DIZ LR ISSUE CAL CAL CAL CAL CAL CAL 4V DIZ EW VMC 100,000,000 100,000,000 2,000,000 2,000,000 4,000,000 1,000,000 5,000,000 5,000,000 2,000,000 2,000,000 1,000,000 1,410,000 50,000,000 1,000,000 1,000,000 500,000 201,400 261,500 150,000 610,000 2,000,000 700,000 500,000 300,000 500,000 142,100 238,500 186,500 1,500,000 200,000 1,000,000 1,000,000 500,000 200,000 110,000 200,000 50,000 200,000 300,000 200,000 500,000 500,000 300,000 100,000 150,000 121,400 118,800 100,000 100,000 183,700 152,200 50,000 50,000 108,200 Shares 2,524,432.50 2,349,210.73 3,319,809.75 3,680,753.35 1,312,875.89 4,508,928.11 5,089,095.00 1,839,977.38 4,230,109.09 7,639,375.27 3,097,710.00 1,850,580.00 1,206,900.00 2,307,924.69 2,202,592.50 1,981,689.57 1,110,348.00 1,634,042.02 2,604,892.50 2,011,500.00 5,632,200.00 3,942,540.00 2,051,730.00 1,544,248.65 1,682,438.71 3,872,137.50 2,310,318.39 2,252,880.00 1,744,966.20 2,045,433.99 2,684,321.62 2,247,851.25 1,387,935.00 2,987,077.50 4,525,875.00 1,759,982.05 2,614,950.00 1,508,625.00 1,989,401.66 2,679,318.00 4,054,970.78 2,546,559.00 2,464,087.51 1,050,400.29 1,754,279.44 1,412,073.00 1,719,832.50 2,834,722.46 3,618,211.78 4,213,489.05 1,321,100.90 1,030,913.86 1,438,222.50 1,482,032.99 Total Debit

Page 20 of 216

108 10 106 104 105 96 103 2 4 05 9 9 101 102 0 1 97 100 7 89 93 0 83 84 85 86 8 1 82 9 15 76 1 63 66 6 68 69 70 73 74 11 62 64 6 1 12 58 59 60 56 57 55 Number 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 20 12 2012 2012 2012 2012 2012 2012 2012 2012 2012 Years 2012 2012 2012 19-Oct 16-Oct 18-Oct 11-Oct 16-Oct 16-Oct 09-Oct 11-Oct 08-Oct 08-Oct 09-Oct 10-Oct 04-Oct 05-Oct 08-Oct 03-Oct 05-Oct 05-Oct 08-Oct 25-Sep 04-Oct 04-0ct 21-Sep 01-Oct 03-Oct 20-Sep 04-Sep 10-Sep 11-Sep 11-Sep 14-Sep 17-Sep 28-Aug 29-Aug 14-Sep 23-Aug 28-Aug 28-Aug 29-Aug 31-Aug 16-Aug 24-Aug 28-Aug 08-Aug 09-Aug 09-Aug 13-Aug 13-Aug 14-Aug 15-Aug Date 13-Aug 13-Aug 14-Aug 10-Aug BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY 413 94 41300 41349 41195 41233 41234 41287 41298 41158 41172 41173 41130 41146 41152 41153 41093 41094 41113 41118 41059 41088 REF # 40973 41038 41055 40878 40888 40 39 40814 40821 40871 40918 40705 40739 40 799 40623 40065 40671 40672 40681 40686 40477 40484 40496 40530 40551 40645 40653 40463 40465 40476 40434 40411 40423 40446 APM APM CLOUD EG GREEN APM APM MA PX SFI MEG SF APM MA MAB APM LR APM GREEN AGI CYBR PHES BLOOM APM CMT PX PX MEG PX CMT CMT LC MJC SG TDY TDY GREEN CMT AG GREEN PCOR MEG AGI MEG ABA TDY BHI ACE BH TDY ISSUE TDY TDY CMT CMT 300,000,000 30,000,000 200,000,000 100,000,000 20,000,000 50,000,000 140,000,000 100,000,000 71,390,000 28,610,000 90,000,000 300,000,000 11,070,000 10,000,000 50,000,000 20,000,000 2,000,000 560,000 200,000 100,000,000 3,000,000 1,296,000 200,000,000 2,000,000 2,000,000 1,500,000 2,000,000 175,500 3,000,000 3,000,000 600,500 10,000,000 1,000,000 200,000 200,000 100,000 200,000 10,000,000 1,800,000 500,000 300,000 500,000 300,000 184,000 400,000 116,000 200,000 127,700 445,000 145,200 700,000 600000 500,000 130,300 Shares 4,797,427.50 4,877,887.51 2,896,560.00 2,514,375.00 2,931,517.85 4,114,131.01 1,726,470.45 6,436,960.93 6,336,225.00 1,688,895.63 1,025,865.00 1,568,291.14 2,260,423.14 5,292,155.93 3,419,550.00 4,867,830.00 1,910,925.00 7,844,850.00 4,646,565.00 3,922,425.00 6,927,404.85 3,150,451.52 2,564,662.50 3,198,285.00 3,777,597.00 3,254,500.40 2,989,089.00 2,283,052.50 1,478,452.51 2,363,512.50 1,216,957.50 2,413,800.00 4,505,760.00 1,810,350.00 1,242,101.25 1,609,200.00 6,849,157.50 3,427,596.00 2,293,110.00 1,506,693.96 2,401,710.89 1,181,756.26 4,638,519.00 3,520,125.00 4,141,022.75 1,636,413.60 1,454,565.94 1,898,087.62 2,635,065.00 1,591,619.49 1,810,350.00 1,233,049.50 1,364,802.75 1,757,930.32 Total Debit

Page 21 of 216

162 151 154 157 158 161 150 152 153 155 156 159 160 148 138 143 144 149 134 135 139 140 142 145 146 147 132 136 137 141 130 131 133 117 124 127 128 129 109 114 115 116 118 119 120 121 123 125 126 110 111 112 113 122 Number 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2012 2012 2012 2013 2013 2013 2013 2013 2012 2012 2012 2013 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 Years 2012 2012 2012 2012 17-Apr 27-Mar 16-Apr 16-Apr 08-Mar 20-Mar 22-Mar 15-Apr 15-Apr 28-Feb 04-Mar 04-Mar 05-Mar 06-Mar 15-Apr 21-Feb 12-Mar 31-Jan 31-Jan 05-Feb 05-Feb 14-Feb 18-Feb 18-Feb 19-Mar 07-Dec 18-Dec 17-Jan 17-Jan 07-NoV 09-N 09-Nov 14-NoV 19-Nov 23-NoV 28-Nov 11-Dec 17-Dec 15-Jan 16-Jan 17-Jan Date 29-Oct 05-No 08-Nov 08-NoV 09-NV 15-NoV 22-Nov 27-Nov 08-!an 05-N 05-NoV 06-NV 06-No BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY 45507 44565 445 93 44812 45508 455 09 45297 45310 45313 REF # 44139 44310 44403 44668 43681 43800 44097 44111 44204 43641 43 987 42812 42849 42872 42882 429 04 4345 43447 43315 433 50 4357 2 42193 42241 42381 42633 415 42 41753 41806 41841 41898 41991 42008 42034 420 90 42359 41601 41627 41637 41649 41682 41710 41723 41727 415 95 415 96 ABS MP TA MP TA MMI BHI TA TA TA TA BLOOM TA BEL SLI BLOOM SLI ZH ARA ZH PRIM CH DNL TA TA CYBR TA DNL GREEN PHES EVER SL PRIM VUL GREEN GREEN CPG VITA VUL GREEN VUL GREEN WEB WEB VITA APM GREEN BHI APM APM APM APM ISSUE APM GREEN 20,000,000 2,000,000 200,000,000 2,000,000 2,000,000 2,000,000 2,000,000 1,222,000 200,000,000 200,000,000 2,000,000 1,000,000 1,000,000 2,000,000 500,000 100,000,000 100,000,000 2,000,000 2,000,000 150,000 700,000 778,000 30,000,000 83,000,000 5,000,000 3,000,000 2,000,000 2,000,000 80,000,000 20,000,000 30,000,000 1,000,000 500,000 300,000 100,000 49,030,000 60,970,000 71,000,000 10,000,000 1,000,000 1,500,000 494,000 500,000 700,000 44,700 1,000,000 730,000 300,000 1,000,000 1,000,000 777,000 1,000,000 100,000 111,300 Shares 4,212,757.88 1,910,673.57 4,547,257.26 1,367,803.92 2,949,663.60 3,862,080.00 2,755,755.00 1,885,761.13 2,831,186.25 4,666,680.00 1,257,187.50 2,604,892.50 5,329,881.62 2,423,857.50 1,156,612.51 1,693,612.59 1,504,420.97 3,117,825.00 3,942,670.76 4,721,050.85 4,820,805.15 1,233,160.14 3,416,170.67 4,083,345.00 1,744,654.42 1,408,050.00 1,835,493.75 3,691,102.50 2,514,375.00 5,028,750.01 2,058,870.83 2,091,960.00 2,004,228.42 1,919,976.75 4,626,450.00 1,229,740.58 1,356,796.97 2,081,902.50 1,284,553.96 1,850,580.00 4,103,460.00 3,982,770.00 1,729,890.00 1,410,061.50 8,071,274.50 4,626,450.00 1,478,452.51 1,659,487.50 8,522,936.71 2,574,720.00 2,413,800.00 1,578,353.65 6,176,924.26 1,499,573.25 Total Debit

Page 22 of 216

213 215 216 209 210 211 212 207 214 206 208 1 9 201 202 203 204 205 198 200 194 195 196 197 1 2 185 1 90 193 181 183 186 187 188 189 191 178 182 184 176 177 179 180 171 175 16 172 173 174 163 164 167 168 169 170 Number 115 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 20 13 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 Years 2013 29-Ju 23-Ju 24-Jul 22-Jul 23-Jul 23-Ju 25-Jul 18-Ju 04-J 11-Jul 11-Jul 12-(u 16-Jul 04-Jul 04~Jul 11-Jul 19-Jul 28-Jun 03-Jul 24-Jun 04-Jun 18-Jun 19-Jun 29-May 03-Jun 04-Jun 06-Jun 10-Jun 10-Jun 17-Jun 24-May 31-May 06-May 21-May 29-May 30-Apr 03-May 03-May 07-May 07-May 14-May 25-Apr 29-Apr 23-Apr 24-Apr 24-Apr 26-Apr 30-Apr 22-Apr 22-Apr Date 17-Apr 17-Apr 18-Apr 18-Apr BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY 49001 48776 48844 48841 48848 48636 48680 48758 48484 48587 482 74 48275 48276 48283 48038 48076 47617 47637 47734 47879 48073 480 22 REF # 47437 47591 47291 47367 47425 47131 47234 47269 472 8 46549 46791 46902 47128 46228 46888 45 99 46053 46091 46107 45861 45864 45890 45952 46140 45359 45360 45373 45 438 455 26 45 5 78 45 6 80 45859 C MA TA ALPHA MER SMPH TA TA TA BLOOM LC MCP MEG MEG LC MCP MM COSCO COSCO LC TA SUN TA DMPL MEG LCB SMDC COSCO MEG LCB TA VUL MEG LC LCB MMI TA BH TA SUN SL TA ISSUE VUL APC PNB SIN TA TA H20 ACR TA MCP VUL VUL 100,000,000 10,000,000 10,000,000 2,000,000 2,000,000 1,631,000 3,000,000 5,000,000 419,000 3,000,000 1,000,000 1,600,000 2,000,000 1,000,000 4,000,000 500,000 400,000 3,000,000 1,500,000 1,000,000 390,500 609,500 29,200 20,000,000 4,000,000 109,400 2,000,000 4,000,000 300,000 50,000 1,971,000 4,000,000 2,000,000 1,500,000 7,000,000 8,000,000 1,000,000 1,342,000 2,000,000 3,000,000 500,000 150,000 2,000,000 2,000,000 1,000,000 500,000 1,134,000 2,000,000 2,000,000 200,000 338,000 121,500 916000 50,000 Shares 6,637,950.00 14,120,730.00 1,131,046.32 4,429,021.27 5,626,416.95 1,468,395.00 4,928,175.00 5,531,625.00 7,442,501.74 2,609,921.25 5,257,793.49 3,117,825.00 2,309,101.43 10,047,442.50 9,685,372.50 2,312,520.97 1,196,842.51 1,122,919.88 4,023,022.10 6,311,489.58 5,310,360.01 11,334,802.51 4,377,526.88 2,715,525.00 1,799,739.34 5,317,460.59 2,313,225.00 8,066,115.00 3,073,672.59 3,178,170.00 4,274,437.50 1,062,072.00 5,257,920.21 5,531,625.00 3,240,858.41 3,017,250.00 5,732,775.01 4,002,885.00 2,665,237.50 1,890,810.00 8,146,575.00 1,063,128.04 5,431,050.00 3,193,205.96 2,874,220.28 2,765,812.50 1,230,333.97 6,336,225.00 5,431,050.00 1,368,051.32 1,631,648.35 2,047,978.56 2,935,532.82 4,103,460.00 Total Debit

Page 23 of 216

20 219 263 267 268 250 254 255 25 9 260 261 262 264 265 266 218 226 228 230 232 2035 236 237 239 240 241 247 248 249 251 252 253 256 257 258 Number 217 220 223 225 227 231 233 234 238 242 243 244 245 246 219 221 222 224 229 2014 2014 2014 2014 2014 2014 2014 2014 2013 2013 2013 2013 2013 2013 2013 2013 2013 2014 2014 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 Years 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 2013 03-Mar 06-N 08-N 08-No 08-NoV 05-Dec 17-Dec 20-Dec 21-Jan 22-Jan 17-Feb 20-Feb 09-Sep 09-0ct 10-Oct 21-Oct 24-Oct 30-Oct 04-No 07-NV 13-Nov 14-Nov 20-Dec 26-Dec 27-Jan 29-Jan 12-Feb 21-Feb 26-Feb 31-Jul 02-Sep 04-Sep 17-Sep 01-Oct 0 7-Oct 14-Oct 17-Oct 24-Oct 07-Nov 16-Dec Date 31-Jul 01-Aug 08-Aug 14-Aug 22-Aug 23-Aug 30-Aug 17-Sep 17-Sep 03-Oct 10-Sep 16-Sep 15-Aug 30-Aug BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY REF # 54658 5385 9 54183 54228 54358 5 4423 54533 51581 51871 5 1878 52140 52551 52728 52793 52916 52941 52985 53608 53686 53808 50692 50785 50843 50943 51034 51125 51176 51315 51468 51472 51756 5 1768 51850 51851 51870 5 20 80 49152 4 9367 49414 49554 4 95 98 49821 49822 49847 49917 50039 50236 50317 50318 50319 49312 49293 49997 49180 VMC MA MA MA LRW VMC SMPH MA MA VMC VMC SMPH MRC IRC GSMI GSM MARC MARC TA BKD LG VMC GMA7 SMPH BHI TA SUN SUN SMPH GSM TS TS TS BHI MCP LOTO MARC TUGS MARC TA BKD LMG ISSUE SE CB LCB LCB SMPH SMPH GSMI EMP MARC LC LC TS GSMI 150,000,000 150,000,000 150,000,000 150,000,000 100,000,000 12,720,000 4,000,000 1,310,000 20,000,000 1,000,000 9,000,000 10,000,000 9,000,000 5,000,000 1,500,000 1,000,000 1,700,000 1,988,000 5,000,000 1,786,000 1,000,000 700000 682000 200,000 600,000 100,000 717,000 500,000 500,000 326,000 1,703,000 512,000 265,000 500,000 500,000 111,600 500,000 100,000 648,400 798,000 600,000 777,000 100,000 198,000 220,600 500,000 100,000 500,000 159,000 86, 900 50,000 70,000 100,000 50,000 Shares 9,351,873.84 1,247,783.74 16,941,687.78 8,609,220.00 10,912,387.51 1,790,018.76 7,533,067.51 2,866,387.50 2,011,007.19 1,267,265.11 2,866,387.50 1,910,925.00 3,017,250.00 3,017,250.00 1,959,522.84 1,262,316.82 3,419,550.00 8,277,322.50 4,974,077.42 1,197,848.25 4,997,159.40 1,952,472.54 1,458,337.50 1,478,301.64 1,088,945.64 6,436,800.01 3,067,537.50 3,311,130.14 2,558,628.00 8,196,862.50 2,162,493.25 2,110,536.21 1,351,828.58 2,988,063.14 2,673,484.65 2,320,114.39 3,017,250.00 2,263,058.18 7,825,135.30 2,614,950.00 1,282,331.25 1,159,649.87 3,253,601.25 3,382,618.86 2,773,838.39 3,505,038.75 1,289,371.50 1,292,006.56 6,739,530.75 1,005,448.26 8,146,575.00 1,061,931.21 1,158,624.00 1,410,413.53 Total Debit

Page 24 of 216

324 323 310 312 313 317 321 3 22 311 314 315 316 318 319 320 300 301 305 06 308 309 2 28 282 286 287 288 2 90 291 292 293 294 296 2 7 298 299 302 303 304 307 Number 271 272 273 275 276 279 280 283 284 289 2 5 274 281 285 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 Years 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 07-Jul 09- 09-Ju 21-Jul 23-Jul 12-Aug 02-Jun 06-Jun 10-Jun 17-Jun 20-Jun 24-Jun 24-Jun 25-Jun 26-Jun 30-Jun 03-Jul 22-Jul 24-Jul 28-Ju 05-Aug 12-Aug 21-May 05-Jun 06-Jun 20-Jun 11-Aug 03-Apr 08-Apr 30-Apr 07-May 13-May 13-May 16-May 16-May 28-May 29-May 30-May 10-Jun 04-Mar 07-Mar 21-Mar 01-Apr 02-Apr 03-Apr 08-Apr 10-Apr 06-May 21-May Date 10-Mar 26-Mar 11-Apr 14-Apr 13-May BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY REF # 59621 5 858 60025 60074 60112 588 24 59326 5 9365 59541 5 9577 59603 59679 58627 58676 58776 5 8804 5 8 07 590 24 59134 5 9209 56516 56840 56843 5 6847 57238 57265 57489 575 79 57618 57 664 57985 58064 58065 58225 582 39 58465 546 85 5 5 680 55712 55732 55802 55851 56334 56443 5 7035 57036 54873 54889 55215 55267 55508 55558 55564 55397 VL SCC CE PX PXP PXP PX APX ION VITA APC COAL DAVIN NOW SINO CE MA MAB PHA PHA SUN SINO VITA IM IM COAL OM ATN DD DD MB MB MARC TA BKD CPM CYBR HOUSE DD SINO SINO SCC MARC CYBR SL DD CNPF DD DD ISSUE MA BHI LRW LRW VMC 14,210,000 100,000,000 9,470,000 100,000,000 2,000,000 3,313,000 2,000,000 70,000,000 2,646,000 3,000,000 1,912,000 5,000,000 1,000,000 15,000,000 5,000,000 5,354,000 4,130,000 2,000,000 2,000,000 1,100,000 1,190,000 2,000,000 2,000,000 1,000,000 969,000 2,000,000 2,000,000 1,465,000 560,000 300,000 80000 330,000 136, 900 201,100 1,001,000 1,000,000 400,000 870,000 501,000 999,000 600,000 516,000 500,000 682,000 361,400 500,000 394,700 198,900 500,000 810,000 845,000 20,000 500000 Shares 10,000 1,810,812.66 1,289,019.50 1,609,200.00 1,898,594.50 4,125,586.50 2,505,715.50 7,040,250.00 4,727,025.00 1,910,925.00 4,123,575.00 3,731,513.54 6,683,234.91 1,810,153.88 4,525,875.00 2,954,410.74 4,055,787.45 1,169,776.76 1,638,132.42 1,536,454.11 3,928,550.02 2,262,696.13 2,051,227.12 6,415,156.27 2,655,180.00 1,091,133.16 3,918,774.13 1,766,469.13 1,189,158.57 2,360,374.56 4,126,511.80 3,881,058.51 7,794,562.50 2,112,075.00 1,721,341.13 2,881,795.58 1,516,892.26 3,634,780.50 4,012,318.94 2,333,863.00 1,431,976.80 1,857,740.94 1,810,350.00 4,023,000.00 2,358,483.76 2,036,643.75 1,462,400.73 1,062,323.44 1,031,899.51 4,847,151.77 1,981,327.50 4,805,775.23 1,337,647.50 1,615,737.38 1,059,054.75 Total Debit

Page 25 of 216

377 378 376 3164 367 368 372 373 374 375 310 362 363 365 369 370 371 35 9 361 366 355 35 6 357 358 39 351 352 354 343 346 348 353 37 339 340 341 344 345 34 350 336 338 342 327 33 325 326 328 329 31 332 334 335 Number 330 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 Years 17-NoV 21-Nov 18-Nov 18-Nov 19-NoV 21-Nov 14-No 19-Nov 06-Nov 06-NoV 00-NO 11-NoV 12-Nov 12-No 17-N 30-Oct 04-No 04-NoV 05-No 05-Nov 06-Nov 06-NoV 07-Nov 11-Nv 12-Nov 21-Oct 05-Nov 14-Oct 21-Oct 21-Oct 21-Oct 31-0ct 24-Sep 25-Sep 02-Oct 08-Oct 02-Sep 11-Sep 16-Sep 18-Sep 23-Sep 25-Sep 25-Sep 07-Oct Date 20-Aug 28-Aug 02-Sep 16-Sep 13-Aug 13-Aug 20-Aug 02-Sep 03-Sep 12-Sep BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY 63423 63437 63480 63499 635 65 635 69 63688 63332 63333 63526 63689 REF # 63162 63197 63198 63277 63282 63327 63084 63154 63161 62823 62 900 62 90 63008 63068 63082 63132 61904 62435 61679 61703 61704 62013 62120 62228 62430 62440 62450 61358 61540 61641 60138 60576 60090 60714 60808 61128 61212 61317 61434 60164 60384 60689 60353 TUGS SUN TUGS I SUN PLC FPI LRW FP SUN IS SFI LRW LRW S S FPL SF BHI SFI WN SFI LF IS AR S S BH IS IS AR CE FPI SF CPM MED IM IM S CMT CEL TAPET CEI RWM AR ISSUE CE VUL TAPET CE CEI MRC MAC CE VUL 9,000,000 5,900,000 300,000,000 483,000,000 29,000,000 10,180,000 5,000,000 2,649,000 25,241,000 43,385,000 1,869,000 4,800,000 400,000,000 20,000,000 23,200,000 18,000,000 4,800,000 1,310,500 2,900,000 1,900,000 875,000 5,000,000 1,081,000 900,000 10,000,000 7,500,000 2,370,000 5,000,000 4,760,000 281,000 5,000,000 20,000,000 2,000,000 5,000,000 7,500,000 766,000 489,500 20,000,000 13,290,000 10,510,000 18,000,000 11,150,000 2,000,000 195,000 2,000,000 9,490,000 1,000,000 300,000 254,000 174,000 182,900 181,000 483,000 569,000 Shares 4,928,667.81 1,653,422.85 10,807,890.08 3,001,902.25 1,290,528.12 20,020,620.43 2,100,006.00 2,187,506.25 1,261,994.98 7,241,400.00 31,696,824.76 1,865,263.94 2,597,047.65 4,314,265.20 2,161,759.05 1,703,670.11 4,107,563.46 18,717,007.51 4,265,989.20 1,692,677.25 4,029,913.52 1,370,837.25 2,202,592.50 3,216,639.95 1,013,735.65 1,096,317.79 1,618,759.66 1,312,503.75 5,833,350.00 2,987,077.50 2,102,017.51 2,222,858.36 3,293,026.65 1,408,050.00 1,048,796.10 1,858,374.57 1,257,187.50 1,148,968.80 1,937,406.40 2,926,646.01 1,307,475.00 1,967,860.52 4,495,199.62 1,387,130.41 1,601,968.66 3,459,780.00 1,030,270.18 1,887,651.96 3,356,238.04 4,204,035.00 1,054,901.00 1,420,179.35 1,547,296.10 1,733,550.92 Total Debit

Page 26 of 216

432 430 431 420 421 422 423 424 426 428 429 411 412 414 417 418 419 425 427 383 401 413 415 416 382 38 388 397 3 98 402 405 407 408 409 410 37 380 381 385 387 389 3 0 3 1 3 2 393 394 3 6 3 9 400 403 404 406 Number 384 395 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2014 2014 2014 2014 2014 2015 2015 2015 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 Years 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 2014 23-Jan 20-Jan 20-Jan 22-Jan 08-Jan 08-Jan 19-Jan 23-Dec 29-Dec 05-Jan 06-Jan 08-Jan 12-J an 14-Jan 14-Jan 14-Jan 01-Dec 17-Dec 22-Dec 23-Dec 29-Dec 07-Jan 13-Jan 14-Jan Date O1-Dec 02-Dec 04-Dec 10-Dec 11-Dec 16-Dec 19-Dec 22-Dec 21-Nov 2-No 26-Nov 27-Nov 28-Nov O1-Dec 02-Dec 03-Dec 05-Dec 05-Dec 11-Dec 12-Dec 16-Dec 17-Dec 18-Dec 24-Nov 05-Dec 11-Dec 11-Dec 10-Dec 10-Dec 11-Dec BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY REF # 64889 64893 64931 64 960 64961 65032 65065 645 71 64638 64717 64720 64721 64846 64888 64891 64413 64465 645 06 64544 64570 64641 648 26 64230 64374 64375 64504 64545 64676 63690 63748 63811 63896 63959 639 90 639 92 639 93 64029 64085 64114 64143 64144 64148 64195 64196 64225 64231 64232 64236 64 257 643 25 6438 63857 64023 64193 UN ISM IM OV IS I IS UNI MARC LRW LRW FN FNI MED CE X X MARC MAXS MAXS MAXS UN LC S TUGS ROCK PSPC LRW X X LRW X I X X X IS PRMX IS UPM PSPC MAXS HSSUE LRW CHIPS S HR X CMT CMT IS PSPC LRW PSPC 99,000,000 19,900,000 10,530,000 5,300,000 100,000,000 20,140,000 1,400,000 1,950,000 3,100,000 20,898,000 15,920,000 10,330,000 3,000,000 9,900,000 2,580,000 1,454,000 1,446,000 19,210,000 721,000 1,326,000 9,995,000 2,950,000 7,900,000 372,000 1,970,000 1,190,000 1,073,000 495,000 553,000 950000 210,900 779,100 274,600 418,000 1,000,000 495,000 173,800 198,300 190,000 411,000 490,000 466,000 500,000 252,300 522,700 467,300 391,000 355,000 690,000 990,000 122,100 396,900 56,300 50,000 Shares 2,688,369.75 8,389,815.65 1,104,816.38 2,130,178.50 2,904,606.00 1,146,756.14 5,284,673.17 2,876,445.00 2,090,954.25 1,479,837.43 5,103,175.50 1,128,451.51 4,130,313.53 1,411,278.46 13,298,469.02 3,460,454.87 1,307,475.00 4,575,758.19 1,582,557.69 5,482,151.17 6,904,473.75 1,237,072.50 1,053,673.99 8,605,800.46 2,148,855.27 1,944,285.72 2,519,735.65 10,456,782.75 3,952,597.50 4,149,548.49 1,391,057.87 2,543,441.17 1,256,473.41 2,186,922.92 3,152,891.48 6,023,758.59 6,566,813.31 3,419,550.00 2,364,819.99 4,188,948.75 3,001,489.89 1,380,532.67 1,395,367.48 4,745,469.45 4,248,682.26 1,482,038.00 1,087,399.82 3,552,695.20 4,048,445.47 4,765,092.64 1,749,492.07 8,091,057.59 4,604,525.66 4,654,026.67 Total Debit

Page 27 of 216

486 48 479 483 471 474 45 478 481 482 484 61 463 465 466 470 472 473 476 477 480 456 459 460 464 467 468 469 455 45 458 462 445 44 447 40 452 453 454 Number 433 434 436 437 439 440 441 442 444 448 449 451 435 438 443 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 Years 2015 2015 2015 2015 2015 2015 2015 23-Mar 27-Mar 27-Mar 27-Mar 30-Mar 01-Apr 17-Mar 19-Mar 19-Mar 20-Mar 24-Mar 27-Mar 03-Mar 06-Mar 16-Mar 19-Mar 24-Feb 26-Feb 05-Mar 09-Mar 10-Mar 16-Mar 16-Mar 17-Mar 17-Mar 04-Feb 18-Feb 18-Feb 18-Feb 23-Feb 24-Feb 25-Feb 03-Mar 02-Feb 04-Feb 09-Feb 13-Feb 13-Feb 17-Feb 18-Feb 18-Feb 20-Feb 24-Feb 27-Feb 16-Mar 23-Jan 27-Jan 28-Jan 30-Jan 02-Feb 03-Feb 06-Feb 18-Feb 12-Feb Date BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY REF # 66 88 67043 67146 66615 66616 66698 66699 66745 66754 66846 66 77 66 978 66980 66251 66545 665 77 665 79 66707 66059 66084 66167 66168 66298 66391 665 78 66604 65 926 65981 65 982 65 989 66336 65682 657 64 65800 658 25 65826 65829 65831 65874 66021 65071 65169 65247 65303 653 77 653 79 65 440 65490 65689 65823 65138 65304 65345 65643 UN BH 2GO PPC ACR PRMX PPC S UN GTCAP NI N IS IS IS ACR JAS IS IS SF IS IS N FN FN 2GO 2G SFI UN 2GO CPM FN LRW DM UNI UNI SF ISSUE X CAL IS SR IS OM N FP LRW LRW CAL IS HOUSE LR IS FN LR 29,000,000 13,260,000 5,384,000 11,379,000 54,410,000 10,000,000 7,710,000 44,970,000 3,760,000 1,168,000 12,990,000 13,820,000 18,740,000 14,590,000 5,900,000 2,490,000 20,000,000 35,680,000 20,000,000 11,230,000 8,160,000 4,940,000 665,000 300,000 305,000 201,900 195,000 545,000 19,980,000 1,900,000 534,000 498,000 2,016,000 1,525,000 4,940,000 248,100 384,000 572,000 825,000 7,990,000 1,990,000 990,000 309,00 490,000 10,000 238,000 268,000 300,000 103,700 186,000 390,000 490,000 480,000 490,000 Shares 12,451,476.66 3,851,067.05 2,055,501.57 2,292,607.14 2,036,110.70 2,660,329.45 3,500,010.00 1,568,970.00 3,325,914.70 13,474,168.56 2,301,156.00 1,571,735.82 2,814,088.51 17,100,163.83 13,934,766.83 2,038,107.12 1,995,729.83 4,740,904.35 1,930,869.02 2,171,780.34 1,077,761.70 1,469,881.48 3,168,112.51 5,928,292.80 3,441,676.50 1,666,045.00 1,039,663.87 1,517,576.17 1,540,617.93 5,433,866.10 1,266,641.55 6,805,538.14 7,286,809.62 3,235,457.51 1,999,933.87 4,435,357.51 1,802,947.67 10,215,503.32 1,621,973.03 2,628,628.20 1,930,537.13 1,096,247.38 1,429,985.39 1,566,958.50 5,783,464.80 7,844,850.01 1,220,564.11 2,207,420.10 1,324,773.89 5,124,195.69 1,622,928.50 5,028,750.01 1,712,389.95 1,309,486.51 Total Debit

Page 28 of 216

50 539 53 5036 537 538 531 53 534 529 530 5 32 528 525 526 14 17 518 19 5 20 524 527 5 11 5 12 513 516 521 522 523 510 5 15 9 50 02 03 05 507 508 50 495 498 501 504 506 493 496 4 7 490 492 494 Number 48 488 489 491 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 20 15 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 Years 2015 2015 2015 17-Jun 05-Jun 08-Jun 05-Jun 01-Jun 04-Jun 03-Jun 19-May 19-May 22-May 25-May 29-May 29-May 29-May 15-May 18-May 18-May 11-May 13-May 14-May 18-May 04-May 05-May 07-May 08-May 08-May 08-May 11-May 21-Apr 27-Apr 27-Apr 28-Apr 05-May 12-May 16-Apr 21-Apr 13-Apr 13-Apr 16-Apr 16-Apr 16-Apr 07-Apr 07-Apr 08-Apr 08-Apr 08-Apr 08-Apr 13-Apr 13-Apr 06-Apr 06-Apr 07-Apr 07-Apr 10-Apr Date BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN 68341 68441 68233 68295 68312 68325 68326 68230 68255 REF # 68047 68126 68140 68228 68000 68003 68004 68024 68043 678 90 67 85 67798 67817 67818 67861 67863 67913 67603 67628 67714 677 37 67744 67814 67406 67476 67477 675 74 67276 67304 67306 67307 67404 67405 67408 67244 67247 67308 67205 67207 67208 67228 67243 67163 67179 67203 POP PXP PHA FNI MHC FNI CROWN FN LB FNI CAL PXP GT CAP ICT APC TA GTCAP POP POP ICT LB POPI ATNB TAPET MAXS MAXS LRW BRN CAL POP TA POPY I CROWN NIKL NIKL NIKL GEO GEO NIKL MEG POPI NIKL MEG N NIKL NIKL FN FN MEG GERI ISSUE NIKL NIKL FN 3,617,000 2,776,000 2, 90,000 3,524,000 7,262,000 2,990,000 5,800,000 2,990,000 990,000 990,000 500,000 1,059,000 1,000,000 1,130,000 3,000,000 676,000 990000 6,200,000 1,480,000 4,920,000 346,000 2,900,000 1,443,500 1,881,000 2,195,000 7,000,000 2,990,000 2,000,000 398,700 1,000,000 250,000 40,620 22,100 1,593,000 670,000 195,000 91,300 1,044,000 232,200 305,300 495,000 990,000 2,000 247,600 217,600 300,000 107,500 200,000 352,400 195,000 2,000 282,400 995,000 495,000 Shares 5,190,283.51 5,204,434.41 12,193,783.42 6,011,347.63 4,339,016.72 2,156,730.29 5,527,954.01 2,507,214.06 1,970,988.37 1,494,946.80 2,100,508.87 2,079,780.38 1,543,323.37 1,483,481.25 1,082,891.03 2,866,387.50 2,662,069.39 2,413,800.00 2,335,975.08 11,578,400.20 3,219,204.60 1,156,612.50 2,606,853.71 2,812,077.00 1,251,776.56 4,568,506.73 2,750,726.25 2,787,939.00 1,688,905.70 1,113,968.70 5,853,465.00 2,156,490.93 6,138,890.82 4,714,583.88 1,383,308.55 1,831,571.33 1,682,770.61 1,649,083.03 1,741,104.11 6,773,967.62 3,641,187.13 5,240,601.17 1,151,146.25 3,527,145.14 3,102,738.75 4,578,668.84 2,663,477.45 8,546,043.82 2,333,128.80 7,241,400.00 4,792,398.75 4,032,876.48 6,049,309.67 1,162,395.56 Total Debit

Page 29 of 216

583 589 5 90 591 2 5 93 594 5 5 5 9 580 581 582 584 588 5 577 585 586 587 5 70 571 572 574 578 552 510 561 563 564 5 65 58 569 573 541 542 545 546 54 550 551 554 555 556 55 9 562 566 567 544 548 549 553 557 558 Number 543 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 Years 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 [12-0ct 01-Oct 06-Oct 07-Oct 09-Oct 09-Oct 23-Sep 28-Sep 28-Sep 28-Sep 29-Sep 30-Sep 01-Oct 01-Oct 09-0ct 12-Oct 07-Sep 22-Sep 27-Jul 04-Aug 07-Aug 14-Aug 19-Aug 20-Aug 24-Aug 28-Aug 17-Sep 21-Sep 23-Sep 02-Jul 09-Ju 16-Jul 22-Jul 24-Jul 27-Ju 28-Jul 29-Jul 07-Aug 07-Sep 14-Sep Date 17-Jun 23-jun 25-Jun 29-Jun 03-Jul 07-Jul 08-Ju 08-Jul 14-Jul 15-Ju 11-Aug 19-Jun 19-Ju 30-Jun BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY REF # 70094 70095 70127 6 759 6 9834 6 9872 698 98 69921 69927 70087 70110 69518 69681 6 730 6 758 69833 69842 6 928 6 9 9 70022 693 79 69 444 6946 69582 689 59 68987 6 070 69107 69108 69136 69210 69 263 69290 69315 685 66 68618 68718 687 73 68794 68807 68873 68 9 08 68938 68939 68445 68480 68499 68537 685 95 68643 68670 68689 686 2 68479 NW ION LB MCP SPH UN DAVIN UNI IO SPH PBB PA SBS ION I SG ION DAVIN MED ISM I LB GERI SBS PPC CAL AR SBS POP POP PA LB I AR MCP GTCAP PPC PPC AR POPI ICT POPI ICT ATN AR POPI AR LB PLC TA ISSUE TAPET TAPET POPI ICT 1,500,000,000 298,000,000 40,000,000 520,000,000 498,000,000 300,000,000 10,000,000 5,000,000 20,000,000 1,000,000 9,000,000 1,588,000 1,212,000 1,310,000 3,750,000 1,490,000 1,000,000 1,980,000 2,305,000 1,000,000 4,000,000 641,000 777,000 11,900,000 19,950,000 1,000,000 2,000,000 841,000 737,000 563,000 177,000 2,500,000 2,000,000 750,000 1,990,000 917,000 527,000 500,000 1,000,000 990,000 559,000 441,000 800,000 500,000 495,000 500,000 227,600 888000 590,000 15,000 Shares 00,000 15,000 2,000 15,000 3,802,740.75 1,337,245.19 1,555,573.42 2,560,438.35 1,623,763.26 2,061,546.13 3,172,276.30 7,241,922.99 2,675,677.21 2,607,879.57 2,133,155.55 1,568,970.00 2,898,269.77 4,002,885.00 4,743,519.30 3,361,880.30 4,023,000.00 2,865,240.95 5,256,954.68 2,524,211.24 2,604,892.51 2,002,548.82 2,103,445.67 1,455,672.26 4,884,143.27 1,815,670.40 5,016,057.44 2,154,457.30 1,867,496.72 5,762,323.95 2,031,615.00 4,623,261.77 9,252,900.00 1,033,559.00 1,119,429.93 2,698,982.43 1,393,245.36 1,667,030.63 1,697,203.13 2,661,888.35 5,616,359.44 3,500,010.00 1,102,483.04 1,828,252.35 3,255,612.75 3,082,834.98 3,042,192.60 3,584,493.00 2,836,215.00 1,764,326.90 1,750,005.00 1,667,030.63 1,780,177.50 1,071,053.34 Total Debit

Page 30 of 216

68 64 64 641 643 644 645 635 636 637 638 646 639 642 626 62 632 634 625 628 629 630 631 633 618 620 622 624 613 616 619 621 623 603 605 608 09 612 614 615 617 5 9 5 9 602 604 66 60 610 611 596 597 5 98 60 601 Number 2016 2015 2015 2015 2015 2015 2016 2016 2016 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 Years 2015 2015 12-Jan 05 -Jan 23-Dec 28-Dec 05-Jan 05-Jan 22-Dec 23-Dec 28-Dec 03-Dec 04-Dec 07-Dec 08-Dec 09-Dec 09-Dec 11-Dec 14-Dec 18-Dec 27-No 02-Dec 10-Dec 17-NoV 24-Nov 26-No 10-NoV 12-NoV 16-No 23-Nov 28-Oct 30-Oct 05-No 06-NV 11-NoV 11-No 13-No 26-Oct 27-Oct 04-Nov 05-Nov 20-Oct 21-Oct 22-Oct 23-0ct 27-Oct 27-Oct 21-Oct Date 12-Oct 14-O ct 19-Oct 19-Oct 13-0ct 13-Oct 14-Oct 16-Oct BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN 71193 71106 70949 71038 71048 71053 71063 71068 71104 71105 REF # 70 919 70934 71007 70887 70898 70904 70645 70694 70723 70742 70773 70806 70826 70864 70617 70638 70675 70511 70546 705 63 705 66 705 92 70419 70468 704 90 70491 70319 70373 70374 70389 70161 70166 70176 70234 70253 70254 70282 70303 70304 7035 70349 70372 70128 70195 LB PLC IDC PLC MCP NOW IO ION EG MCP X NOW NOW NOW IDC IDC F p ION CROWN NOW DAVIN NOW IO FIP MRSG CROWN NOW IO LG PA PPC PXP BRN BRN PA PPC PPC LB LB LB ISSUE IO IO NOW SFI NOW NOW SUN NOW ION ATN CYBR NOW SFI NOW 100,000,000 230,500,000 5,000,000 100,000,000 2,000,000 5,000,000 1,968,000 1,206,000 1,000,000 1,532,000 1,000,000 2,000,000 5,300,000 2,000,000 2,000,000 1,270,000 4,228,000 1,346,000 374,000 1,000,000 300,000 2,309,000 1,000,000 5,000,000 700,000 361,700 200,000 5,000,000 17,930,000 2,300,000 2,000,000 1,500,000 1,000,000 500,000 300,000 1,500,000 7,000,000 5,000,000 2,000,000 5,000,000 5,000,000 1,236,000 1,472,000 646,000 5,257,000 1,399,000 500,000 875,000 891,000 626,000 897,000 690,000 625,000 500,000 Shares 3,268,687.50 4,717,741.95 3,859,545.52 1,197,224.68 1,709,775.00 3,418,162.05 2,514,375.00 3,136,833.68 1,028,067.57 1,106,325.00 3,256,266.49 4,309,880.12 1,674,553.64 3,459,780.00 2,779,842.72 2,603,343.65 5,793,693.28 2,164,794.40 3,034,750.05 2,534,490.00 1,689,660.00 9,107,569.12 3,438,971.02 1,605,076.42 2,062,793.25 4,324,725.00 1,679,602.50 1,807,604.30 3,993,430.95 1,221,091.11 3,835,669.03 2,260,755.02 2,552,050.40 6,684,858.19 4,322,089.92 1,568,175.45 4,819,724.98 7,039,926.16 1,382,906.25 4,763,674.51 2,957,206.72 2,252,880.00 1,910,925.00 2,524,432.51 8,297,437.50 3,147,997.51 2,169,111.10 3,447,077.39 1,005,750.00 2,124,194.29 1,387,100.22 4,253,125.67 1,377,877.50 1,759,459.06 Total Debit

Page 31 of 216

72 93 6 699 684 691 695 698 700 71 685 686 68 688 689 690 692 694 6 6 67 680 681 683 668 669 671 673 66 682 64 650 655 657 65 8 65 9 662 663 664 66 667 670 672 674 675 677 678 Number 652 653 654 656 660 661 665 651 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 Years 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 22-Apr 22-Apr 05-Apr 07-Apr 11-Apr 11-Apr 12-Apr 13-Apr 04-Apr 05-Apr 11-Apr 14-Apr 29-Feb 02-Mar 08-Mar 21-Mar 21-Mar 28-Mar 29-Mar 29-Mar 17-Feb 17-Feb 22-Feb 03-Mar 04-Mar 08-Mar 14-Mar 17-Mar 17-Mar 22-Mar 22-Jan 25-Jan 29-Jan 02-Feb 03-Feb 09-Feb 19-Feb 19-Feb Date 13-Jan 20-Jan 25-Jan 01-Feb 02-Feb 02-Feb 09-Feb 10-Feb 15-Feb 15-Feb 15-Feb 16-Feb 13-Jan 10-Feb 12-Feb 18-Jan BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY REF # 72751 72955 72491 72624 72646 72651 72701 72740 72745 72771 72786 72808 72948 72319 72370 72391 72446 72453 71800 71823 71874 719 29 71963 72016 72101 722 20 72322 72369 71264 71301 71619 71676 71699 71702 71705 71733 71752 71760 71797 72088 71202 71349 71369 71371 71465 71481 71503 715 04 715 17 715 5 71597 71628 71200 71505 NW ISM VITA COAL PXP APC IS ST Nw BRN VITA VITA DAVIN O0 PXP BRN NOW ATN NOW NOW LCB PLC DAVIN S PXP PLC IRC MCP MAB DAVIN MA LCB PLC PLC LC LC IS ION LCB LI PLC PLC DAVIN PLC SS MCP SI MA PA LC PLC SS DAVIN PLC ISSUE 100,000,000 23,000,000 112,900,000 3,000,000 3,000,000 200,000,000 108,700,000 8,480,000 2,000,000 4,000,000 4,000,000 2,214,000 4,362,000 2,000,000 5,000,000 1,000,000 1,000,000 2,298,000 25,000,000 5,000,000 30,000,000 11,340,000 10,000,000 2,000,000 50,000,000 4,000,000 15,000,000 10,000,000 5,000,000 5,000,000 500,000 3,000,000 4,160,000 3,000,000 550,000 2,500,000 5,000,000 5,065,000 1,000,000 1,000,000 1,500,000 1,000,000 1,500,000 560,000 5,000,000 4,310,000 300,000 990,000 1,000,000 500,000 940,000 300,000 500,000 500,000 Shares 2,413,800.00 6,664,652.66 2,889,771.18 1,805,723.55 3,951,893.49 3,519,018.68 2,453,396.40 2,845,488.00 3,086,988.71 9,271,164.40 6,487,087.50 1,653,764.80 2,363,512.50 4,827,600.00 7,968,758.42 1,755,777.99 2,591,948.51 1,295,285.31 2,151,832.29 1,358,305.59 3,209,297.96 2,383,627.50 4,701,881.25 2,313,225.00 4,626,450.00 4,140,944.32 2,832,192.00 3,479,895.00 1,810,350.00 1,433,193.75 1,307,475.00 1,520,694.00 3,466,588.93 9,956,925.00 3,771,562.50 1,333,624.50 2,109,912.65 6,761,154.38 3,215,885.62 1,380,824.32 2,406,709.47 1,795,263.75 2,262,937.50 2,614,950.00 1,421,225.33 1,476,139.27 1,709,775.00 8,272,293.74 1,421,728.20 3,577,261.66 4,324,725.00 2,358,383.17 1,408,050.00 3,153,116.76 Total Debit

Page 32 of 216

55 756 42 45 746 7 749 153 754 732 733 738 740 741 743 744 748 750 751 752 734 735 73 7 37 739 7 723 724 726 727 728 729 730 731 Number 703 04 06 09 11 12 13 718 19 721 725 705 707 708 710 714 15 16 717 720 201608-Jul 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 Years 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 24-Jun 28-Jun 28-Jun 30-Jun 01-Jul 04-Jul 05-Jul 07-Jul 07-Jul 17-Jun 21-Jun 23-Jun 28-jun 06-Jun 13-Jun 13-Jun 13-Jun 14-Jun 14-Jun 15-Jun 02-Jun 08-Jun 0 -jun 13-Jun 16-Jun 17-Jun 25-Apr 28-Apr 04-May 05-May 05-May 10-May 11-May 17-May 17-May 18-May 20-May 23-May 24-May 26-May 30-May 10-Jun Date 25-Apr 26-Apr 27-Apr 02-May 05-May 11-May 12-May 13-May 18-May 26-May 28-Apr BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY REF # 73984 73 985 740 26 74036 74063 74085 74096 740 9 74115 73766 73784 73808 73826 73827 73860 739 09 73941 73982 73712 73732 73746 73749 73750 73767 73555 735 94 73643 73 659 73693 73751 73253 73255 73290 7315 7346 7377 73419 73480 73494 73509 73553 73001 73032 73059 73081 730 90 73132 73169 73198 73201 73205 73234 734 25 73000 APO T T HV VITA NW ATN SBS APX HVN NOW NOW NOW DD DD NOW PX P PXP DD DC ALT PLC DD NOW CYBR IDC ATN ATN PXP LC T ALT ALT ACR ALT LB PHA DD ISSUE SLS IS ATN LC S IS IS ACR IS ATN ATN ARA NOW IS ATN PGOLD 11,550,000 1,000,000 25,000,000 1,500,000 1,507,000 1,500,000 6,138,000 20,000,000 1,000,000 1,049,000 1,162,000 1,000,000 14,060,000 30,000,000 4,000,000 11,000,000 20,000,000 30,000,000 12,620,000 3,040,000 6, 960,000 30,000,000 1,225,000 1,961,400 2,000,000 3,000,000 873,000 300,000 816,000 7,000,000 3,560,000 2,000,000 3,000,000 816,000 286,400 1,100,000 5,000,000 3,000,000 565,000 766,000 300,000 100,000 788000 500,000 500,000 300,000 678,000 813,000 100,000 500,000 600,000 50,000 90,120 30000 Shares 10,308,931.47 6,023,318.08 5,807,944.76 6,719,657.15 3,380,104.51 3,781,620.00 22,467,635.34 6,939,675.00 3,294,229.54 3,017,250.00 5,314,614.34 16,015,261.28 6,133,689.08 3,183,701.65 1,886,515.46 3,942,540.00 2,625,007.50 5,890,515.83 2,309,081.32 3,467,463.91 4,634,274.73 6,335,420.40 1,229,046.61 5,431,050.00 6,317,216.32 1,271,066.85 11,566,125.00 10,284,306.70 3,318,975.00 1,675,318.00 1,508,625.00 4,328,778.17 4,594,517.44 11,968,425.01 2,590,007.40 2,459,370.54 2,262,937.50 3,384,811.40 2,779,661.67 3,379,320.00 7,356,357.22 1,538,797.50 9,328,331.25 3,741,379.96 2,189,467.47 3,967,723.98 1,543,323.37 5,642,659.80 7,195,849.58 7,593,412.51 1,985,199.64 1,131,267.60 1,448,280.00 1,267,245.00 Total Debit

Page 33 of 216

810 808 809 04 05 0 1 03 806 0 02 4 1 7 7 98 7 9 2 195 191 3 8 7 1 78 785 786 788 789 783 784 781 4 773 719 780 2 73 775 776 770 1 719 771 764 765 766 717 76 710 7161 758 75 9 712 763 757 Number 201627-Oct 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 Years 25-Oct 19-Oct 20-O0ct 06-Oct 06-Oct 17-Oct 27-Sep 27-Sep 03-0ct 03-Oct 05-Oct 06-Oct 26-Sep 30-Sep 23-Sep 01-Sep 05-Sep 15-Sep 15-Sep 22-Sep 25-Aug 30-Aug 31-Aug 02-Sep 23-Aug 24-Aug 02-Aug 15-Aug 16-Aug 18-Aug 29-Jul 02-Aug 05-Aug 05-Aug 16-Aug 21-Jul 26-Ju 27-J ul 28-Ju 14-Jul 15-Ju 18-Jul 19-J 20-Ju 14-J 13-Jul 08-Jul 08-Ju 12-Ju 08-Ju 11-Jul Date 11-Jul 13-Jul BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY 75655 755 46 755 77 75587 75 620 75428 75446 75455 75 457 75397 75399 75 342 75378 75306 75315 75333 75218 75220 75291 75130 75040 75103 74926 74968 75016 750 79 747 76 74825 74904 74759 74775 74558 745 59 74611 74619 REF # 74492 745 26 74329 74432 74468 74278 74302 74244 74264 74197 74198 74215 742 29 74128 74141 74173 74121 74124 74125 LHC PXP MRC LB WEB MED APL WEB TUGS MRC FN PXP MRC MRC MRC MED MRC PXP MRC FNI UNI CAL CAL VITA NOW NOW NOW IM TUGS LR VITA MRC IDC BH VITA VITA BHY BHL ALT IDC PXP BHI BH IS ALT PXP PXP ALT VUL ALT VITA VUL ALT ALT ISSUE 50,000,000 5,000,000 20,000,000 20,000,000 1,000,000 6,000,000 2,000,000 8,773,000 1,500,000 15,000,000 6,000,000 5,000,000 12,000,000 20,000,000 5,000,000 1,000,000 439,800 520,000 1,096,000 9,300,000 20,000,000 5,000,000 20,000,000 4,000,000 1,000,000 50,000,000 1,000,000 3,000,000 3,000,000 500,000 20,000,000 18,000,000 20,000,000 800,000 750,000 50,000,000 500,000 4,000,000 2,500,000 363,000 637,000 1,000,000 910,700 500,000 700,000 8,000,000 1,069,000 300,000 800,000 779,000 8000 1,931,000 967,00 411,000 Shares 8,245,440.24 6,989,841.82 5,159,145.51 3,571,070.26 4,704,837.15 2,297,344.20 3,969,675.16 3,208,342.50 4,716,967.50 5,516,096.23 1,265,474.88 5,232,464.67 5,642,257.50 4,405,637.59 4,958,347.51 3,687,954.51 3,590,497.33 1,156,612.50 2,110,898.28 2,268,972.00 3,664,248.99 3,899,795.62 3,867,108.75 6,798,870.00 1,709,775.00 12,277,431.64 4,019,221.40 3,186,065.15 20,467,012.51 4,978,462.50 5,943,982.50 1,450,291.51 2,564,883.76 23,534,550.01 2,359,871.67 2,816,100.00 3,329,032.50 5,971,650.69 2,112,075.00 4,021,042.83 7,327,492.20 6,135,075.00 4,948,290.02 1,408,050.00 5,510,001.37 2,270,098.43 4,375,012.50 4,377,526.90 5,089,265.98 1,931,040.00 2,819,620.12 8,317,552.50 1,581,835.57 1,607,540.52 Total Debit

Page 34 of 216

4 8 63 854 85 85 6 85 7 85 9 860 862 850 852 853 858 861 845 848 84 851 834 835 83 839 842 843 846 847 833 838 840 841 844 832 836 826 827 828 830 831 811 19 821 824 825 82 813 814 815 816 820 822 823 Number 812 817 818 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2016 2016 2017 2017 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 2016 Years 30-Jan 31-Jan O1-Feb 02-Feb 23-Jan 27-Jan 31-Jan 25-Jan 26-Jan 16-Jan 20-Jan 27-Dec 28-Dec 05-J an 0 9-Jan 09-Jan 09-Jan 11-Jan 17-Jan 17-Jan 19-Jan 21-Dec 23-Dec 03-Jan 08-Dec 21-Dec 23-Dec 29-Dec 02-Dec 07-Dec 07-Dec 12-Dec 15-Dec 16-Dec 29-No O1-Dec 05-Dec 05-Dec 06-Dec Date 28-Nov 29-NV O1-Dec O1-Dec 02-Dec 17-Nov 18-No 24-Nov 28-Nov 08-NV 22-No 09-Nov 09-NV 10-NoV 15-Nov BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY 7705 6 76841 76924 76 68 76986 769 8 77005 77046 REF # 76710 76797 76802 76866 76873 76916 76662 76776 765 11 765 74 76654 76661 76308 76393 76421 76422 76459 7647 76486 76183 76229 76293 76396 76127 76151 76171 75727 760 92 76102 76117 76136 76022 76023 76043 76044 76068 76069 76078 75751 75754 75778 75856 75878 75 923 75971 75828 DNN LMG SBS STE WEB MA LMG LMG APL ALCO ALCO ST ALCO NOW WEB WEB LIHC ALCO ALCO PA WEB DFNN DFNN LIHC APL LIHC LIHC PIZZA TUGS LHC LIHC SL ALCO ALCO ALCO FNI FN WEB LHC WEB EW ALCO ISSUE CPG LIHC ALCO LIHC LIHC CDC CDC LIHC SL CPG LIHC LIHC 50,000,000 10,000,000 150,000,000 6,000,000 90,100,000 10,000,000 5,000,000 2,731,000 30,000,000 610,000,000 2,000,000 2,102,000 5,000,000 300,000 500,000 2,000,000 2,450,000 200,000 800,000 176, 900 22,000,000 10,000,000 2,000,000 1,000,000 4,950,000 600,000 21,593,000 3,580,000 1,000,000 2,120,000 500,000 200,000 4,513,000 7,039,000 12,000,000 7,000,000 10,074,000 1,890,000 2,194,000 2,000,000 2,000,000 6,640,000 210,000 237,900 708,400 8,407,000 5,000,000 6,000,000 2,000,000 2,000,000 250,000 300,000 880,000 444,900 Shares 2,579,748.75 2,140,262.15 3,117,825.00 3,591,190.29 5,547,767.30 2,309,650.56 10,912,387.50 5,530,729.89 2,279,763.69 4,943,301.50 3,620,700.00 1,267,245.00 1,654,946.55 7,844,850.01 12,267,697.97 2,052,672.43 1,146,555.00 3,369,262.50 2,730,108.38 1,087,416.90 33,345,641.25 2,398,713.75 2,471,127.75 5,613,342.19 2,486,455.37 2,330,222.18 5,723,683.04 8,096,287.50 11,020,445.29 13,275,900.00 6,269,078.13 33,179,058.88 4,777,312.50 3,230,670.15 15,051,451.05 3,212,627.00 1,266,339.83 2,534,490.00 12,898,381.70 1,584,257.40 1,023,451.20 16,806,303.78 13,546,346.16 2,833,901.77 2,926,732.50 6,164,931.69 5,495,971.16 9,055,602.03 3,414,752.59 4,520,836.19 3,321,288.23 9,594,855.00 5,798 148.77 1,753,726.28 Total Debit

Page 35 of 216

918 0915 916 917 910 9911 912 913 914 907 909 04 906 0900 9 901 902 905 895 891 897 0 903 83 4 898 892 893 885 886 888 88 8 0 8 1 87 1 882 887 3 71 879 80 883 884 1 874 875 877 65 867 872 Number 866 818 819 870 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 Years 10-May 05-May 20-Apr 24-Apr 04-Apr 05-Apr 07-Apr 19-Apr 29-Mar 03-Apr 04-Apr 04-Apr 05-Apr 10-Apr 12-Apr 18-Apr 29-Mar 03-Apr 21-Mar 22-Mar 22-Mar 28-Mar 06-Mar 06-Mar 07-Mar 20-Mar 03-Mar 17-Mar 24-Feb 02-Mar 20-Feb 22-Feb 24-Feb 01-Mar 01-Mar 02-Mar 22-Feb 24-Feb 07-Feb 08-Feb 10-Feb 10-Feb 14-Feb 16-Feb 16-Feb 16-Feb 17-Feb Date 02-Feb 02-Feb 06-Feb 08-Feb 08-Feb 14-Feb 03-Feb BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY 78352 77 979 77 95 78025 78045 78065 78078 78118 782 95 77913 77914 77872 77891 778 9 77900 77815 77832 77879 REF # 77750 77758 77766 778 27 77567 77568 775 90 77721 77728 775 25 77550 77503 77513 775 34 77351 77364 77383 77416 77417 77460 77469 77470 77288 77297 77335 77350 77158 77186 77200 77245 77252 77057 77059 77082 77142 77185 BHI MRC RLT CHP ATN CPM CPM LMG ATN 2GO 2GO CHIB ALCO MRC CHIB 2GO CHIB CHIB LMG MRC DFNN LMG LMG MG ALCO APL PGOLD LMG APL RLT APX DFNN LMG DFNN LMG LMG PSPC DFNN DFNN APX APL APL LMG LMG CPG RLT PA RLT BSC ISSUE DFNN DN BSC ALCO FPH 15,000,000 70,000,000 20,000,000 20,000,000 100,000,000 5,871,000 30,000,000 1,000,000 1,500,000 1,161,000 9,000,000 200,000,000 14,650,000 2,000,000 2,000,000 5,000,000 241,300 29,980,000 287,000 355,500 2,205,000 400,000 160,000 50,000,000 3,000,000 268,100 88,700 50,000,000 300,000 700,000 13,900,000 343,600 242,500 818,000 71,200 9,900,000 16,380,000 5,000,000 5,000,000 795,000 182,000 9,399,000 549,000 228,900 328,700 700,000 468, 900 148,000 30,000 300,000 171,300 276,800 600,000 Shares 20,000 12,257,497.68 1,234,186.00 6,984,491.23 9,947,591.67 3,690,866.14 8,025,885.00 4,444,550.08 4,012,942.50 6,319,781.00 9,051,749.99 5,229,900.00 3,624,093.42 9,303,187.50 2,686,509.12 2,917,167.82 4,657,628.25 1,146,555.00 4,820,678.45 14,734,237.50 2,291,953.39 6,557,349.21 5,783,062.50 3,787,654.51 2,715,525.00 6,581,502.30 6,416,926.39 2,021,557.50 3,045,489.46 1,378,883.26 1,562,935.51 2,039,661.00 4,147,753.24 1,851,756.73 1,797,035.90 1,451,459.17 8,111,373.75 5,040,617.83 1,956,837.49 5,805,943.34 5,583,873.72 1,360,664.09 2,643,352.37 5,109,332.70 1,339,341.18 5,675,447.25 3,369,262.50 1,839,295.49 1,214,744.85 2,641,128.67 5,642,257.50 3,369,262.50 1,448,280.00 8,202,997.57 4,475,587.50 Total Debit

Page 36 of 216

967 919 971 72 966 68 970 95 3 95 4 958 961 962 914 965 8 052 956 57 959 960 963 94 945 946 947 94 950 951 955 37 39 941 942 943 944 9 20 21 9203 925 926 927 928 929 930 931 932 935 931 938 Number 919 922 933 934 924 2018 2018 2018 2018 2018 2018 2018 2018 2018 2017 2017 2018 2018 2018 2018 2018 2018 2018 2017 2017 2017 2018 2018 2018 2018 2018 2018 2018 2018 2017 2017 2017 2017 2018 Years 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 2017 14-Mar 20-Feb 21-Feb 26-Feb 28-Feb 01-Mar 07-Mar 09-Mar 09-Mar 09-Mar 14-Feb 15-Feb 22-Feb 27-Feb 07-Mar 22-Jan 09-Feb 12-Feb 12-Feb 14-Feb 14-Feb 05-Dec 18-Dec 09-jan 22-Jan 25-Jan 01-Jun 07-Jun 28-Jun 28-Sep 26-Oct 00-NoV 06-NV 13-Nov 15-NV 24-Nov 14-Dec 15-Dec 15-Dec 19-Dec 09-Jan 30-May 02-Jun 02-Jun 07-Jun 22-Sep 04-Oct 04-Oct 04-Oct 01-Dec 06-Dec 12-May Date 17-May 23-May BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY REF # 820 98 8236 81942 81971 82134 82150 82253 82254 82330 8237 82427 81362 81414 81694 81760 81764 81765 81836 81896 82068 81234 81235 81361 81673 81698 81053 1095 81153 80092 80355 80438 80456 80618 80623 8075 80871 80 35 80951 81072 81084 78492 78581 78682 78759 78760 79003 79886 79 9 800 0 80091 78389 78433 78656 78663 ION ION DAVIN MBT S P SP PXP PXP PXP MRC APC TBGI MRC PRIM PRIM PGOLD NOW PGOLD NOW CE NOW POPI NOW PXP SHLPH MJC SHLPH TB GI CHIB CHIB MER NOW WP PXP CL NRCP NRCP BKR EDC PXP IDC IDC CHIB CHIB ISSUE PX RLT ACR PGOLD DM PXP IDC GSMI IDC TUGS 25,000,000 35,000,000 22,418,000 15,000,000 12,000,000 1,345,000 1,655,000 1,500,000 1,178,000 1,000,000 1,000,000 3,000,000 1,300,000 1,312,000 822,000 688,000 840,000 500,000 300,000 1,800,000 6,000,000 1,990,000 700,000 625,700 50,000 6,000,000 2,000,000 2,000,000 1,121,900 1,098,000 1,715,000 3,000,000 200,000 990,000 551,700 500,000 300,000 300,000 554,000 100,000 200,000 500,000 236,800 150,000 300,000 86000 20,000 20,000 211,500 128,200 35,690 19 940 30,000 5,000 Shares 2,051,488.62 4,852,027.15 13,066,995.67 14,784,525.00 9,502,945.54 17,600,625.00 11,616,412.51 13,314,088.32 10,620,720.00 4,932,369.00 1,388,900.53 6,519,472.67 5,619,034.74 15,387,975.00 1,707,240.49 3,296,124.37 7,550,780.77 3,933,196.58 1,960,548.70 2,880,266.85 1,091,880.41 7,005,048.75 2,094,505.55 3,230,469.00 10,041,357.72 6,698,295.00 1,072,659.55 9,006,491.26 5,278,342.97 5,280,187.51 3,268,299.29 11,965,085.89 1,064,194.12 4,586,220.01 6,066,280.69 7,337,187.62 4,634,618.71 2,712,789.37 1,200,724.70 3,349,147.50 1,655,846.69 2,010,735.63 5,277,170.25 2,011,583.47 3,510,937.48 2,062,994.40 4,224,150.00 6,706,914.27 1,649,430.00 3,800,910.29 1,369,831.50 1,130,362.41 5,233,420.13 1,807,435.35 Total Debit

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1026 1025 1022 1023 1024 10006 1019 1020 1021 1013 1015 1016 1017 1018 1005 1007 1008 1009 1010 1011 1012 1014 91 9 994 91 997 998 9 9 1003 1004 988 98 1000 1001 1002 91 984 986 987 990 9 3 995 979 980 982 98 973 974 77 978 983 975 976 Number 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2018 2018 2019 2019 2019 2019 2018 2018 2018 2018 2019 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 Years 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 2018 24-Apr 21-Feb 01-Mar 14-Mar 26-Mar 26-Mar 30-Jan 31-Jan 08-Feb 12-Feb 28-Jan 04-Feb 04-Feb 07-Feb 11-Feb 23-Jan 24-Jan 25-Jan 27-Nov 27-Nov 24-Jan 01-Aug 08-Aug 24-Aug 03-Sep 03-Sep 07-Nov 13-No 13-Nov 21-NoV 13-Dec 02-Jul 05-Jul 06-Aug 25-Jun 05-Jul 13-Jul 27-Apr 05-Jun 05-Jun 19-Jun 20-Jun 25-Jun 10-Ju 20-Mar 04-Apr 05-Apr 05-Apr 07-May 24-May 24-May 29-May Date 27-Mar 03-May BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN BUY BUY BUY BUY 86028 86029 85664 85800 85873 85961 85995 85553 855 95 85617 85646 REF # 84888 85071 85435 8545 3 85 4 98 85517 855 46 84887 85398 85409 85414 84616 84714 84830 83885 84050 84111 84112 84713 833 55 8343 83474 83475 83532 83779 83834 83262 832 77 83356 83608 83002 83003 83051 83119 83128 82510 82637 82648 82649 82812 82829 82837 82592 PXP X X PHA SOC SOC X GREEN PHA PHA PHA PHA NOW PHA PHA PHA PHA PHA GEO 2GO SMC IM ISM ISM ISM NOW IRC SM ISM ISM PXP ATN SMC MER NOW IM ISM MER PXP NOW ABA ISM IRC TBG SSUE VUL EAGLE TB GI MRC MRC VUL CHIB NOW NOW BPI 2,000,000 10,000,000 2,000,000 2,000,000 1,000,000 2,124,000 6,000,000 10,000,000 2,000,000 5,000,000 2,000,000 2,000,000 1,000,000 1,000,000 4,014,000 3,000,000 3,000,000 779,000 700,000 1,000,000 8,000,000 7,000,000 11,790,000 10,000,000 2,000,000 2,000,000 1,000,000 702,000 10,000,000 100,000 15,000,000 1,000,000 500,000 605, 900 394,100 400,000 9,000,000 1,000,000 1,531,000 600,000 894,000 500,000 600,000 594,400 2005,600 500,000 606,000 41,00 10,000 6,00 35,000 50,000 70,000 5,000 Shares 5,242,602.62 5,218,293.65 3,195,227.54 12,958,334.44 1,242,785.15 2,755,755.00 6,329,399.98 10,057,500.00 4,401,805.70 2,044,790.32 2,383,627.50 2,497,488.45 2,775,870.00 2,517,150.88 1,554,849.30 10,336,726.36 3,337,219.29 4,672,302.15 1,627,504.65 2,214,661.50 2,362,828.59 2,820,505.19 1,770,119.99 6,215,535.00 3,169,483.35 6,788,812.50 11,817,562.50 3,048,810.44 4,586,220.00 1,780,177.51 4,851,079.24 2,543,400.97 1,767,505.06 6,663,093.75 1,777,771.75 6,529,526.15 9,622,448.77 7,092,046.13 1,583,724.37 10,107,787.50 9,578,712.73 3,017,250.00 5,219,023.81 1,267,245.00 3,510,308.87 2,946,063.03 7,351,831.35 1,094,457.15 5,624,154.00 4,847,966.44 5,953,442.61 2,065,754.17 1,056,037.51 1,232,043.75 Total Debit

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1047 1044 1045 1046 100 1027 1038 1041 Number 1028 1030 1031 1032 1033 1034 1035 1036 1037 1039 1042 1043 1029 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 2019 Years 2019 2019 2019 2019 05-Jul 02-Jul 19-Aug 19-Aug 19-Aug 23-May 24-May 26-Jun 28-Jun 03-Sep 04-Sep 24-Oct 24-Oct 29-0ct 14-May 19-(un 06-Aug 19-Aug 20-Aug 27-Aug Date 13-Jun BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY TRAN REF # 86918 86250 86262 8633 86380 86424 86495 86693 86771 86778 86779 86781 86784 86849 86940 87189 871 90 86218 86441 86468 87231 SUN BDO KPPI SUN ISSUE PNB MHC ABA ABA ABA CHIB I PHA B PI ABA PRIM KPPI KPPI VUL T I PRIM 5,000,000 5,504,000 5,005,000 2,995,000 7,000,000 1,000,000 2,000,000 1,000,000 1,769,000 1,682,000 6,043,000 1,970,000 1,500,000 186,500 400,000 181,000 301,300 47,000 20,000 10,000 70,000 Shares 6,969,847.51 5,129,325.00 2,833,650.35 1,228,573.92 1,876,065.70 1,209,622.58 6,343,104.35 4,069,908.17 1,531,757.24 3,881,189.25 1,508,625.00 2,888,966.59 1,421,004.07 2,272,743.57 4,609,714.33 2,272,995.00 1,609,200.00 1,602,411.20 1,825,436.25 5,149,983.10 1,196,900.84 Total Debit

securities in numerous transactions amounting to more than P1,000,000.00 and as high as P33,000,000.00.in spite of his declared financial capacity amounting to P1,000,000.00 only. Therefore, to a reasonable mind, it would appear that there must be a suspicious securities transaction on the Sulapas account that Respondents intentionally and repeatedly ignored and did not bother to scrutinize and investigate. From the above, it is inexplicable how Mr. Sulapas was allowed to transact or buy

associated persons or salesman have an obligation to recommend to their customers only the purchase of securities that are reasonable and suitable to the customer's financial situation and needs. In addition, it is well-established that under the Suitability Rule, the broker dealers.

value of his alleged stock position amounting to Php44,639,825.00 which also served as illegal trades through this credit provided by VSI. even granted Mr. Sulapas a credit line22 allowing Mr. Sulapas to borrow up to 40% the the value of the collateral on Mr. Sulapas trading account without updating his source of funds and net income. Even though Respondents are aware of the reason of the abrupt change in Mr. Sulapas financial situation, they still actively facilitated the trades by giving credit line to the Sulapas account. Sulapas account was able to continuously conduct the standing and that his account is a Cash Account, Respondents through Respondent Racadio Not only that, despite being aware that Mr. Sulapas has only One Million Financial

client's financial situation but they are also required to conduct ongoing diligence to update itself as to the changes in the financial situation of its clients. Despite Respondents claim to know the true financial condition of Sulapas due to his alleged trading pattern, they did not fulfill their obligation to update the CAIF. It is clear from the KYC Rule that Respondents must not only be aware of their

22 Credit Line Agreement dated August 18, 2015 signed by Mr. Racadio, Annex 11of Respondents Position Paper, cited in Par. 3.46 pages 16&17 Respondents Answer and Annex H of Complainant Position Paper.

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investment experience and investment objectives. The purpose of getting the detailed information is to protect both parties in a business transaction and all stakeholders within the industry to preserve the integrity of the capital markets. business practice and to prevent the money laundering and other illegal acts as required under the SRC IRR. In other words, it is the process of identifying and verifying the clients in compliance with legal and regulatory requirements as well as part of good personal circumstances of the investors, their wealth status, the sources of their funds. To emphasize, the main purpose of the KYC Rule is to verify the identity of the

becomes known, then Respondents should have required the updating of the CAIF determine the true financial condition of their clients. If the true financial condition accordingly It is the reason why the KYC Rules imposes a strict duty on trading participants to

transactions with VSt. Sulapas as well as his dealings with VSI from 2012-2019 determined that he has the support for the argument, Respondents avers that this can be seen from the fact that he only made a few deposits into his account from 2012-2019 and Mr. Sulapas' EQ Trade transactions into his account also form a small portion of his buying and selling financial capacity for his numerous buy and sell transactions given that he can sustain funding for his transactions almost entirely from his trading activities. As additional Third, Respondents argued that the trading pattern allegedly established by Mr.

disproportionate to his buying transaction. discussed above, Mr. Sulapas financial capacity of P1,000,000.00 is already We find that the Respondents reliance on these justifications to be misplaced. As

transactions or by applying the prohibited credit line on the Sulapas account. Further, as payment to the transactions, VSI executed the unauthorized EQ Trade

transactions if not for the execution of the EQ Trade transactions. knowledge that Mr. Sulapas financial capacity cannot sustain funding for his buy and sell Thus, as early as May 30, 2012 there was already a clear indication of Respondents

PXP which was sold on the same day for Php 2,242,298.33. made dated 30 May 2012 (a day after account opening on 29 May 2012) were two (2) buy transactions of CAL shares amounting to Php 2,210,759.23 (Php1,482,032.99 and Php 728,726.24). This transaction was settled through an EQ Trade of 52,500 shares of Based on the Ledger of Mr. Julieto Sulapas with VSI (SU026), the first transactions

November 2019 for the transaction Buy 87228 dated 29 October 2019 for 20,000 shares of ALI at P48.80 per shares and that the Sulapas account has a total of Three Hundred Seventy Nine (379) EQ Trade transactions from R&L to VSI consisting of One Hundred Sixty Seven (167) Stock Credit Memo, to wit: paid cash for all of his transactions once for the amount of Php 981,612.00 dated 04 Furthermore, as observed in the account ledger of Mr. Sulapas (SU026), he has only

5/30/12 DATE Wedneday, 30 May 2012 Date 2 SCM TXN REF 5 422 Reference CLG91619769 Ledger PXP STOCK SHARES 52,500 R& TRANSFER

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6/0/16 2/26/16 2/26/16 2/26/16 6/22/16 7/ 9/15 12/29/15 1/13 /16 2/26/16 5/11/15 6/ 4/15 10/15/15 6/10/15 3 /25/15 4/10/15 4/14/15 5/13/15 3/25/15 3/19/15 5/16/14 6/24/14 6/24/14 12/19/14 / 5/13 6/24/14 11/ 7/14 11/13/14 83/24/12 5/21/13 6/18/13 7/ 3/13 7/24/13 9/20/13 11/28/14 6/18/13 8/24/12 2/ 6/13 8/ 6/12 10/ 5/12 10/5/12 11/26/12 7/10/12 6/28/12 Monday, 20 June 2016 2016 Wednesday. 20 16 2016 Friday, 2016 Friday. Thursday, 4 June 2015 Thursday, 15 October Tuesday, 29 December Friday, 2016 Tuesday, 14 April 2015 Monday, 11 May 2015 Wednesday, 13 May Wednesday, Thursday, 9 July 2015 2015 Wednesday, january 2016 Friday, Friday, 10 April 2015 2015 2015 2015 Wednesday, 25 March Wednesday, 25 March 2015 Friday, 28 November Friday, 19 December 2015 2015 Friday, 16 May 2014 Tuesday, 24 June 2014 Tuesday, 24 June 2014 2014 November 2014 2014 2014 Thursday, Friday, 5 July 2013 Friday, 20 September Tuesday, 24 June 2014 Thursday, Tuesday, 18 June 2013 2013 Friday, Thursday,28June Friday, 24 August 2012 Friday, 24 August 2012 Friday, 5 October 2012 Wednesday, February 2013 Tuesday, 21 May 2013 Tuesday, 18 June 2013 Wednesday. Wednesday. 2013 Friday, 5 October 2012 Monday, 26 November 2013 2012 Tuesday, 10 July 2012 2012 Monday. 2012 26 26 February 26 February 2 1 10 June November February 19 March February 22 June 6 24 July August 2 13 July 13 SCM 6 SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM S M SM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SM SCM SCM SC M SCM SCM SCM SCM 865 9 865 9 8843 8872 865 9 8583 85 5 8659 8221 8412 8164 8 183 8190 80 0 8157 8071 8071 8088 7940 8070 77 4 7844 7879 7149 7149 7149 6438 6460 6581 7112 5959 6396 6421 6421 643 5677 5 677 5751 5751 6108 5562 5 579 565 4 CLG95998864 CLG095570081 CLG095570077 CLG095985699 CLG095570075 CLG095433563 CLG0000094563963 CLG094743272 CLG0000095182424 CLG95399102 CLG095570074 CLG094654505 CLG094856271 CLG094761172 CLG094512831 CLG09465655 CLG93656343 CLG094202353 CLG094487483 CLG094512832 CLG094552996 CLG094082807 CLG094127975 CLG93656342 CLG094065164 CLG92653691 CLG93537924 CLG93656344 CLG092595423 CLG92661845 CLG0000092706183 CLG92856036 CLG92002330 CLG092595422 CLG97644751 CLG97680604 CLG0000091887622 CLG092194196 CLG092499288 CLG91766336 CLG91798999 CLG91708880 CLG91682704 LR CYBR PX MER FPH NIKL BLOOM NIKL GTCAP CHIB MER CH B NIKL NIKL ISs NIKL Is MER GTCAP APC Is I NIKL AG GTCAP NIK MA PGOLD NIKL FPH PGOLD PGOLD PGOLD PX MAB MA MA BLOOM MAB SMC ICT CAL O 100,000,000 1,000,000 5,000,000 40,00,000 1,000,00 40,000,000 22,000,000 30,000,000 200,00 50,000,000 50,000,000 20,000,000 300,0 0 50,000,000 3,000,000 200,000 50,000,000 100,0 45,000 600,000 400,000 400,0 600,00 200,000 200,000 14,000 11,000 29,000 200,00 100,000 500,000 300,000 20,000 300,000 200,000 200,000 7000 100,000 3 00,000 250,000 10,000 50,000 30,000 R R& R&L R&L R&L R&L R& R&L R&&L R&L R&L R&L R& R&L R&L R&L R&L RL RL RL R&L R&L R&L R&L R&L R&L R&L R& R&L R&L RL R& R&L R&L R&L R&L R&L R&L RL R&L R&L R&L RL

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6/ 6/17 8/11/17 9/13/17 7/2/16 7/22/16 7/22 /16 7/22/16 7/22/16 8/17 /17 3/23/17 9/29/17 10/ 4/17 10/18/17 11/14/17 11/24/17 12/ 4/17 12/ 6/17 12/13/17 12/19/17 6/29/16 7/12/16 9/ 6/16 10/25/16 11/ 9/16 6/21/17 8/30/17 10/11/17 11/ 2/17 11/24/17 6/22/16 9/ 2/16 11/22/16 12/ 6/16 12/ 8/16 12/13/16 12/29/16 1/20/17 2/13 /17 6/21/17 11/24/16 December 2016 Monday, 4 December 2017 2017 Wednesday, 21 June Friday, 29 September October 2017 Wednesday. October 2017 Thursday, 2 November Tuesday, 14 November Friday, 24 November Wednesday. December 2017 Tuesday, 19 December Wednesday, 22 20 16 Wednesday, 29 June Friday, 22 July 2016 Friday, 2 September Tuesday, 6 December Thursday, 8 December Monday, 13 February Wednesday. 2017 Friday, 11 August 2017 Thursday, 17 August Wednesday, 23 August Wednesday, 30 August Wednesday, 4 October 2017 2017 Friday. Wednesday. December 2017 20 16 Tuesday, 12 july 2016 Friday,22 July 2016 Friday, 22 July 2016 2016 Tuesday, 6 September 2016 Tuesday, 25 October 2016 November 2016 Tuesday, 22 November 2016 20 16 2016 Tuesday, 13 December 2016 Thursday. Friday. 2017 2017 2017 Wednesday. September 2017 Wednesday, 2017 2017 Friday, 22 July 2016 Friday, 22 July 2016 Wednesday. Thursday. November 2016 2017 Tuesday, 6 June 2017 2017 2017 2017 2017 , 24 November 20 21 January June June 29 11 18 13 13 6 SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM S M SCM SCM SCM SC M SCM SC M SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM 10268 10277 10213 10227 10262 10265 10266 10137 10141 10147 10160 10196 10202 10232 10256 10262 8872 8 05 8 27 9043 9043 9043 9043 9043 9166 946 9470 9475 94 2 949 95 7 9630 9664 9910 9971 99 1 10154 9162 9365 9496 CLG97680604 CLG097751816 CLG97543862 CLG97644751 CLG97716703 CLG097737974 CLG097776108 CLG09798011 CLG096106283 CLG096587912 CLG97232380 CLG093794754 CLG097479573 CLG097556805 CLG097579093 CLG 97598968 CLG97716704 CLG95998865 CLG96063001 CLG096106357 CLG096106284 CLG096106285 CLG096106282 CLG096273897 CLG096537748 CLG096547097 CLG96783917 CLG097423880 CLG097442927 CLG096018307 CLG96265097 CLG96446490 CLG96492824 CLG095679479 CLG096599482 CLG96653656 CLG096714452 CLG097180217 CLG97232378 CLG097411016 MPI * MER BW DD NIKL CHEB AC AC AC GTPPA 8990p AL DD SHLPH SHLPH SHLPH SHLPH DD AT CHIB CHIB CHIB NIKL PPC CHIB CHIB PX FGEN NIK SHLPH SHLPH SHLPH SHLPH APC SMC DDPR SMC2D MWIDE SHLPH SHLPH 8,000,000 1,000,000 200,000 100,000 500,000 200,000 500,000 300,000 500,000 300,000 500,000 200,000 200,000 100,000 300,000 500,000 100,000 300,000 200,000 300,000 250,000 100,000 500,000 100,000 130,000 200,000 800,000 700,000 100,000 100,000 100,000 500,000 100,000 80,000 30,000 30,000 7000 7,00 7,000 2,00 RL R&L RL RL R&L R&L R&L R&L R&L RL R&L R&L R&L R&L R&L R&L R& R&L R& RL R&L R&L R&L R&L R&L R&L R&L R&L R&L R&L RL R&L R&L RL R&L RL R&L R&L R&L R&L

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4/27/18 5/ 8/18 5/ 8/18 4/27/18 4/27/18 5/ 8/18 4/27/18 4/17/18 4/26/18 4/18/18 4/26/18 4/26/18 4/ 3/18 4/18/18 4/18/18 3/27/18 4/ 3/18 4/18/18 3/20/18 3/20/18 3/27/18 4/ 3/18 3/ 7/18 3/ 7/18 3/ 7/18 3/20/18 3/20/18 3/ 7/18 1/12/18 2/27/18 12/22/17 12/22/17 1/26/18 12/22/17 12/22/17 12/22/17 12/22/17 12/29/17 12/20/17 12/20/17 Friday, 27 April 20 18 Friday, 27 April 2018 Tuesday, 8 May 2018 Tuesday, 8 May 2018 Tuesday, 8 May 2018 Friday, 27 April 2018 Thursday. Wednesday, 18 April 20 18 Thursday, 2018 Friday, 27 April 2018 Wednesday, 18 April 2018 Wednesday. Wednesday, 18 April 2018 Thursd ay. 20 18 Tuesday, 3 April 2018 Tuesday, 17 April 2018 2018 2018 Wednesday, 7 March Tuesday. 2018 2018 Tuesday, 2018 Tuesday, 3 April 2018 Tuesday, 3 April 2018 Wednesday, 7 March 2018 Tuesday. Wednesday, 20 18 Tuesday. 20 18 Tuesday. 2018 Tuesday. Friday, 22 December 20 18 Tuesday, 27 February 2018 Wednesday, 7 March 2018 2018 2018 Friday, 22 December Friday, 22 December Friday, 2017 Friday. 2018 Friday. Wednesday. 2017 2017 2017 2017 Wednesday. December 2017 December 2017 Friday, 22 December 2017 Friday. Friday. 2017 29 December 22 December 22 December 2? 26 12 20 20 2 18 April 26 26 20 26 20 7 March January January March April March April March March April March March 20 20 SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SC M SCM 10446 10466 10466 10446 10446 10446 10466 10445 10445 10445 10437 10394 10394 10436 10438 10437 10437 10394 10382 10382 10382 10393 10393 10382 10308 103 20 10338 10364 10379 10379 10379 10379 10300 10278 10300 10300 10300 10300 10300 10278 CLG098242243 CLG098242244 CLG098215991 CLG098215989 CLG098215990 CLG098215992 CLG098211323 CLG098242247 CLG098184503 CLG098212986 CLG098212988 98184504 FROM R & CLG098184499 CLG0 98127313 98139006 FROM R & 98139002 FROM R & CLG098181661 H CLG098184507 CLG098095128 98139159 FROM R & CLG098095124 CLG098095125 CLG098127312 CLG097814976 CLG098057820 CLG098057818 CLG098095126 CLG0000097918626 CLG0000098022794 CLG098057819 CLG098057821 CLG097814365 CLG097814411 CLG097828973 CL097867979 CLG097804305 CLG097814364 CLG097814363 CLG097814630 CLG097804304 PNX38 SHNG PNX3A PHEN PNB BDO BEL PC OR PRF2A AUB ALCPB COSCO CHIB OPM BP BLOOM BP AV DMC EAGLE GTCAP CHIB MBT FGEN MBT PXP APC EW DNL CLC DD TEL PX SMC CHB CHIB CHIB SMC MWIDE NIKL 200,000,000 1,000,000 1,500,000 5,00,000 200,000 700,000 1,000,000 100,000 300,000 205,000 20,00 200,000 20,000 10,000 100,000 300,000 150,000 3 00,000 300,000 200,000 100,000 50,000 20,000 100,000 500,000 500,000 50,000 200,000 500,000 500,000 60,000 40,000 400,000 50,000 50,000 3,000 30,000 40,000 2,000 4.000 R&L RL R&L R&L R&L R&L R&L RL R&L R&L R&L R R&L R&L RL R&L RL R&L R&L R&L R&L R&L R&L R&L RL R&L R& R& R&L R&L R& R& R&L RL R&L R&L R&L R&L R&L R&L

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8/24/18 8/24/18 8/24/18 8/30/18 8/30/18 8/30/18 8/16/18 8/16/18 8/16/18 8/30/18 8/ 9/18 8/16/18 8/16/18 8/16/18 8/ 2/18 8/ 2/18 8/ 2/183 8/ 6/13 6/11/18 6/26/18 7/10/18 7/27/18 8/ 2/18 8/ 2/18 8/7/18 5/25/18 5/25/18 6/ 4/18 6/11/18 6/11/18 6/11/18 6/11/18 7/27/18 7/27/18 8/ 2/18 5/10/18 5/25/18 5/31/18 5/31/18 7/27/18 5/8/18 5/10/18 Thursday, 30 August Friday, 24 August 2018 Thursday, 30 August 2018 Thursday, 16 August Friday, 24 August 2018 Thursday, 30 August 2018 2018 Friday, 24 August 2018 2018 Thursday, 30 August Thursday, 9 August 2018 Thursday. Thursday, 16 August 2018 2018 Thursday, Monday Thursday. 2018 Thursday, Thursday, 20 18 Thursday. 20 18 Thursday. 2018 2018 Thursday. 2018 Thursday. 2018 2018 Tuesday, 2018 2018 2018 Monday, 11 June 2018 Tuesday, 10 July 2018 Friday, 27 July 2018 Thursd ay. Tuesday, 8 May 2018 Friday, 25 May 2018 Thursday. Monday, 11 June 2018 Monday, 11 June 20 18 Monday, 11 June 2018 Monday, 11 June 2018 Tuesday, 26 June 2018 Friday, 27 July 2018 Friday, 27 July 2018 2018 Thursday, 2018 Friday, 25 May 2018 Friday, 25 May 2018 Thursday, 20 18 2018 Friday, 27 July 2018 Thursday, Monday, 4 June 2018 2018 16 August 16 August 16 August 2 August 2 16 August 10 2 2 2 31 10 31 August August August August August August August May May May May SCM SCM SCM SCM SCM SCM SCM SCM SCM SM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM 10887 10820 10820 10820 10887 10887 10887 10602 10602 10593 10594 10601 10602 10602 10602 10602 10587 10587 10587 10543 10543 10543 10570 10581 10581 10587 10587 10587 10543 10543 10552 10581 10581 10466 10468 10468 104'75 10475 10477 10 477 10479 10475 CLG98569089 FROM CLG98568986 FROM CLG098556766 CLG98568947 FROM CLG98569090 FROM R&L CLG098556765 R & L R &L CLG098533170 CLG098537820 CLG098537831 R& L CLG098537816 CLG098537815 CLG098537817 CLG098537818 CLG098556767 CLG98481879 FROM RL CLG98498881 CLG98498880 R&L CLG98498879 CLG98509911 CLG998294567 CLG9841878 FROM CLG98481863 FROM R&L CLG9841862 FROM R&L CLG98498882 CLG98498883 CLG98498884 CLG098511904 CLG098310878 CLG098348079 CLG093848186 CLG098392390 CLG098439045 CLG098242246 CLG098294566 CLG098310878 CLG98320988 FROM R & L INVESTMENT CLG098348080 CLG098348075 CLG098348077 CLG098250551 CLG098250550 CLG098294565 8 90 P AP CPM SCC CHIB PAX PS PXP MBT PBB CHP GSMI MAXS MRSG RWM FBP2 ACR AGI MWP PY TFH LG URC GTPPB DMC MBT CLC CYBR MPI B PI SM AC ACPB BEC PPC TUGS WLCON CNPF BPL EW AL 90,100,000 5,000,000 100,000 400,000 700,000 4,000,000 200,00 100,000 300,000 100,000 250,000 700,000 200,000 300,000 200,000 170,000 30,00 15,000 40,000 100,000 120,000 100,000 30,000 14,000 100,000 50,000 80,000 50.000 10,000 17,000 9,000 70,000 20,000 35,000 15,000 30,000 4,000 2,000 3,00 1,500 1,800 4,000 R&L R& R&L RL R&L R&L R&L R&L R& R&L RL R&L R&L R&L R&L R& R&L R&L R&L R& R&L R&L R&L R&L R&L R&L R&L R&L R&L R&L RL R&L R&L R&L R&L R&L R&L R&L R&L RL R&L R&L

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11/23/18 11/23/18 11/15/18 11/15/18 11/15/18 11/23/18 11/23/18 11/15/18 11/15/18 11/15/18 10/25/18 11/ 9/183 11/15/18 11/15/18 11/8/18 11/15/18 10/12/18 10/25/18 10/25/18 10/12/18 10/12/18 9/28/18 10/ 5/18 10/ 5/18 10/ 5/18 10/ 5/18 10/ 5/18 9/19/18 9/19/18 9/19/18 9/28 /18 9/6/18 9/19/18 9/19/18 9/19/18 8/31/18 8/31/18 Friday, 23 November Friday, 23 November Friday, 23 November 2018 November 2018 November 2018 2018 2018 20 18 Friday, 9 November 2018 November 2018 November 2018 November 2018 Thursday. November 2018 Friday, November 2018 Thursday. Thursday. Thursday. Thursday. Thursday. Thursday. Thursday, 8 Novemher 2018 2018 Thursday. November 2018 Thursday, 25 October Thursday, 25 October 2018 Thursday. Friday, 5 October 2018 2018 2018 Friday, 5 October 2018 Friday, 20 18 Friday. Friday, 20 18 Thursday, 25 October 2018 Friday, 28 September Friday, 5 October 2018 Friday, 5 October 2018 Friday, 28 September 2018 2018 Friday, 5 October 2018 Thursday, 6 September September 2018 Wednesday, September 2018 September 2018 Wednesday. September 2018 Friday, 31 August 2018 2018 Wednesday. September 2018 Wednesday. Wednesday. September 2018 Wednesday. Friday, 31 August 2018 , 23 November 12 12 12 November October October October 15 15 15 15 15 15 15 15 15 19 19 19 19 19 19 SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM 10970 1090 10939 10939 10970 10970 10939 10939 10939 10939 10939 10934 10936 10 939 10939 10932 10921 10921 10921 10932 10 32 10918 10918 10918 10918 10899 10910 10910 10918 10899 10899 10899 10899 1089 10893 10899 1089 R&L INVESTMENT CLG98810760 FROM CLG98810755 FROM R&L INVESTMENT CLG98810758 FROM R&L INVESTMENT CLG98783655 R&L INVESTMENT CLG98810757 FROM CLG98783656 CLG98768007 FROM CLG98783652 CLG98783649 CLG98783648 CLG98731024 FROM CLG98783654 CLG98760856 FROM R&L R&L CLG98783650 CLG98783653 CLG98783651 CLG98678911 FROM CLG98678909 FROM CLG98695759 FROM CLG98731025 FROM R&L CLG98695758 FROM R&L CLG98731026 FROM CLG98678908 FROM R&L R&L CLG98695760 FROM R&L CLG98678910 FROM R&L R&L R& R&L R& CLG98678907 FROM CLG98572616 FROM CLG98626809 FROM CLG98626807 FR0M CLG98626806 TO CLG98626808 FROM CLG98626810 FROM CLG98657387 FROM RL CLG98657389 CLG98572615 FROM R&L CLG98626811 FROM R&L R&L RL R&L R&L R&L R&L R&L CLG098590326 CNP EW V AUB CLC PBB SLF SSP URC ICT MWIDE PNB FE GSMI MBT MPY MRC MBT COSCO MEG FBP2 BDO B PI FNI DNL PGOLD SM ABA PCOR SM SHLPH AT NIKL BDO FL FPH MWC 1,500,000 100,000 400,000 1,500,000 300,000 30,000 50,000 20,000 100,000 40,000 250,000 100,000 60,000 60000 20,000 15,000 30,000 4,000 200,000 70,000 10,000 70,000 300,000 100,000 400,000 7,000 1,000 25,000 50,000 15,000 10,000 5,000 5,000 2,000 5,00 1,000 500 R&L R R& R&L R&L R&L R&L R&L R&L R&L R&L R&L RL R&L R&L R&L R&L R&L R&L R&L R&L R&L R&L R&L R&L R&L RL R&L RL R&L R&L R&L R&L R&L RL RL R

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1/11/19 1/10/19 1/ 7/19 1/10/19 1/10/19 1/10/19 1/10/19 1/ 3/19 1/ 7/19 1/ 3/19 1/ 3/19 1/ 3/19 1/ 3/19 1/ 3/19 1/ 3/19 12/12/18 12/11/18 12/19/18 1/ 3/19 12/11/18 12/11/18 12/11/18 12/11/18 12/11/18 12/ 7/18 12/ 7/18 12/ 7/18 12/ 7/18 12/ 7/18 11/29/18 12/ 7/18 12/ 7/18 12/ 7/18 12/ 7/18 11/23/18 11/23/18 11/23/18 Thursday, 10 January Thursday, 10 January 2019 Thursday, 10 January Thursday, 10 January Friday, Thursday, 10 January 2019 2019 20 19 2019 2019 2019 Thursday, 3 January Monday, Thursday, 3 January Thursd ay. 2019 Thursday. 2019 20 19 Thursday, 3 Monday. 20 19 2019 Thursday, 3 January Thursday, 2019 2019 2019 Thursday. Tuesday, 11 December Wednesday. December 2018 December 2018 2019 Tuesday, 11 December 20 18 Tuesday, 11 December Tuesday, 11 December 2018 Wednesday. Tuesday, 11 December 2018 2018 Friday, Friday. 2018 Tuesday, 11 December 2018 2018 November 2018 2018 Friday. Friday. Friday, 2018 Friday, 23 November Friday, 23 November 2018 Friday. 2018 Friday, 2018 2018 2018 2018 Friday. Friday. 20 18 Friday, 2018 Thursday. 2018 11 23 November 3 January 3 January 3 January 1 3 Y January December Decemher January January December January January December December December December December December 12 19 29 SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M 11010 11012 11010 11010 11010 11010 11007 11004 11004 11006 11007 11004 11004 11004 11004 11004 10981 10983 10994 10981 10981 10981 10981 10 981 10978 10978 10978 10978 10978 10978 109 78 10978 10970 10970 10970 10973 10978 CLG98949538 CLG98954421 CLG98949539 CLG98949540 CLG98930648 CLG098936703 CLG98949537 CLG98949451 CLG098927851 CLG098927852 CLG098927853 CLG098936704 CLG098927850 CLG098927889 CLG098927854 CLG098927868 CLG98897711 CLG98868578 CLG98868575 CLG98868576 CLG098873690 CLG98868573 CLG098856480 CLG98868579 CLG98868577 CLG098857364 CLG098857365 CLG098856482 R&L INVESTMENT CLG098856485 CLG098856483 CLG098856479 CLG098857363 R&L INVESTMENT CLG98810756 FR0M CLG098826503 CLG098856481 CLG98810759 FROM R&L INVESTMENT CLG98810754 FROM IM LC LPZ PXP B DO 1FC SE CB BC PNB GEO BLOOM AGI PRF2A N PX ALCO ALC PB CHIB CHIB CEB C MAC SHLPH TUGS AC SOC PAL SLF DD NIKL OPM OPMB VLL ACPB2 SSI SMC RLC 4,000,000 2,000,000 1,000,000 50,000,000 100,000 50,000,000 5,020,000 100,000 60,000 300,000 1,000,000 150,00 300,000 500,000 400,000 60,00 10,000 40,000 5,000 3,000 120,000 3,000 10,000 300,000 30,000 150,000 50,000 5,000 25,00 70,000 30,000 40000 4,000 500 4400 350 900 RL RL R&L R&L R&L R&L R&L RL R&L R&L R&L R&L R&L R&L R&L RL R&L R&L R&L RL R&L RL R&L R&L RL R&L RL R&L R&L R&L RL R&L RL R& R& R&L R&L

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4/15/19 3/22/19 4/ 4/19 4/ 4./19 4/ 4/19 4/ 5/19 4/15/19 3/15 /19 3/22/19 3/2/19 3/22/19 3/22/19 4/ 4/19 4/ 5/19 4/ 5/19 4/ 5/19 4/ 5/19 3/ 8/19 3/15/19 3/15/19 3/15/19 3/15/19 3/22/19 3/22/19 3/22/19 4/4/19 3 / 8/19 3/ 8/19 3/15/19 3/26/19 1/11/19 1/18/19 3/ 7/19 3/ 7/19 3/ 7/19 3/ 7/19 3/ 7/19 3/ 8/19 1/18/19 1/29 /19 1/29 /19 1/29 /19 1/18/19 1/22/19 1/29/19 1/29/19 1/11/19 Monday, 15 April 2019 Friday, 22 March 2019 Tuesday, 26 March Thursday, 4 April 2019 Friday, 5 April 2019 Friday, 5 April 2019 Friday, 15 March 2019 Friday, 22 March 2019 Friday, 22 March 2019 Friday, 22 March 2019 2019 Thursday, 4 April 2019 Thursday, 4 April 2019 Thursday, 4 April 2019 Thursday, 4 April 2019 Friday, 5 April 2019 Friday, 5 April 2019 Monday, 15 April 2019 Thursday. 2019 Friday, 8 March 2019 Friday, 22 March 2019 Friday, 22 March 2019 Friday, 22 March 2019 Friday, 22 March 2019 Friday, 5 April 2019 Friday. 2019 Tuesday. 2019 2019 Thursday. Thursday. Friday, 15 March 2019 Friday, 15 March 2019 Friday, 15 March 2019 Friday, 15 March 2019 Frid ay, 2019 2019 2019 Friday. Friday 2019 2019 2019 Tuesday, Tuesday. Thursday. 2019 2019 2019 Friday, 8 March 2019 Friday, 8 March 2019 Friday, 8 March 2019 Friday, 15 March 2019 Frid ay, Tuesday. 2019 Tuesday, 2019 Tuesday. 2019 Thur'sday. 29 January , 29 January 29 January 18 January 11 11 18 22 January 29 January 29 January e January January January January March March March March March S CM SC M SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SC M SCM 11084 11087 11087 1030 11040 11040 11083 11083 11083 11083 11083 11084 11084 11084 11084 11033 11033 11033 11033 1103 11040 11040 11040 11040 11040 11041 11029 11030 11030 11030 11033 11040 11019 11019 11029 11029 11029 11029 11012 11012 11014 11014 11014 11018 11019 11019 11019 CLG099222489 CLG099222488 CLG99243699 CLG0999182442 CLG0999182460 CLG99219596 CLG099222490 CLG099918240 CLG0999182457 CLG0999182443 CLG99190537 CLG99219592 CLG99219595 CLG099222492 CLG099222491 CLG099243697 CLG99141583 CLG99162381 CLG099182441 CLG0999182459 CLG99219593 CLG9920647 CGL99138274 CLG99141582 CLG99162384 CLG99162382 CLG99162383 CLG 99162386 CLG0999182458 CLG99013845 CLG99138272 CLG99141581 CLG99141580 CLG 99162385 CLG98954419 CLG098981007 CLG098981006 CLG098981003 CLG098989857 CLG99013847 CLG99013849 CLG99013846 CLG099013860 CLG99138273 CLG99138271 CLG99138270 CLG98954420 ST SM GTPPA OPMB EBL BHI GS EL MPI ACPB AP IC PHA ANI SMPH CHP MVC APX APO PNB PHEN GT CAP ACR I CL ZHI COL SMC2D CHIB GT PPB RWM PCOR MA VUL IRC CHIB RLT LMG GLO APC BRN PSB SBS UPM MAB ABS AEV 100,000,000 100,000,000 150,000,000 25,000,000 2,00,000 6,000,000 1,500,000 1,000,000 500,000 500,000 130,000 150,000 180,000 400,000 200,000 600,000 100,000 150,000 200000 100,000 700,000 280,000 120,000 80,000 400,000 60,000 18,000 00,000 15,0 00 1200 15,000 5000 60.0 60000 15,000 9,000 7,000 5000 6000 5,820 6, 0 00 60 400 40 800 200 420 R&L R&L R&L R&L R&L RL R&L RL R&L R&L R&L R&L R&L R& R&L RL RL RL RL R&L R&L R&L R&L R&L R&L R&L R R&L R&L R&L R&L R&L RL R&L RL R&L R&L R&L RL RL R&L R&L R& R&L R&L R&L RL

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8/ 6/19 7/31/19 6/28/19 7/ 2/19) 7/16/19 7/31/19 7/31/19 6/ 3/19 6/25/19 6/ 3/1 6/ 3/19 6/ 3/19 6/19 /19 6/19/19 6/27/19 6/19/19 5/ 3/19 5/20/19 5/23 /19 5/23/19 5/30/19 6/ 3/19 5 / 3/19) 5/ 3/19 5/19 5/ 3 /19 5/ 3/19 5/ 3/19) 5/23/19 5/23/19 4/23/19 5/ 3/19 4/23/19 4/23/19 4/23/19 4/23/19 4/25/19 4/16/19 4/23/19 4/23/19 4/23/19 4/25/19 4/25/19 4/16/19 4/16/19 4/16/19 4/15/19 Wednesday, 31 Wednesday, 19 June Tuesday, 16 July 2019 2019 Wednesday, 19 June Tuesday, 25 June 2019 Tuesday, 2 July 2019 2019 Wednesday. 2019 Tuesday, 2019 2019 Thursday, Wednesday, Monday, 3 June 2019 Monday, 3 June 2019 Monday, 3 June 2019 Monday, 3 June 2019 Monday, 3 June 2019 2019 2019 Friday, 28 June 2019 Wednesday, 19 June 2019 Thursday. Friday, 3 May 2019 Friday, 3 May 2019 Tuesday, 7 May 2019 Thursday. 2019 Thursday, Thursday. 2019 Friday, 3 May 2019 Friday, 3 May 2019 Friday, 3 May 2019 Monday, 20 May 2019 Thursday, 2019 2019 Tuesday, 23 April 2019 Tuesday, 23 April 2019 Tuesday, 23 April 2019 Thursday, Friday, 3 May 2019 Friday, 3 May 2019 2019 Monday, 15 April 2019 Tuesday, 23 April 2019 Tuesday, 23 April 2019 Tuesday, 23 April 2019 Tuesday, 23 April 219 Thursday, 2019 Tuesday, 16 April 2019 2019 2019 Tuesday, 16 April 2019 Tuesday, 16 April 2019 Tuesday, 16 April 2019 Tuesday, 23 April 2019 Thursday, 6 27 31 31 25 23 23 23 30 23 25 2 August July July July June May M ay April May May May April April SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM SCM SCM SCM SCM SCM SCM SCM SC.M SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SC M SCM 11160 11160 11175 11147 11149 11151 11160 11139 11145 11146 11126 11126 11126 11126 11139 11139 11117 11126 11107 11114 11116 11119 11100 11100 11100 11100 11101 11115 1102 11100 11100 11090 11092 11092 11100 11088 11090 11090 11090 11090 11090 11090 11090 11088 11088 11087 11088 CLG099570566 CLG099587589 CLG099468110 CLG099570564 CLG099570565 CLG 099470469 CLG099479096 CLG99523860 CLG099391977 CLG99442234 CLG99442235 CLG099457033 CLG099391981 CLG099391978 CLG99442233 CLG099288238 CLG099391980 CLG099391979 CLG099288237 CLG099297289 CLG099355764 CLG099355763 CLG099355762 CLG CLG099288135 CLG099288141 CLG099288138 CLG099288236 CLG99309574 CLG099355765 CLG099259948 CLG099267890 CLG099267888 CLG099288140 CLG099247887 CLG099247886 CLG099259937 CLG099259934 CLG099259932 CLG099259935 CLG099259936 CLG099267889 CLG099243698 CLG099247884 CLG099247885 CLG099259930 CLG099259931 DD SL RC FC GREEN PRF3A ALCPC PNB BP PNB PSB JFC PB RFM RCI SMC B PL PCOR AL AL GTCAP LG WP COAL AUB PAX SMC BC PIZZA HLCM MRSGL CPG PX SC PRIM TEL SHNG GTPPA GMAP NIKL IRC SHLPH FGEN FB FB P2 MAXS OM 1,500,00 1,100,000 100,000 200,00 20,000 20,000 15,000 200,000 300,000 650,000 80,000 3 50,000 450,000 20,000 250,000 50,000 50,000 10,000 2,000 2,00 450,000 17,000 12,000 300,000 100,000 200,000 180,000 8.000 6000 25,0 00 85000 150,000 20,000 15,000 80,00 1,00 60,000 10,000 3,00 2,500 2,400 980 7,000 500 350 300 350 R&L R&L R&L R& R&L R& R R&L R& R&L R&L RL R&L R&L R&L R&L R&L R& R&L R&L RL R&L R&L R&L RL R&L RL R R&L R&L RL R&L R&L R R R& R&L R&L R R&L R&L RL R& RL R&L R R&L

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10/31/19 10/31/19 10/31/19 10/31/19 10/31/19 10/31/19 9/20/19 10/15/19 10/22/19 10/31/19 10/31/19 10/31/19 10/ 9/19 10/14/19 10/18/19 9/12/19 9/18/19 9/18/19 9/18/19 9/20/19 8/7/19 8/ /19 9/17/19 8/ 6/19 8/ 6/19) 8//19 8/13/19 9/12/19 8/ 6/19 8/ 6/19 8/ 6/19 Thursday, 31 October Thursday, 31 October 2019 Thursday. 31 October Thursday, 31 October 2019 2019 Thursday, 31 October Thursday, 31 October Thrsday, 31 October Thursday, 31 October Monday, 14 October 2019 Thursday, 31 October 20 19 2019 2019 20 19 Friday, 20 September Friday, 20 September Wednesday, 9 October 2019 Tuesday, 2019 Friday. Tuesday. 2019 2019 2019 Wedneday, 7 August September 2019 September 2019 September 2019 20 19 2019 Wednesday, 7 August September 2019 Wednesday, Wednesday. Wednesday. 2019 2019 Wednesday, 2019 Thursday, September 2019 Thursday. Tuesday. September 2019 Tuesday. 2019 Tuesd ay. 20 19 2019 Tuesday. 2019 Tuesday, Tuesday. Tuesday. 2019 2019 20 1 9 15 22 October 18 13 August , 7 August 6 6 1 6 October October August August August August August 17 18 10 18 12 12 SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM SCM 11353 11353 11353 11353 11353 11353 11269 11273 11276 11353 11353 11353 11204 11204 11205 11205 11239 11268 11176 11176 11178 11202 11202 11203 11204 11175 11175 11175 11175 11175 11176 CLG99831055 CLG9983 1057 CLG99831059 CLG99831056 CLG99831089 CLG99831060 CLG99831061 CLG99831054 CLC9978560 CLG99806853 CLG99831062 CLG996722761 CLG99722762 CLG99699878 CLG99774482 CLG99785553 CLG099798550 CLG099591633 CLG99699886 CLG99714766 CLG99714768 CLG099587591 CLG099591631 CLG099591632 CLG99710907 CLG99714767 CLG099587590 CLG99606370 CLG099587547 CLG099587546 CLG099587588 TBG JFC MEG IT PCOR PGOLD AGI PX PAL PX HOME PPG BESC HOME RWM SMC AXLM BDO JFC RCI ANS B DO PNB JFC MP NIKL CEL X STR NCP CHP 1,300,00 1,000,000 100,000 100,000 500,000 700,000 700,000 90,000 60.000 180,000 300,000 30,000 15,000 40,000 100,000 2,00 150,000 20,0 00 25,700 6200 90.,000 10,000 7,000 11,600 65,000 15,000 3,000 4,000 900 3,00 2000 R&L R&L R& R&L R&L RL R&L R&L R&L R&L RL RL R&L R&L R&L R&L R&L R&L R&L RL R&L R&L R&L RL R&L R&L R&L R&L RL R&L R

trading pattern, Fourth, there is also no merit in Respondents allegation that based on Sulapas Sulapas is day trader who executes numerous buying and selling

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transactions during the trading day which characterize Sulapas pattern of transactions as a day trader. 23

shares, allowing them to lock in quick profits. 24 who rapidly buys, sells and short-sells stocks throughout the day in the hope that the stocks continue climbing or falling in value for the seconds and minutes they hold the A day trader is defined by the United States Securities Commission as a customer

or after a profit has been realized. on a particular stock and selling them within the same day with the goal of making a profit It can be understood from the foregoing that a day trader refers to buying activity

"F" of the Complainant Position Paper reveal that Sulapas holds his securities for one to foregoing ledgers clearly show that Mr. Sulapas is not an active day trader. three days in average on several occassions. Thus, contrary to Respondents claim, the In this case, based on Sulapas' itemized and summarized Iedger attached as Annex

he has existing account with another broker, R&L. any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that Fifth, Respondents allowed Mr. Sulapas to indicate in his CAIF that he does not have

securities transactions. alerted the Respondents that something was amiss in relation to the conduct of Mr. Sulapas repeatedly requested Mr. Sulapas to correct and update his information in the CAIF and for his failure to correct, VSI had merely duly noted that Mr. Sulapas maintained an account with another broker dealer for being inconsistent with ordinary experience and common sense. Such failure on the updating of Mr. Sulapas CAIF, at the first instance, should have It is difficult to believe the Respondents simplistic explanation that Ms. Aguilar

Respondents failed to cause the updating of the CAIF. that Mr. Sulapas personally goes to'VSI Office in order to collect his checks25, still the Besides, despite numerous opportunities to do so, i.e., Aguilar stated in her Affidavit

account holder with other broker, they did not fulfill their mandatory obligation to update component of KYC regulation. Despite Respondents knowledge that Mr. Sulapas is an his CAIF. Obviously, Respondents did not take any steps to update the CAIF, which is the key

Sinumpaang Salaysay 26 dated 17 September 2020 and Supplemental Affidavit 27 dated 08 March 2021 denied and controverted the Respondents allegations regarding what Fifth, another disturbing circumstances is the fact that Mr. Sulapas himself in his

27 Annex "D" of Complainant Position Paper. Complainant's arguments in paragraph 2-2.4 of its Comments 13 and par. 2.35 page 13 Respondents Reply. 24 Investo.gov.US Securities and Exchange Commission, https://www.investor.gov/introduction. Also cited in par. 617 of Complainant Position Pape 25 Paragraph 23 of Adora Aguilar Affidavit attached as Annex 14 of the Position Paper, Also part of 26 Annex "C" of Complainant Position Paper. 23 Paragraph 3.5.1 page 10, par. 3.29 page 13, par. 3.33 page 14, par. 4.9 page 22 and par. 4.30 page 27 of Respondents Answer, par. 2.16 page 9, par 2.39 page 15 of Respondents Position Paper and par. 2.31 page

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authorization pertaining to the Sulapas account trading transactions, thus: transpired during the account opening of Mr. Sulapas and his alleged lack of knowledge or

Sinumpaang Salaysay dated 17 September 2020:

kinausap siya doon, "Grace" ang pangalan. Tingin ko siya yung amo doon. Nung Securities, Inc. yun. Binigyan ako ng mga dokumento at sinagutan ko naman. Nagbigay din ako ng mga ID na pina-photocopy nila. Pagkatapos noon ay umuwi "15. Na pinapunta ako ulit ni Mar sa PSE makaraan ang mga tatlong lingo hanggang isang buwan. Doon lang po kami may tapat ng Ayala Triangle. Umakyat po kami sa isang gusali doon sa isang opisina sa ika-walong palapag. May panahon na iyon, di ko alam yung opisina, pero ngayon alam ko na Venture na din ako;"

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kay Mar. Ang alam ko lang yung mga text sa akin ni Mar tungkol doon sa mga 41. Na gusto kong sabihin na wala akong alam tungkol sa scam na binibintang tseke. Yung sa pagbebenta po ng shares, wala po ako alam doon. Supplemental Affidavit dated 08 March 2021:

ng mensahe ni Marlo Moron sa cellphone kapag kukunin ko na ang mga tseke. Sa tuwing kukunin ko ang tseke, wala namang espesyal na pakikitungo sa akin sa Securities (pag-de-deposito ng pera o pagbenta o pagbili ng kahit anung Venture Securities. nakapangalan sa akin, o na may dalawa akong account sa Venture Securities. Wala rin akong natatandaan na kahit anung transaksyon na iniutos ko sa Venture securities). Ang alam ko lamang ay may mga dokumento akong pinirmahan na iniabot sa akin ni Krystel at ni Dianne ng Venture Securities. May mga pagkakataon din na si Krystel ang kumokontak sa akin para magpunta sa opisina ng Venture Securities para magpapirma ng mga dokumento. Pinapadalhan ako "xvi. Na wala akong alam sa mga nilalaman ng Venture Securities accounts na

xvii. Na iisang CAIF lamang ang pinirmahan ko sa Venture Securities. Ang CAIF kamay. Hindi rin pirma ko ang naka-cross signature sa CAIF at Signature Card ng Venture Securities. Maliban sa cross signature, sulat kamay ko ang mga pirma sa mga dokumentong ito;" para sa SU26 na account sa pangalan ko sa Venture Securities ay hindi ko sulat

XXX XXX XXX

gagawin niya ang paghahatid. Hinihintay ko lang ang tseke sa Venture kapag Venture. Hindi ako nag-utos ng kahit na anung transaksyon sa Venture. Lahat ng mga transaksiyon ay nangaggaling kay Marlo sa pamamagitan ng test message ganun, at matapos ang 30 minuto ay nakukuha ko din naman ito. Wala akong natatandaan na nagtanong sa akin si Diane o si Krystel tunkol sa mga share na ihahatis. Si Marlo lamang ang kinakausap nila. Minsan nagbibigay din sa akin si Krystel o Dianne ng mga dokumento para pirmahan sa labas ng opisina ng xxxi. Na may mga pagkakataon na inuutusan ako ni Diane na sabihan si Marlo Moron na hindi pa nahahatid ang mga securities. Sinabihan ko si Marlo Moron, at

Respondents were not afforded the opportunity to confront him with his allegations before right to due process to present the affidavits of Mr. Sulapas at this point because (i) There is also no merit on the argument of Respondents that it is a violation of their

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the Formal Charge was filed, (ii) Mr. Sulapas is not a party to the case filed against and Securities Regulation during their Investigation. 28 Respondents and (iii) he was not present when Respondents appeared before the Market

his allegations before the filing of the Formal Charge. party to the case. It is not also required for the Respondents to confront Mr. Sulapas with Complainant presented the affidavits of Mr. Sulapas as part of its evidence in this case. The Complainant was not also prohibited to obtain the affidavits of its witnesses who are not Contrary to their stance, Respondents were accorded due process when

via its Reply to Complainants Position Paper. Trite to state, to confront Mr. Sulapas prior Universal Rightfield Property Holdings, Inc. 29 opportunity to refute, explain and present their defense. Respondents were able to do this to filing of Formal Charge is not necessary to comply with the requirements of due process. The essence of due process as applied to administrative proceedings is simply the opportunity to be heard. As the Court held in Securities and Exchange Commission v. Respondents were amply apprised of the affidavits, and then given the reasonable It will be sufficient for the satisfaction of the demands of due process that the

process, as a constitutional precept, does not always, and in all situations, require a trial-type proceeding. Litigants may be heard through pleadings, written explanations, position papers, memoranda or oral arguments. The standard of due process that must be met in administrative tribunals allows a legally objectionable for being violative of due process for an administrative agency to resolve a case based solely on position papers, affidavits or documentary evidence submitted by the parties." "In A.Z. Arnaiz, Realty, Inc. v. Office of the President, the Court held that due certain degree of latitude as long as fairness is not ignored. It is, therefore, not

seen in the case of Office of the Ombudsman v. Mislang that said doctrine finds application even in administrative cases30 is untenable. Sinumpaang Salaysay and Supplemental Affidavit cannot be used against them in this case under the doctrine of res inter alios acta as embodied under Section 31, Rule 130 and as Likewise, the claim of Respondents that the statements of Mr. Sulapas in his

administrative and adjudicatory cases. The 2016 SEC Rules of Procedure state that: rules of procedure as it is allowed to be liberal in the application of its rules in deciding The Commission as an administrative body is not strictly bound by the technical

before the Commission and to carry out the objectives of the laws it is mandated to implement. construed and administered to promote public interest, to secure a just, prompt. expeditious, and inexpensive determination of every action and proceeding SEC. 1-4. Construction of Rules. - a. These Rules shall be liberally

character and effect. provisions of the Rules of Court may, in the interest of expeditious dispensation of justice and whenever practicable, be applied by analogy or in a suppletory SEC.1-6 . Suppletory Application of the Rules of Court. - The pertinent

28 Par 2.27 page 9 Respondents Reply. 29 G.R. No. 181381, July 20, 2015. 30 par.228.-2.32, Pagei0-11 Respondents Reply

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explain: In Divina Palao v. Florentino International, Inc. 31, the Court had the occasion to

and administrative due process cannot be fully equated with due process in its strict judicial sense." the rules obtaining in courts of law. Administrative tribunals exercising quasi-judicial powers are unfettered by the rigidity of certain procedural requirements, subject to the observance of fundamental and essential requirements of due process in justiciable cases presented before them. In administrative proceedings, technical rules of procedure and evidence are not strictly applied "[A]dministrative bodies are not bound by the technical niceties of law and procedure and

bound by the exception on independently relevant statements. in this case, the treatment of the statements in the affidavits of Mr. Sulapas as hearsay is In any case, even if it is assumed that the rule on res inter alios acta were to apply

does not apply, and the statements are admissible as evidence. Evidence as to the making of such statement is not secondary but primary, for the statement itself may constitute a fact in issue or be circumstantially relevant as to the existence of such a or falsity, the fact that such statements have been made is relevant. The hearsay rule fact. 32 "Under the doctrine of independently relevant statements, regardless of their truth

participation of Respondents in the instant controversy considering the vital role of his securities transaction in the commission of the securities fraud. Thus, such statements should be given consideration by the panel as it is directly relevant to the issue at hand. made by Mr. Sulapas, who was the alleged owner of the accounts subject of controversy, Verily, Mr. Sulapas statement in his affidavits is independently relevant to prove the

investment objectives to begin at least at the time he assumed office as the president of VSI. bereft of merit. As President, he is liable under the law and Rules as control person based on his failure to supervise VSI registered representatives in establishing the true and full identity of each of his clients, their financial situation, investment experience, and 30.2.1.2.4.1, Rule 30.2.1.2.4.3, and Rule 30.2.1.2.4.6 since he is not a registered person, is Regarding the claim of Mr. Racadio that he cannot be made liable under SRC Rule

continuous conduct of the illegal trade transactions on Mr. Sulapas account, will make them liable for violating SRC Rule 30.2.1.2.4. on Information About Clients. at least contributed to the acts resulting to the prejudice of the investors and rendered the Balabis to implement and comply with the requirements of the KYC Rule have resulted or All told, from all indications, the failure of Respondents VSI, Racadio, Aguilar and

Balabis) Racadio, Adora Aguilar and Loreto B. On the Charge for Violation of 52.1.6.16 of the 2015 SRC Rules Rule 52.1.6.8, 52.1.6.15 and (Venture Securities, Inc., Wilfred

In the Formal Charge33, Complainant alleged that:

32 People v. Estibal, G.R. No. 208749, November 26, 2014. 31 G.R. No. 186967, January 18, 2017 33 Pages 23-24 of Formal Charge.

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2. Adora Aguilar does not have knowledge on the background of Julieto Sulapas 1. VSI does not have a clear customer acceptance policies and procedures that were implementation of appropriate customer acceptance policy (KYC) is an important element in determining suspicious transactions for purposes of Anti-Money applied to Julieto Sulapas. Laundering Council reporting. Properly knowing the client through the

3. Loreto Balabis narrated during the investigative proceedings that Marlo Moron R&L., Julieto Sulapas wants to open an account with Venture. approached him on the PSE trading floor to inform Loreto Balabis that a client of

Loreto Balabis also admitted that he merely gave Marlo Moron a blank Customer Account Information Form (CAIF) which was allegedly filled out by Julieto Sulapas without his presence.

5. Julieto Sulapas indicated in his CAIF that he does not have any other account with admitted that she knew that Julieto Sulapas has an account with R & L, but she did not require him to correct this fact in the CAIF. other broker dealers notwithstanding his existing account with R&L. Adora Aguilar

6. Based on the CAIFs and account ledgers of Julieto Sulapas submitted by VSI, the annual income of Julieto Sulapas is Php 1 million but he was allowed to transact beyond his financial capability.

7. Adora Aguilar also admitted during the investigative proceedings that there was Sulapas. no verification made for the disclosed source of income (JS Lumber) of Julieto

8. Based on the CAIFs and account ledgers of Julieto Sulapas submitted by VSI, the annual income of Julieto Sulapas is Php 1 million but he was allowed to transact Way beyond his financial capability.

9. The abovementioned circumstances reveal that VSI lacks proper KYC procedures applied in the Julieto Sulapas accounts.

10. As the overseer of VSI, the President Wilfred Racadio also failed to ensure that the Julieto Sulapas accounts. proper customer acceptance policies and procedures are in place particularly as to

In their answer, 34 Respondents countered:

Rule 52.1.6.16; 1. The Respondents cannot be held liable under Rule 52.1.6.8, Rule 52.1.6.15, and

2. The Respondents have already sufficiently discussed above their customer acceptance and KYC procedures as well as its anti-money laundering procedures;

to the office of VSI on 29 May 2012. During this time, Mr. Sulapas was able to provide sufficient information for purposes of creating an account; 3. The Respondents properly identified and interviewed Mr. Sulapas when he went

34 Page 40 of the Respondents Answer.

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account when it was part of the audits conducted by CMIC; 4. Based on his transactions from 2012-2019, the Respondents have been able to create a trading profile of Mr. Sulapas as well as determine more accurately his financial situation, investment background, and investment objectives. Based on this information, the Respondents have determined that Mr. Sulapas is able to sustain funding for his transactions almost entirely from his trading activities. Thus, it was well within his financial capacity to enter into his numerous transactions. There have also never been any adverse findings on the Sulapas

render the transactions he entered into as fraudulent; 5. Ms. Aguilar repeatedly required Mr. Sulapas to correct and update his information in his CAIF. Ms. Aguilar, however, cannot commit a felony or offense just to make sure that the CAIF reflects the correct information. Instead, VSI just duly noted that Mr. Sulapas has another account with another broker dealer. Furthermore, the failure on the part of Mr. Sulapas to update his CAIF did not

We are not persuaded by Respondents arguments.

dealer to maintain information for each account. The pertinent provision of the Rule provides: SRC Rule 52.1.6. on Customer Account Information Rule mandates the broker

information and requirements: 52.1.6.1. Every Broker Dealer shall maintain for each account, the following

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the partner, officer or manager who accepts the account 52.1.6.1.7. Signature of the salesman introducing the account and signature of

XXX XXX

otherwise, relevant details on the identity documents will be recorded. measures for verifying and recording the true and full identity of their identity issued by an official authority, preferably bearing a photograph of the 52.1.6.8. The Broker Dealer shall develop clear customer acceptance policies and procedures when conducting business relations or accommodating specific transactions and shall exercise due diligence in implementing its customers. It shall require customers to produce original documents of customer and where practicable, maintain file copies of documents of identity; policies and procedures. Furthermore, it shall adopt adequate internal control XXX XXX XXX

(180) days after the effectivity of these amendments and every two (2) years 52.1.6.13. All existing CAIFs shall be updated within one hundred eighty subsequent thereto.

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material information contained in the CAIF. 52.1.6.15. It is the Broker Dealer's duty to know its clients well and, accordingly, it shall be primarily responsible in keeping current all

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the Anti-Money Laundering Act (RA 9160, as amended). 52.1.6.16. The Broker Dealer, its directors, officers, and associated Anti-Money Laundering Council (AMLC), pursuant to the provisions of persons, are required to report any suspicious client transaction to the

nature or circumstances, or (b) the person or group of persons with whom they are dealing, and based on the bringing together of all relevant factors including knowledge or the person's or persons' business or background (as well as behavioral factors). (Emphasis ours) For purposes of this section, a suspicious client transaction shall mean any transaction which causes any ordinary person to have a feeling of apprehension or mistrust about the transaction considering (a) its unusual

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pertaining to his account trading transactions. allowed Julieto Sulapas to indicate in his CAIF that he does not have any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that he has existing account with another broker, R&L; (5) Respondents did not require Mr. Sulapas to update his CAIF; Supplemental Affidavit the Respondents allegations regarding what transpired during the account opening of Mr. Sulapas and his allegation of lack of knowledge and authority and, (6) Mr. Sulapas denied and controverted in his Sinumpaang Salaysay and that: (1) Mr. Balabis was not present during the Sulapas account opening; (2) the Financial Capacity of Mr. Sulapas indicated in his CAIF is only P1,000,000.00 but based on the documents submitted there were numerous transactions which were evidently beyond the client's declared financial capacity; (3) Mr. Sulapas was not a day trader; (4) Respondents As already discussed above, it has already been established by substantial evidence

Sulapas as required under the VSI Supervisory Procedures. and Compliance Manual of VSI require the signature of the Salesman in the CAIF who was introducing the account. Looking at the CAIF,36 it appears that it was signed by Mr. Balabis despite of his clear admission that he was not present at the time Mr. Sulapas allegedly opened the account with VSI and the fact that no face-to-face interview was done with Mr. Rule pertaining to minimum required information on CAIF of the Supervisory Procedures Further, both SRC Rule 52.1.6.1.7 and Item III (J) (1) (e) 35 on Books and Records

knowledge as to the truth and correctness of what he signed. Thus, it must be noted at the not be validly opened in the absence of Mr. Balabis. face interview, he should not have signed the document because he did not have personal outset that there was an infirmity on Mr. Sulapas account opening since the account could verified the information indicated therein to be true and correct. Considering that Mr. Balabis was not present during the account opening and have not conducted a face-to- The purpose of Mr. Balabis in affixing his signature in the CAIF is to attest that he

mandatory and it is the legal duty of Broker Dealers to know its clients well and primarily responsible in keeping current all material information contained in the CAIF. findings on the Sulapas account when it was part of the audits conducted by CMIC is unavailing for the same have no bearing on the clear violation of the Customer Account Information Rule committed by the Respondents. Under the Rule, updating of CAIF is Furthermore, the allegation of Respondents that there had never been any adverse

35 Pages 49-50 Annex 12 of the Respondents Position Paper 36 Annex 1-A position paper.

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of the SRC and its IRR committed by VSI regarding the Sulapas account and his securities transactions. ultimately, in its 19 December 2019 Report37; CMIC clearly stated that there were violations Moreover, the CMIC itself debunked this assertion made by the Respondents since,

40 is not bound on the inadvertence committed by CMIC in its audit findings, if any. mandated to administer the SRC,38 and is given regulatory powers39 and "absolute jurisdiction, supervision and control over all corporations, partnerships' or associations " Besides, the Commission as the primary regulator being the government agency S

motu proprio whether corporations comply with the Corporation Code, Securities Regulation Code, and rules implemented by the Securities and Exchange Commission.c Commission is also given the power to impose fines and penalties. It may also investigate To ensure compliance with the law and the rules, the Securities and Exchange leslaw SEC. 5. Powers and Functions of the Commission. - 5.1. The Commission shall act the Financing Company Act and other existing laws. Pursuant thereto the Commission shall have, among others, the following powers and functions:c with transparency and shall have the powers and functions provided by this Code, Presidential Decree No. 902-A, the Corporation Code, the Investment Houses Law,

D Regulate, investigate or supervise the activities of persons to ensure compliance;

f Impose sanctions for the violation of laws and the rules, regulations and orders issued pursuant thereto;

Issue cease and desist orders to prevent fraud or injury to the investing public;

. Suspend, or revoke, after proper notice and hearing the franchise or certificate of registration partnerships or associations, upon any of the grounds provided by law; and of corporations.

as those which may be implied from, or which are necessary or incidental to the carrying out of, the express powers granted the Exercise such other powers as may be provided by law as well

37 Attached as Annex "A" Formal Charge and Annex "B" of Complainant Position Paper. 38 Rep. Act No. 8799 (2000), sec. 4.1 39 Pres. Decree No. 902-A (1976), secs. 5 and 6. 40 Pres. Decree No. 902-A (1976), sec. 3. Republic Act 11232, Section 179(a).

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Commission to achieve the objectives and purposes of these 1aws. 41

anytime independently of CMIC on the Sulapas account, file charges and impose administrative sanctions if warranted by the attendant circumstances. Hence, the Commission may initiate and conduct its own audit and investigation

transactions only formed a small part of his buying and selling transactions." 42 with his trading profile and with his established trading pattern, and (3) his EQ Trade including the transactions of Mr. Sulapas, (2) VSI did not make any suspicious transaction report on the transactions of Mr. Sulapas because all of his transactions were in accordance purposes of Anti-Money Laundering since (1) VSI reports all covered transactions, There is also no merit in Respondents assertion that VSI has systems in place for

and 21-A" the alleged VSI systems43 in place relative to Anti-Money Laundering. In their Anti-Money Laundering Council are also attached as Annex "23" of their Reply. claim that VSI also submits the required reports, samples of reports submitted by VSI to the In support of this argument, Respondents appended in their Reply Annexes "21

withdrawals from the Sulapas account from 4 June 2012 to 22 June 2017 were made so that that multiple checks were prepared for a particular day. The pertinent portion of the Report each check would be lower than Five Hundred Thousand Pesos (Php 500,000.00) to remove provides and we quote: the transactions from the purview of the Anti-Money Laundering Council. CMIC also noted Contrary to the Respondents claim, based on the CMIC Report, CMIC found that the

"B.3. Movement of Cash Based on Ledgers of Mr. Sulapas

603,840,730.70), were drawn in favor of Mr. Sulapas. Based on the review of money movements in the accounts of Mr. Sulapas (SU026 and SU027), CMIC noted that that the client had made no cash deposits since withdrawals, with an aggregate value of Six Hundred Three Million Eight Hundred Forty Thousand Seven Hundred Thirty and 70/100 pesos (Php inception date of the account. On the contrary, five hundred forty (540) check

CMIC found that the withdrawals from the accounts from 4 June 2012 to 22 June 2017 were made so that each check would be lower than Five Hundred Thousand Money Laundering Council. Similarly noted is the fact that multiple checks were prepared for a particular day. Pesos (Php 500,000.00) to remove the transactions from the purview of the Anti-

22 June 2019, averaging P3,388,605 per check, with a total value of However, starting 23 June 2017, the checks being prepared were already based on actual amounts for disbursements; they were no longer divided into several checks. There are one hundred twenty-seven (127) checks issued subsequent to P430,352,880.

Money Laundering may be true, the panel, nonetheless, observes that it is highly unlikely Although Respondents allegation that VSI system is in place for purposes of Anti-

43 Par. 2.81 page 24 Respondents Reply. Group Development Corporation, G.R. No. 179047, March 11, 2015. 42 par. 4.40 page 28 of Respondents Answer 41 Securities and Exchange Commission v. Subic Bay Golf and Country Club, Inc. and Universal International

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Money Laundering Act. that Respondents VSI, Racadio and Aguilar did not have any participation in violating the Customer Account Information Rule, specifically Rule 52.1.6.16 which requires the Broker Dealer, its directors, officers, and associated persons, to report any suspicious client transaction to the Anti-Money Laundering Council, pursuant to the provisions of the Anti-

Sulapas transactions from the purview of the Anti-Money Laundering Council. was Mr. Racadio. Notably, the fact that Respondent Racadio signed the multiple checks lower than Five Hundred Thousand Pesos (Php 500,000.00) and prepared for the same day starting January 7, 2016 do not discount Respondent's participation to remove the part of the records of the case, the panel also noted that one of the signatories of the checks A review of the documents submitted by VSI during the investigation which forms

VSI to the Anti-Money Laundering Council attached as Annex "23" of their Reply appears not to have any relation to VSI reports pertaining to the transactions of Mr. Sulapas Likewise, the samples of reports dated January 3-5, 2017 allegedly submitted by

Council, pursuant to the provisions of the Anti-Money Laundering Act (RA 9160, as amended) and as required by SRC Rule Sec. 52.1.6.16. their duty to report the suspicious Sulapas transaction to the Anti-Money Laundering From the foregoing, VSI, its directors, officers, and associated person, failed on

a significant time after that 44 is also without merit. may not be accused of failure to put in place and implement proper acceptance policies and procedures as to the Sulapas account at the time of the opening of the account and for VSI only in July 2014, or over two (2) years after the opening of the Sulapas account, he The claim of Mr. Racadio that since he started as an employee (as President) of

supervise VSI registered representatives in requiring the updating of the Sulapas account to the Anti-Money Laundering Council as required by the Rule at least beginning at the time he assumed the office as president of VSI. Likewise, the Customer Account Information Rule mandates the broker dealer to maintain information pertaining to the account after its opening like updating in every two years and keeping current all material information and the Respondents' (including Racadio) duty to report the suspicious Sulapas transaction in the CAIF As President, he is liable under the Rules as control person based on his failure to

Sulapas accounts, have violated Rule 52.1.6 Customer Account Information Rule. customer acceptance policies and procedures are in place and implemented in the Julieto Clearly, VSI, Racadio, Aguilar and Balabis, for their failure to ensure that proper

Racadio) the 2015 SRC Rules (VSI and C. On the Charge for Violation of Rule 48.2 in connection with Rule 48.1 of

D. On the Charge for Violation of Rule Racadio) 50.1 of the 2015 SRC Rules (VSI and

44 See paragraph 3.69 (last sentence) page 20 of Respondents Answer.

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each other. The above issues shall be discussed together because they are intertwined with

On the alleged violation of Rule 48.2 in relation to 48.1, Complainant alleges that: 45

Sulapas account is a margin account. 1. Among the documents received from VSI is a credit line agreement in favor of Julieto Sulapas which includes a provision on interest. This indicates that the

the 2015 Implementing Rules and Regulations to the Securities Regulation Code. 2. The Julieto Sulapas account does not comply with the Rules and Regulation of the Commission on margin accounts as enumerated under Rules 48.1 and 48.2 of

Racadio as the representative of VSI. 3. Despite such non-compliance, the credit line agreement is still signed by Wilfred

Respondents argued, that: 46

of the SRC-IRR regarding margin accounts; 1. Mr. Racadio cannot be held liable under Rule 48.2 in connection with Rule. 48.1

in Rules 48.1.1, 48.1.2, 48.1.3, 48.1.4, 48.1.5, and 48.2.2; 2. Mr. Racadio maintains that the Sulapas is a cash account. Moreover, even assuming without conceding that the Sulapas Account is a margin account, the said account complies with all the requirements for a margin account as set forth

borrow up to 40% of the current market value of his present stock holdings. The amount Mr. Sulapas was allowed to borrow was much lower compared to the limit set under Rule 48.1.1 of the SRC-IRR; 3. Under the terms of the credit line agreement, Mr. Sulapas was allowed to

to the minimum amount set in Rule 48.1.2 of the SRC IRR; 4. Mr. Sulapas was also required to maintain a margin of at least 60% of the current market value of his present stock holdings. This is much higher compared

5. Sulapas settled all "margin calls" made by VSI without any issues;

problems with Mr. Sulapas; 6. Mr. Sulapas always maintained sufficient collateral on securities in accordance with Rule 48.2.2 of the SRC-IRR. Venture Securities also did not encounter any

rest of the Respondents to evade the requirements for margin accounts under the SRC and the SRC-IRR; 7. Based on the foregoing, there is no intention on the part of Mr. Racadio and the

On the alleged violation of Rule 50.1, Complainant alleges that: 47

46 Page 38 of Respondents Answer. 47 Page 22 of the Formal Charge..- 45 Page 21 of the Formal Charge.

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1. During the administrative proceedings, Adora Aguilar insisted that the Julieto Sulapas account is a cash account.

2. Assuming arguendo that the account is indeed a cash account, the account ledger of Julieto Sulapas submitted by VSI however shows that Julieto Sulapas did not settle his purchases within T+3 in violation of the SRC IRR.

to the T+3 requirement in this case. 3. The President Wilfred Racadio has the duty to oversee the day to day operations of Venture Securities, including ensuring the compliance of the broker dealer to the requirements for cash accounts under the Securities Regulation Code and its Implementing Rules and Regulations. Wilfred Racadio failed to ensure compliance

4. Hence, VSI and Wilfred Racadio violated Rule 50.1 of the 2015 SRC Rules.

On the other hand, Respondents contended that:48

with regard to the Sulapas Account; 1. VSI and Mr. Racadio cannot be made liable for violating Rule 50.1 of the SRC-IRR

he did not avail of the Credit Line Agreement, Mr. Sulapas was able to settle his purchases within T+3 days: 2. The account ledgers of the Sulapas account show that Mr. Sulapas settled his his Credit Line, or by paying in cash. Mr. Sulapas did not need to avail of his Credit Line Agreement for the majority of his purchases. For all of his transactions where purchases within T+3 days. Mr. Sulapas settled his purchases by selling"shares within T+3 days (with proceeds enough to pay for the purchases), or by availing of

3. As previously discussed, the account of Mr. Sulapas complies with Rules 48.1.1, 48.1.2, 48.1.3, 48.1.4, 48.1.5, and 48.2.2. of the SRC IRR:

account. Interestingly, no other than the Complainant submitted the CMIC Report dated Cash Account. The pertinent portion of the Report, reads: the evidence presented. Based on the CAIF's and the account opening agreement (Terms and Conditions) submitted, we are inclined to believe that the Sulapas account is a cash 19 December 2020 as part of its evidence stating that the Sulapas Account with VSI is a In weighing the arguments of the parties on these issues, it is important to examine

identified as margin account in the ACD Form 01, a form requested by each trading participant prior to commencement of audit, had been charged interest by Venture beginning 2015. This may amount to violations of the hundred Thirty-One Thousand Four Hundred Fourty-Seven and 23/100 pesos (8,731,447.23)." 49 pertinent laws. Total interest charges amounted to Eight Million Seven "Lastly CMIC noted that one of the accounts of Mr. Sulapas, not

Accounts and not a Margin Accounts. On this point, we agree with the Respondents that Mr. Sulapas Account is a Cash

49 Item B.3 par. 3 page 7 CMIC Report. 48 Page 39 of the Respondents Answer

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and SRC Rules 48.2, 48.1 and 50, which state as follows: The provisions governing the above issues are Sections 48.2 and 50 of the SRC50

"Section 48. Margin Requirements.

X X X

credit to or for any customer: extend or maintain credit or arrange for the extension or maintenance of 48.2. No member of an Exchange or broker or dealer shall, directly or indirectly

prescribe under this Section including rules setting credit in relation to net capital of such member broker or dealer: and a) On any security unless such credit is extended and maintained_in accordance with the rules and regulations which the Commission shall

the provisions of paragraph (a) of this subsection. (Emphasis ours) b) Without collateral or any collateral other than securities, except (i) to maintain Commission and (ii) in cases where the extension or maintenance of credit is not for the purpose of purchasing or carrying securities or of evading or circumventing a credit initially extended in conformity with rules and regulations of the X X X"

SRC Rule 48.2 - Prohibitions on Extension of Credit starting on the next trading day but not beyond ten (10) trading days following the last day for the customer to pay such purchase price_ unless such sale cannot be effected within said period for justifiable reasons. x x x" To prevent indirect violations of the margin requirements under Section 48, the pay the price of the security purchased for his account within such period as the Commission may prescribe, which shall in no case exceed the prescribed settlement date. Qtherwise, the broker shall sell the security purchased broker or dealer shall require the customer in non-margin transactions to "Section 50. Enforcement of Margin Requirement and Restrictions on Borrowing. -

any customer on the following: No member of an Exchange or broker or dealer shall, directly or indirectly, extend or maintain credit or arrange for the extension or maintenance of credit to or for

member, broker or dealer; accordance with the rules and regulations which the Commission shall prescribe under this Section including rules setting credit in relation to net capital of such 48.2.1. On any security unless such credit is extended and maintained in

SRC Rule 48.1 - Margin

in the account and thirty percent (30%) of the current market value of securities account in which the equity is less than Fifty Thousand Pesos (PhP 50,000.00). than twenty five percent (25%) of the current market value of all securities "long" "short" in the account. of the transaction. In no event shall new or additional credit be extended to an 48.1.2. The margin maintained in a margin account of a customer shall be no less 48.1.1. A Broker Dealer shall not extend credit to a customer in an amount that exceeds fifty percent (50%) of the current market value of the security at the time

50 Republic Act 8799 {2000}.

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shall be executed by the Broker Dealer from the time of insufficiency up to the be issued promptly by the Broker Dealer to the customer. A call for initial margin shall be satisfied within five (5) business days from receipt of the call. A call for maintenance margin shall be satisfied within twenty four (24) hours after the call is received. No purchase or sell order from the customer on the margin account Satisfaction of the call. 48.1.3. When there is an insufficiency of margin, a call for additional margin shall

Exchange in which it is traded before the close the next trading day. 48.1.4. If a margin call is not satisfied within the time prescribed in SRC Rule 48.1.3, the Broker Dealer shall liquidate securities sufficient to meet the margin call or eliminate the margin deficiency existing on the day such liquidation is required, whichever is less. The Broker Dealer shall liquidate the securities through the

into consideration whether the Broker Dealer and the customer are acting in good original payment period or the expiration of any previous extension. seven (7) days upon written application delivered by hand, facsimile transmission, email or equally prompt means by the Broker Dealer to an Exchange, in the case of members of that Exchange, or to the Commission, in the case of non-Exchange members. In granting such an extension, the Exchange or Commission will take faith and whether exceptional circumstances warrant such extension. Application for the extension must be received and acted upon before the expiration of the 48.1.5. The required payment date for a call for initial margin may be extended by

SRC Rule 50 - Purchases and Sales in Cash Account 50.1. Purchases by a customer in a cash account shall be paid in full within three (3) business days after the trade date.

be made with the Exchange and the Commission. following the last day for the customer to pay, unless such sale cannot be effected 50.2. If full payment is not received within the required time period, the Broker Dealer shall cancel or otherwise liquidate the transaction, or the unsettled portion thereof, starting on the next business day but not beyond ten (10) business days within said period for justifiable reasons in which case; notification in writing shall

action required by SRC Rule 50.2. to cover each purchase transaction prior to execution. 50.4. If the amount of money due from a customer in a cash account is less than Ten Thousand Pesos (PhP10,000.00) the Broker Dealer may choose not to take the payment by the customer, prior to any subsequent purchase during the next ninety (90) days, the customer shall be required to deposit sufficient funds in the account 50.3. if a transaction is cancelled or otherwise liquidated as a result of non-

understanding that payment is to be made upon delivery. purchased is unissued or where the purchase is made by the customer with the 50.5. Exceptions to SRC Rules 50.1, 50.2, and 50.3 include when the security

exceptional circumstances and must be filed and acted upon before the expiration of the original payment period or the expiration of any subsequent extension. in the case of a member of that Exchange or to the Commission, in the case of a non-member of the Exchange. Applications for the extension must be based upon 50.6. Written application for an extension of the period of time required for payment under SRC Rule 50.1 may be made by the Broker Dealer to the Exchange XXX

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with the understanding that payment is to be made upon delivery. accounts and lays down the exceptions to the general rule (i.e., that full payment must be made within 3 days) which include a situation where the purchase is made by the customer or maintain credit on any securities other than in conformity with the rules and regulations issued by the Commission. Section 50 of the SRC and SRC Rule 50 set forth the rules on purchases and sales by customers in cash account to prevent indirect violations of Section 48.2 by brokers dealers. SRC Rule 50 prescribes in detail the regulations governing cash Section 48.2 of the SRC and Rule 48.2 above make it unlawful for a broker to extend

occasion to discuss the general rule and the purpose of margin requirements, to wit: The Supreme Court in the case of Abacus Securities Corporation v. Ampil51 had the

securities market and redirect resources into more productive uses. Specifically, the main objective of the law on margins is explained in this wise: patterned, abound with authorities explaining the main purpose of the above statute on margin requirements. [The main purpose of the statute] is to regulate the volume of credit flow, by way of speculative transactions, into the "The United States, from which our country's security policies are

too thinly - although such a result will be achieved as a byproduct of the main to make themselves safe without the help of law. Nor is the main purpose even security loans for lenders. Banks and brokers normally require sufficient collateral protection of the small speculator by making it impossible for him to spread himself purpose. The main purpose of these margin provisions x x x is not to increase the safety of

X X X

method of reducing the aggregate amount of the nation's credit resources which can be directed by speculation into the stock market and out of other more desirable uses of commerce and industry x x x. "The main purpose is to give a [glovernment credit agency an effective

A related purpose of the governmental regulation of margins is the stabilization of the economy. Restrictions on margin percentages are imposed 'in order to achieve the objectives of the government with due regard for the promotion of the economy and prevention of the use of excessive credit.

economy from excessive speculation in securities. Their recognized secondary purpose is to protect small investors. Otherwise stated, the margin requirements set out in the [SRC] are primarily intended to achieve a macroeconomic purpose -- the protection of the overall

subsequent to an unpaid order, the broker should require its customer to deposit funds into the account sufficient to cover each purchase transaction prior to its purchase. The word "shall" as opposed to the word "may," is imperative and operates to impose a duty, which may be legally enforced. For transactions execution. These duties are imposed upon the broker to ensure faithful order. if payment is NOT RECEIVED WITHIN THREE DAYS from the date of The law places the burden of compliance with margin requirements primarily upon the brokers and dealers. [Sections 48.2 and 50 of the SRC and SRC Rule 50] otherwise known as the 'mandatory close-out rule.' clearly vest upon petitioner the OBLIGATION not just the right. TO CANCEL or otherwise LIQUIDATE a customer's

51 G.R. No. 160016, 27 February 2006

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from extending undue credit to a customer. compliance with the margin requirements of the law, which forbids a broker

most direct and effective method of discouraging an abnormal attraction of funds into the stock market and achieving a more balanced use of such as collateral for the advance or loan. Brokers take these securities/stocks to their bank and borrow the 'balance' on it, since they have to pay in full for the traded stock. Hence, increasing margins, i.e., decreasing the amounts which brokers may lend for the speculative purchase and carrying of stocks is the It will be noted that trading on credit (or 'margin trading') allows investors to buy more securities than their cash position would normally allow. Investors pay only a portion of the purchase price of the securities; their broker advances for them the balance of the purchase price and keeps the securities resources.

prices, however, they may cause other forced sales and the resultant snowballing effect may in turn have a general adverse effect upon the entire market.' 'x x x [The x x x primary concern is the efficacy of security credit controls in securities price rises and accelerated declines in the prices of given securities issues and in the general price level of securities. Losses to a given investor resulting from price declines in thinly margined securities are not of serious significance from a regulatory point of view. When forced sales occur and put pressures on securities preventing speculative excesses that produce dangerously large .and rapid

to enforce the margin requirements. are in the superior position to prevent the unlawful extension of credit. Because of this awareness, the law imposes upon them the primary obligation to verify, at any time, the status of the client's account. Brokers, therefore, The nature of the stock brokerage business enables brokers, not the clients,

omission." (Emphasis ours) even be waived. An obligation, however, must be performed; those who do not discharge it prudently must necessarily face the consequence of their dereliction or Right is one thing; obligation is quite another. A right may not be exercised; it may

settle his purchases within T+3 days. 52 his purchases by "selling" shares within T+3 days (with proceeds enough to pay for the purchases), or by availing of his Credit Line, or by paying in cash. Mr. Sulapas did not need to avail of his Credit Line Agreement for the majority of his purchases. For all of his transactions where he did not avail of the Credit Line Agreement, Mr. Sulapas was able to account show that Mr. Sulapas settled his purchases within T+3 days. Mr. Sulapas settled order, if payment is not received within three (3) days from the date of purchase. investor, as in this instant case, when the shares were purchased by Mr. Sulapas. As a consequence, brokers and dealers are forbidden from extending credit under Section 48.2 of the SRC, and SRC Rules 48.2 and 50 obligate them to liquidate the shares in a customer's regulate the credit flow in the securities market when shares of stock are purchased by an In this case, the Respondents alleged that the account ledgers of the Sulapas As can be gleaned from the case of Abacus, the purpose of the general rule is to

52 Par. 2.135 page 31 Position Paper

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of the purchases of Sulapas allegedly within T+3 by availing a credit line since the Sulapas account is a cash account. Unfortunately for the Respondents, they unlawfully applied the payment on some

days, the customer shall be required to deposit sufficient funds in the account to cover each purchase transaction prior to execution. Commission. If a transaction is cancelled or otherwise liquidated as a result of non- payment by the customer, prior to any subsequent purchase during the next ninety (90) or otherwise liquidate the transaction, or the unsettled portion thereof, starting on the next business day but not beyond ten (10) business days following the last day for the customer to pay, unless such sale cannot be effected within said period for justifiable reasons in which case, notification in writing shall be made with the Exchange and the in a cash account shall be paid in full within three (3) business days after the trade date. If full payment is not received within the required time period, the Broker Dealer shall cancel The provision of SRC Rule 50 is specific. It provides that "purchases by a customer

amount based on the previous day credit balance enumerated herein below. Sulapas paid cash for his transactions in the amount of Php 981,612.00 on 04 November 2019 for the transaction Buy 87228 dated 29 October 2019 for 20,000 shares of ALI at P48.80 per shares. To be clear, the Sulapas account had 559 transactions from 2012 to 2019 which were not paid in cash within T+3 taking into consideration the net payable To repeat, based on Sulapas ledger (SU026), there was only one event that

Friday, 8 June 2012 2012 T+O NO. 1

Date Ref no Transaction Particular E Amount

Friday, 22 June 2012 2 Amount(06/14/2012) Cr. As of Settlement Date 06/14/2012 06/14/2012) Friday,8 June 2012 Due Clearing Net Payab Friday,8 June 2012 Friday, 8 June 2012 47228 39703 47223 SELL SELL BUY 10,000 EW 300,000 150,000 shares Shares Shares MC VMC -241,377.00 98,899.24 6,377.30 526,650.94 -186,374.70 -92,521.94

Friday, 22 June 2012 Friday, 22 June 2012 Friday, 22 June 2012 Friday, 22 June 2012 Friday, 22 June 2012 Friday, 22 June 2012 Friday, 22 June 2012 Date 43 0 473 92 398 29 47391 39831 3 9825 3 9828 Ref O Transaction SELL SELL SELL BUY BUY BUY BUY DIZ shares 5,000 DIZ Particular DiZ shares 81,200 NI 2,300 DIZ NI shares 100,000 shares 12,700 share 118,800 20,000 shares shares ORE -179,553.82 -452,596.70 1,050,400.29 721,565.29 552,369.98 -82,3 64.95 683,910.00 Amount

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Friday, 29 June Monday, 2 July Wednesday, 4 Friday, 6 July July 2012 Monday, 25 June 2012 2012 2012 2012 3 Amount(07/09/2012] Amount(07/05/2012) Amount(07/04/2012 Wednesday, 4 July 2012 Wednesday, 4 July 2012 Net Payable Amount(06/28/2012 Net Payable Net Payable Net Payable Date Monday, 2 July 2012 Date Amount(06/27/2012 Monday, 25 June 2012 Date Friday, 29 June 2012 Friday, 29 June 2012 Friday, 29 June 2012 Friday, 29 June 2012 Friday, 22 June 2012 Monday, 25 June 2012 Monday, 25 June 2012 Friday, 22 June 2012 Friday, 22 june 2012 Due Clearing (06/27/2012 (06/27/2012) Net Payable Date Monday, 25 June 2012 Cr. As of Settlement Date 39938 47553 39898 39883 39838 47409 47410 47416 39879 47475 47406 47468 47396 47401 Ref Ref O o. Ref nO Ref no. Transaction Transaction Transaction Transaction SELL SELL SELL BUY BUY SELL SELL SELL SELL BUY SELL SELL BUY BUY Particular Particular Particular 1,000,000 1,000,000 1,500,000 Particular DIZ Shares DIZ Shares 2,000,000 NI Shares 500,000 100,000 1,100 DIZ 200,000 500,000 500,000 shares GERI 100,000 900,000 48, 900 'Shares LIHC 100,000 shares RFM shares MEG LIHC shares shares RFM MARC shares TDY shares ORE shares VMC S S S 2,045,433.99 220,267.74 2,252,880.00 1,825,166.25 2,252,880.0 1,790,458.40 2,604,892.50 3,872,137.50 1,759,982.05 2,229,848.64 1,760,864.99 1,721,295.00 319,834.74 374,160.92 1,326,584.25 -529,743.38 -252,456.60 184,945.86 -172,500.85 -40,549.36 Amount 12,445.01 Arnount Amount Amount D

Friday,6 July 2012 Friday, 6 July 2012 Date 39978 39992 Ref nO. Transaction BUY BUY Particular LR shares 300,000 500,000 BEL shares S 2,614,950.00 2,684,321.62 Amount

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Monday, 9 July 2012 8 Amount(07/11/2012) Friday, 6 July 2012 Friday,6 July 2012 Friday, 6 July 2012 Net Payable Friday,6 July 2012 Friday, 6 July 2012 Friday, 6 July 2012 Friday,6 July 2012 47597 47603 475 2 47602 47586 47591 39993 SELL SELL SELL SELL SELL SELL BUY 63,900 LR DIZ shares DIZ shares LR shares 100,000,0 00 OPMB 500,000 136,100 500,000 shares shares 35,700 14,300 shares shares LIHG BEL 1,161,156.90 593,601.91 2,011,500.00 2,621,512.50 1,247,112.83 -638,066.26 -547,425.24 -501,895.98

Thursday, 12 Amount(07/12/2012) Monday,9 July 2012 Monday, 9 July 2012 Net Payable Monday,9 July 2012 Date 47612 40007 40009 Ref O Transaction SBLL BUY BUY Particular 2,000,000 1,500,000 IC shares 300,000 BLOOM shares shares LCB S 3,163,621.50 2,181,939.7 2,247,851.25 3,097,710.00 Amount 5

Friday,13 July July 2012 2012 10 Amount(07/17/2012) Due Clearing 07/17/2012 Cr. As of Settlement Date Thursday,12 July 2012 Thursday, 12 July 2012 (07/17/2012) Net Payable Date 4054 40070 Ref no. Transaction BUY BUY Particular 100,000,0 00 GREEN 110,000 shares PGOLD shares C 4,151,651.6 2,987,077.50 4,495,702.50 1,508,625.00 -344,050.84 Amount

Thursday, 19 Tuesday, 17 July 2012 July 2012 12 11 Net Payable Amount(07/20/2012) Tuesday,17 July 2012 Amount(07/18/2012) Friday, 13 July 2012 Friday, 13 July 2012 Tuesday,17 July 2012 Net Payable Date Friday,13 July 2012 Date 4726 40117 47704 40080 47686 Ref nO Ref no. Transaction Transaction SELL SELL BUY SELL BUY Particular ELI shares 5,000,000 ELl shares 5,000,000 Particular 5,000,000 1,000,000 100,000 PGOLD shares shares shares ABA ABA S 4,508,928.11 4,313,149.79 195,778.32 4,525,875.00 2,641,29 7.50 1,053,607.5 -830,970.00 Amount Amount 0

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Wednesday, 1 August 2012 August 2012 Tuesday, 24 Tuesday, 31 Friday, 3 July 2012 July 2012 11 15 14 13 Amount([08/06/2012] Friday, 3 August 2012 Wednesday, 1 August 2012 Date Friday, 3 August 2012 Friday, 3 August 2012 Amount(07/27/2012) Amount(08/03/2012) Wednesday, 1 August 2012 Wednesday, 1 August 2012 Net Payable Tuesday, 31 July 2012 Net Payable Date Wednesday, 1 August 2012 Wednesday, 1 August 2012 Date Thursday, 19 July 2012 Net Payable Date Tuesday, 24 July 2012 Tuesday, 24 July 2012 Net Payable Tuesday, 31 July 2012 Tuesday, 31 July 2012 Thursday,19July 2012 Thursday, 19 July 2012 Amount(07/24/2012 Tuesday, 24 July 2012 Date 40349 40368 40369 40302 40309 47855 47878 40289 40202 47778 40279 40280 47840 40156 40165 47747 40201 Ref 1O Ref Ref Ref no. Ref nD o O Transaction Transaction Transaction Transaction Transaction BUY BUY SELL SELL BUY SELL BUY BUY BUY BUY BUY SELL BUY BUY BUY SELL BUY Particular PIP shares Particular Particular Particular PIP shares 3,000,000 2,000,000 Particular 2,000,000 1,410,000 2,000,000 4,000,000 2,000,000 2,000,000 1,000,000 700,000 300,000 500000 201400 500,000 590,000 300,000 142100 shares shares shares MC shares shares shares shares shares TDY shares shares shares VMC shares TDY ABA TDY TDY shares shares ABA VMC shares ABA ABA ABA GEO ABA GEO G 1,634,042.02 2,349,210.73 1,839,977.38 2,202,592.50 1,859,790.00 2,270,328.74 1,981,689.57 926,450.31 1,850,580.00 2,051,730.00 2,307,924.69 1,682,438.71 2,789,685.00 1,206,900.00 1,859,790.00 604,140.00 3,942,540.00 2,833,616.2 1,200,678.4 -593,550.00 872,286.98 Amount Amount Amount Amount Amount 5

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Wednesday, 8 Amount(08/08/2012) Friday, 3 August 2012 Friday, 3 August 2012 Due Clearing Cr. As of Settlement Date 08/08/2012 Net Payable Friday, 3 August 2012 (08/08/2012 Friday, 3 August 2012 Friday, 3 August 2012 Friday, 3 August 2012 Friday, 3 August 2012 47938 47969 47932 47968 47931 40371 40370 SELL SELL SELL SELL SELL BUY BUY 400000 243500 237000 20000 shares shares shares 238500 261500 shares shares shares shares 13000 TDY TDY MCc TDY CAL TDY CAL 5,468,574.00 2,949,160.01 2,245,171.20 1,847,473.4 -397,697.80 3,680,753.35 1,407,643.40 -675,657.74 3,319,809.75 -77,586.88 0 August 2012 1

Thursday, 9 August 2012 18 Amount(08/13/2012) Wednesday, 8 August 2012 Net Payable Cr. As of Settlement Date (08/13/2012) Wednesday, 8 August 2012 Due Clearing 08/13/2012 Wednesday, 8 August 2012 Wednesday, 8 August 2012 Wednesday, 8 August 2012 Wednesday, 8 August 2012 Wednesday, 8 August 2012 Wednesday, 8 August 2012 Wednesday, 8 August 2012 Date 48026 48027 48025 48009 48015 40411 40398 40409 40410 Ref DO Transaction SELL SELL SELL SELL SELL BuY BUY BUY BUY Particular 1000000 445100 154900 shares 18200 shares 145200 PGOLD shares shares 610000 TDY shares shares 98300 TDY shares shares 31000 CMT TDY shares 63000 TDY TDY CMT TDY S 2,141,146.41 1,541,949.5 1,980,597.20 5,638,265.99 -599,196.86 2,751,984.69 7,639,375.27 -233,696.46 2,524,432.50 1,898,087.62 758,928.89 -75,133.53 Amount 5

Thursday, 9 August 2012 Thursday, 9 August 2012 Date 40423 40434 nO. Ref Transaction BUY BUY Particular 700,000 200,000 shares ACE TDY shares 1,233,049.50 2,635,065.00 Amount

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August 2012 Monday, 13 19 Amount(08/14/2012 Net Payable Thursday, 9 August 2012 Thursday, 9 August 2012 48949 48042 SELL SELL 158,200 PGOLD shares 50,000 CAL shares 1,493,370.4 1,001,704.64 1,373,039.43

Thursday, 16 August 2012 20 Monday, 13 August 2012 Monday, 13 August 2012 Amount(08/16/2012) Monday, 13 August 2012 Net Payable Monday, 13 August 2012 Monday, 13 August 2012 Monday,13 August 2012 Date 40476 40477 48084 40465 40475 40463 Ref no. Transaction SELL BUY BUY BuY BUY BUY Particular 10,000,00 500,000 127,700 130,300 500,000 shares shares 42,00 shares CMT 0 BHI shares TDY TDY CMT shares TDY shares 5,515,081.3 1,636,413.60 1,172,755.88 1,591,619.49 1,757,930.32 1,181,756.26 520,117.57 Amount 6

August 2012 Friday, 24 21 Amount(08/23/2012) Thursday, 16 August 2012 Net Payable Thursday, 16 August 2012 Thursday, 16 August 2012 Date 40551 48163 48164 Ref DO Transaction SELL SELL BUY Particular 200,000,0 00 GREEN 235,000 shares 65,000 shares shares TDY TDY S 2,562,652.12 243,729.01 3,520,125.00 -713,743.87 Amount

August 2012 Tuesday, 28 2 Amount(08/30/2012 Friday, 24 August 2012 Net Payable Friday, 24 August 2012] Date 40645 48236 Ref BO Transaction SELL BUY Particular 2,000,000 3,000,000 shares shares MEG MEG 4,521,871.64 6,849,157.50 2,327,285.8 Amount 6

Tuesday, 28 August 2012 Tuesday, 28 August 2012 Tuesday, 28 August 2012 Tuesday, 28 August 2012 Tuesday, 28 August 2012 Date 48252 40671 40672 40653 40665 Ref no. Transaction SELL BUY BUY BUY BUY AGI shares Particular AGI shares 300,000 1,000,000 300,000 116,000 184,000 shares shares TDY shares TDY MEG C 1,506,693.96 2,401,710.89 3,424,783.50 2,293,110.00 3,427,596.00 Amount

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Thursday, 20 September Monday, 17 September August 2012 September September Tuesday, 4 Friday, 14 Friday, 31 2012 2012 2012 2012 2 26 25 23 24 Amount(09/19/2012 Net Payable Net Payable Amount[09/20/2012] Cr. As of Settlement Date Date 2012 Friday, 14 September 2012 (09/19/2012) Monday, 17 September Tuesday, 4 September 2012 Amount(09/07/2012) Friday, 14 Septemher 2012 Friday, 14 September 2012 Friday, 14 September 2012 (09/19/2012 Amount(08/31/2012) Friday, 31 August 2012 Amount(09/05/2012) Date Net Payable Date Due Clearing Tuesday, 28 August 2012 Net Payable Date Net Payable Tuesday, 4 September 2012 Tuesday, 28 August 2012 40888 40878 48559 46684 40871 22308 Ref 40739 48266 40705 Ref no. 48261 Ref HO nO. Ref O. Transaction Transaction Transaction Transaction SELL BUY BUY BUY SELL CN SELL BUY BUY CM Particular 2,000,000 Particular 2,000,000 Particular 2,000,000 PX shares Particular 3,000,000 Dividend 2,000,000 Payment 200,000 Balance CYBR 500,000 Partial shares shares 100,000 Credit shares shares CMT Of Net MEG shares PCOR sh ares shares MEG MEG ABA Cash S 1,810,350.00 3,198,285.00 3,472,205.00 2,589,798.6 1,810,350.0 4,505,760.00 4,431,840.00 -882,406.31 4,471,410.00 2,363,512.50 2,363,512.5 1,216,957.50 1,216,765.0 1,005,078.00 200,000.00 727,839.35 Amount Amount Amount Amount -192.5 U C

2012 Thursday, 20 September 2012 Thursday, 20 September 2012 Thursday, 20 September Date 48626 40918 48621 Ref no Transaction SELL SELL BUY Particular 1,500,000 PX shares 100,000 shares shares 48,000 CMT CMT S 3,922,425.00 1,566,972.00 -121,084.20 Amount

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October 2012 October 2012 Thursday, 4 October 2012 Friday, 5 Tuesday, 25 Monday, 1 September September Friday, 21 2012 2012 32 30 28 Friday, 5 October 2012 Friday, 5 October 2012 Friday, 5 October 2012 Friday, 5 October 2012 Amount(10/09/2012 Friday, 5 0ctober 2012 Thursday, 4 October 2012 Net Payable Date Amount(10/04/2012) Thursday, 4 October 2012 Thursday, 4 October 2012 Net Payable Thursday, 4 October 2012 Monday, 1 October 2012 Date Amount(09/28/2012) Monday, 1 October 2012 Monday, 1 October 2012 Net Payable Date Friday, 21 September 2012 Date Net Payable Amount(09/26/2012) Tuesday, 25 September Tuesday, 25 September Amount(09/25/2012) Friday, 21 September 2012 2012 2012 Net Payable Date 41119 41130 48874 Ref 41118 41113 48835 41094 41088 41093 48770 48769 41038 486 7 no. 48641 40973 40939 no. Ref nO. Ref Ref no Ref no. Transaction Transaction Transaction Transaction Transaction SELL BUY BUY BUY SELL BUY BUY BUY SELL BUY SELL SELL BUY SELL BUY BUY SFI shares Particular 24500 LR 11070000 14000000 Particular LR shares 20,000,00 14000000 200,000,0 50,000,00 Particular 1,296,000 175500 shares Particular 0 APM 00 APM shares 3,000,000 1,000,000 shares 0 APM shares Particular 513,400 shares 0 MAB PX shares PX shares 600,500 BLOOM BLOOM 86,600 BLOOM shares O MA shares shares CMT 200,000 200,000 shares shares PHES PHES shares shares S S 2,260,423.14 4,646,565.00 4,985,820.00 1,568,291.14 219,303.79 5,638,725.00 1,102,254.0 2,564,662.50 1,025,865.00 3,150,451.52 6,927,404.85 269,613.86 5,692,793.44 2,283,052.50 2,989,089.00 2,948,376.53 1,551,007.5 -964,997.55 Amount -732,045.00 Amount 2,234,368.8 40,712.47 Amount Amount Amount 2 0

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October 2012 Thursday, 18 Wednesday, 10 October 2012 October 2012 Tuesday, 16 35 34 33 Cr. As of Settlement Date Amount(10/19/2012) Tuesday, 16 October 2012 Net Payable Tuesday, 16 October 2012 Due Clearing (10/19/2012 (10/19/2012) Tuesday, 16 October 2012 Tuesday, 16 October 2012 Tuesday, 16 October 2012 Tuesday, 16 October 2012 Tuesday, 16 October 2012 Amount(10/10/2012 Net Payable Amount(10/15/2012) Tuesday, 16 October 2012 Wednesday, 10 October Wednesday, 10 October Net Payable Date 2012 Date Friday,5 October 2012 Friday, 5 October 2012 Friday, 5 October 2012 2012 49108 49110 41287 41288 41298 41300 49106 46856 41195 4990 48896 48880 48881 Ref Ref no. O Transaction Transaction SELL SELL SELL BUY BUY BUY BUY SELL SELL SELL BUY C SELL 215,800,0 00 GREEN 3,640,000 300,000,0 00 GREEN 40,000,00 Particular Particular 90,000,00 LR shares 100,000,0 1,000,000 Payment 00 APM Balance 560000 CLOUD shares 1975000 200000 shares Partial CLOUD 40,000 shares shares shares MAB 100000 shares of Net Credit shares shares O EG shares D EG CYBR shares CMT CMT shares S S 6,413,411.02 4,483,083.15 5,574,646.2 1,688,895.63 4,877,887.51 6,336,225.00 2,136,780.00 2,423,662.49 -194,446.97 -838,764.81 6,436,960.93 4,013,298.4 1,682,516.40 1,733,782.30 200,000.00 124,713.00 -239,398.50 53,065.87 Amount Amount

Thursday, 18 October 2012 Thursday, 18 Octoher 2012 Amount(10/23/2012 Date Thursday, 18 October 2012 Thursday, 18 October 2012 Net Payable 41349 49155 49181 41373 Ref no Transaction SELL BUY SELL BUY Particular 20,000,00 600,000 YEHEY shares 0 APM YEHEY shares shares 7,000 shares 7.000 CMT 2,896,560.00 1,477,939.50 1,416,153.3 -20,081.77 17,614.62 Amount 5

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Thursday, 8 November October 2012 Tuesday, 6 November Monday, 29 Monday, 5 November 2012 2012 2012 39 38 36 37 Amount(11/09/2012) Net Payable Amount(11/08/2012) Tuesday, 6 November 2012 Tuesday, 6 November 2012 Monday, 5 November 2012 Net Payable Tuesday, 6 November 2012 Amount(11/05/2012) Monday, 5 November 2012 Date Monday, 5 November 2012 Monday, 5 November 2012 Monday, 5 November 2012 Date Monday, 29 October 2012 Net Payable Date Monday, 29 October 2012 41637 49509 41627 41596 41601 4940 41595 49473 415 42 49368 Ref O Ret no. Ref no. Transaction Transaction Transaction SELL BUY BUY SELL SELL SELL BUY BUY BUY BUY 200,000,0 00 GREEN Particular 00 GREEN 200,000,0 00 GREEN Particular Particular 71,000,00 79,600,00 200,000,0 1,000,000 60,970,00 1,000,000 10,380,00 49,030,00 0 GREEN shares shares VITA shares 0 APM shares shares shares 0 APM shares shares VITA 0 APM O APM shares shares S 1,478,452.51 4,626,450.00 4,748,400.00 1,356,502.5 10,203,065.1 1,192,006.8 6,176,924.26 8,071,274.50 4,352,700.00 1,663,483.22 1,499,573.25 1,850,580.00 187,096.78 Amount Amount Amount F

November Friday, 9 2012 4 Amount(11/13/2012 Net Payable 2012 Thursday, 8 November Thursday, 8 November Thursday, 8 November 2012 Thursday, 8 November Date 2012 2012 41682 49565 49576 41710 Ref o. Transaction SELL SELL BUY BUY 10,000,00 80,000,00 00 GREEN Particular 104,800,0 30,000,00 shares shares 0 APM shares 0 APM O BHI shares S 3,462,375.00 2,384,488.20 4,335,561.0 8,522,936.71 1,659,487.50 Amount

Date Ref Transaction Particular Amount

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Wednesday, 14 Thursday, 15 November 2012 41 Amount(11/19/2012 Net Payable Wednesday, 14 November Wednesday, 14 November 2012 Wednesday, 14 November 2012 Amount(11/14/2012) Friday,9 November 2012 Friday, 9 November 2012 Date 2012 Friday, 9 November 2012 Friday, 9 November 2012 Net Payable 41867 41806 49722 49617 41723 41727 41753 Ref no. Transaction SELL BUY BUY SELL BUY BUY BUY Particular 30,000,00 19,580,00 1,000,000 00 GREEN 50,000,00 100,000,0 300,000 20,000,00 shares 0 APM shares O APM shares shares shares 0 APM 0 APM shares VUL shares VUL S 2,614,884.53 1,998,490.7 4,103,460.00 2,004,228.42 6,380,662.50 2,574,720.00 2,413,800.00 612,085.92 509,915.25 Amount 2 November 2012 4

Monday, 19 November 2012 43 Amount(11/20/2012) Net Payable Thursday, 15 November Date Thursday, 15 Novemher 2012 Thursday, 15 November 2012 2012 49738 49794 41841 no. Ref Transaction SELL SELL BUY Particular 30,000,00 30,000,00 2,000,000 0 APM 0 APM shares PHES shares shares 1,602,585.00 3,982,770.00 3,800,045.59 182,724.41 Amount

Tuesday, 27 November 2012 44 Amount(11/22/2012) 2012 Net Payable Monday. 19 November Monday, 19 November Date 2012 41898 49823 Ref nO. Transaction SELL BUY Particular 10000000 O GREEN 276000 shares shares VUL G 2,118,477.1 2,514,375.00 -395,897.85 Amount 5

2012 Tuesday, 27 November Date Tuesday, 27 November Tuesday, 27 November 2012 2012 42051 42034 47087 Ref no Transaction BUY BUY CN Particular 83,000,00 0 GREEN Balance 569000 Payment shares shares VITA of Net Credit Partial 1,919,976.75 635,221.64 191,848.97 Amount

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Wednesday, 28 Tuesday, 4 November 2012 45 Amount(12/03/2012) Net Payable Cr. As of Settlement Date Date Due Clearing (12/03/2012) Amount(12/03/2012] Wednesday, 28 November 2012 (12/03/2012 Net Payable 42090 Ref no Transaction BUY Particular 111,300 shares WEB 2,334,975.8 1,578,353.65 2,747,047.36 1,578,353.6 -412,071.47 Amount 5 0

December 2012 46

December Friday, ? 2012 47 Tuesday, 4 December 2012 Amount(12/07/2012) Net Payable Tuesday, 4 December 2012 Tuesday, 4 December 2012 Date 42122 42116 23218 Ref MO Transaction BUY BUY CM Particular 17,000,00 0 GREEN Dividend BLOOM shares 45,0 00 shares Cash 1,009,775.9 393,248.26 634,527.68 -18,000.00 Amount 4

Tuesday, 11 Amount(12/12/2012) Friday,7 December 2012 Net Payable Date Friday, 7 December 2012 50169 42193 Ref no Transaction SELL BUY Particular 200,000,0 00 GREEN 100,000 shares shares WEB 3,328,554.0 4,626,450.00 1,297,896.00 Amount 0

Monday, 17 Decemher December 2012 2012 4 48 Amount(12/14/2012) Net Payable Tuesday, 11 December Tuesday, 11 December 2012 2012 Date Tuesday, 11 December 2012 50235 50236 42241 Ref no. Transaction SELL SELL BUY Particular 00 GREEN 200,000,0 2,552,000 shares shares shares 25,000 VUL VUL S 3,788,362.56 5,028,750.01 1,202,301.3 -38,086.12 Amount 3

Amount(12/20/2012) Cr. As of Settlement Date Net Payable Monday, 17 December 2012 Due Clearing (12/20/2012) (12/20/2012) Date 42359 Ref o Transaction BUY 1,500,000 Particular PHES shares G 1,210,735.49 1,229,740.58 1,229,740.58 19,005.09 Amount

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Thursday, 27 December Tuesday, 18 Friday, 28 December December 2012 2012 2012 52 51 50 Amount(01/03/2013) Amount(12/21/2012) Date Thursday, 27 December Net Payable Net Payable 2012 Thursday, 27 December Date Tuesday, 18 December Tuesday, 18 December 2012 2012 2012 42477 42381 50342 42476 Ref no. DO Ref Transaction Transaction SELL BUY BUY BUY Particular Particular 5,000,000 CLOUD CLOUD EVER 20,000 6000 shares 9.000 shares shares shares DNL S 2,058,870.83 1,969,838.3 47,949.87 28,865.03 -89,032.50 19,084.84 Amount Amount 3

Friday, 28 December 2012 Amount(01/04/2013 Friday, 28 December 2012 Net Payable Date Friday, 28 December 2012 42494 42495 42496 Ref O Transaction BUY BUY BUY Particular 24,000 62000 shares 14,000 shares shares CAL CAL CAL 401,062.93 249,426.00 55,527.45 96,109.48 Amount

Thursday, 17 January 2013 Thursday, 10 January 2013 January 2013 Tuesday, 15 Tuesday, 8 2013 55 53 54 Net Payable Amount(01/11/2013 Amount(01/15/2013 Tuesday, 15 January 2013 Amount(01/18/2013) Thursday, 10 January 20 13 Net Payable Date Net Payable Date Tuesday, 8 |anuary 2013 Tuesday, 8 January 2013 Date 42812 42694 42633 42634 Ref Ref MO Ref IO no. Transaction Transaction Transaction BUY BUY BUY BUY Particular ZHI shares 3,000,000 Particular Particular 500,000 777,000 223,000 shares shares shares CPG CPG CPG S 2,081,902.50 2,081,902.5 859,041.24 1,356,796.97 1,749,290.9 859,041.24 392,493.94 Amount Amount Amount 0 A

January 2013 56

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February 2013 Wednesday, 13 February 2013 Thursday, 21 February 2013 February 2013 Monday, 18 Tuesday, 5 59 50 58 57 Cr. As of Settlement Date (02/21/2013 Net Payable Amount(02/21/2013) Net Payable Amount(02/18/2013 Monday, 18 February 2013 Due Clearing (02/21/2013 Amount(01/22/2013) Cr. As of Settlement Date 02/08/2013 Amount(02/08/2013 Monday, 18 February 2013 Thursday, 17January 2013 Net Payable Date Date Thursday, 17 January 2013 Net Payable Date Tuesday, 5 February 2013 Tuesday, 5 February 2013 Due Clearing (02/08/2013 Wednesday, 13 February 2013 Date Thursday, 17 January 2013 Thursday,17 (anuary 2013 43681 43641 43555 50837 43315 43350 42872 42882 42904 Ref no. RO Ref nO Ref Ref Do. Transaction Transaction Transaction Transaction BUY BUY BUY BUY BUY SELL BUY BUY BUY Particular Particular CHI shares 2,000,000 TA sh ares Particular Particular 2,000,000 2,000,000 ZHI shares TA shares 1,000,000 2,000,000 2,000,000 300,000 500,000 shares shares 20,000 EVER DNL shares shares CYBR shares ARA ARA S S O S 3,416,170.67 3,942,670.76 3,691,102.50 5,195,523.47 7,358,841.43 6,457,281.7 1,504,420.97 4,978,080.5 764,370.00 -901,559.73 1,284,553.96 1,693,612.59 1,408,050.00 4,360,298.2 -217,442.96 764,370.00 -25,918.35 Amount Amount Amount Amount 1

February 2013 Thursday, 28 61 Thursday, 21 February Net Payable Amount(02/27/2013 Date 2013 Date 43800 Ref O Ret no Transaction Transaction BUY Particular Particular TA shares 2,000,000 O 3,862,080.00 3,862,080.0 Amount Amouint

(03/05/2013 Cr. As of Settlement Date Thursday, 28 February Due Clearing (03/05/2013 Thursday, 28 February 2013 2013 43987 51944 BUY SELL SLI shares 1,000,000 700,000 BEL shares 1,112,393.49 4,083,345.00 3,240,494.12 -842,850.88

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Wednesday, 20 Friday, 8 March Wednesday, March 2013 Tuesday, 12 Tuesday, 19 March 2013 March 2013 March 2013 March 2013 March 2013 Monday, 4 Tuesday, 5 2013 68 67 64 1 62 63 15 Amount(03/22/2013) Amount(03/05/2013 Amount(03/07/2013) Amount(03/08/2013) Amount(03/11/2013 Amount(03/13/2013) Amount(03/15/2013) Tuesday, 19 March 2013 Net Payable Tuesday, 19 March 2013 Net Payable Monday, 4 March 2013 Monday, 4 March 2013 Net Payable Date Tuesday, 5 March 2013 Net Payable Wednesday, 6 March 2013 Net Payable Friday,8 March 2013 Friday,8 March 2013 Net Payable Tuesday, 12 March 2013 Tuesday, 19 March 2013 Date Tuesday, 5 March 2013 Tuesday, 5 March 2013 Date Wednesday, 6 March 2013 Date Date Date Net Payable Monday, 4 March 2013 52455 52456 52263 445 65 52046 52061 52062 4204 52152 44310 44403 440 7 44111 44139 Ref Ref O n n. Ref TO. Ref Ref Ref o no. Transaction Transaction Transaction Transaction Transaction Transaction SELL SELL SELL SELL SELL BUY SELL SELL BUY BUY BUY BUY BUY BUY Particular TA shares Particular SLI shares Particular 1,000,000 2,000,000 2,000,000 SLI shares Particular Particular Particular 2,000,000 00 GREEN SLI shares TA shares 2,000,000 56,500,00 TA shares 100,000,0 TA shares 1,000,000 1,000,000 0 GREEN 300,000 107,900 92,100 BLOOM 650,000 shares shares shares shares shares 50,000 MMI MMI shares shares BEL BEL S S S 3,155,501.2 2,128,100.6 1,257,187.50 1,167,315.00 2,604,892.50 5,329,881.62 1,978,500.00 3,351,381.6 2,423,857.50 2,423,857.5 4,547,257.26 4,721,050.85 4,810,923.3 4,820,805.15 3,934,257.14 1,061,959.88 1,542,932.6 582,848.27 -732,120.17 -659,635.86 -303,699.74 Amount Amount Amount Amount Amount Amount 1 2 3 2 S

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Friday, 5 April Wednesday, 27 March 2013 2013 70 6 Amount(04/03/2013) Wednesday, 27 March 2013 Wednesday, 27 March 2013 Wednesday, 20 March 2013 Date Net Payable Wednesday, 20 March 2013 Amount(03/25/2013) Wednesday, 20 March 2013 Wednesday, 20 March 2013 Net Payable Date 44812 52660 52490 445 98 44593 44597 Ref no. Ref no Transaction Transaction SELL SELL BUY BUY BUY BUY Particular 20,000,00 Particular 100,000 BLOOM shares shares 150,000 O BHI 150,000 shares 6,000 PRIM shares 1,000 PRIM shares shares MM MMI S S 2,755,755.00 1,384,950.00 1,370,805.0 1,156,612.51 1,135,179.20 34,999.31 11,533,71 Amount 2,032.29 Amount

Monday, Amount(04/11/2013) Net Payable Friday, 5 April 2013 Friday, 5 April 2013] Friday, 5 April 2013] Friday, 5 April 2013 Date 45030 45031 45032 45018 Ref nO Transaction BUY BUY BUY BUY 100,000 T Particular 110,000 T 1,000,000 65,000 T shares shares shares shares MED 1,283,789.5 289,857.15 275,575.50 543,105.00 175,251.94 Amount 9 April 2013 1

Tuesday, 16 April 2013 Monday, 15 April 2013 73 72 Amount(04/18/2013 Due Clearing (04/18/2013) 04/18/2013 Net Payable Cr. As of Settlement Date Monday,15 April 2013 Monday, 15 April 2013 Amount(04/12/2013) Monday, 15 April 2013 Net Payable Monday,8 April 2013 Date Date 455 08 45509 45507 45049 Ref no. Ref DO Transaction Transaction BUY BUY BUY BUY 1,222,000 Particular TA shares TA shares Particular 200,000T 778,000 700,000 shares shares MPI S 9,048,182.61 1,484,565.77 7,563,616.8 1,885,761.13 2,949,663.60 4,212,757.88 522,869.32 522,869.32 Amount Amount

Tuesday, 16 April 2013 Date 45297 Ref nO Transaction BUY Particular 500,000 shares MPI S 2,831,186.25 Amount

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Wednesday, 17 April 2013 74 Tuesday, 16 April 2013 Amount(04/19/2013) Net Payable Tuesday, 16 April 2013 45310 53057 SELL BUY 2,000,000 TA shares 1,200,000 MPI shares 4,666,680.00 6,529,050.00 968,816.25

Wednesday, 24 April 2013 Monday, 22 April 2013 76 15 Amount(04/25/2013) Monday, 22 April 2013 Net Payable Amount(04/22/2013 Monday, 22 April 2013 Monday,22 April 2013 Net Payable Date Monday, 22 April 2013 Wednesday, 17 April 2013 Wednesday, 17 April 2013 Wednesday, 17 April 2013 Wednesday. 17 April 2013 Date 53347 53304 45526 45578 45360 53141 45359 45313 Ref no. Ref mO. Transaction Transaction SELL SELL BUY SELL BUY BUY BUY BUY Particular 2,000,000 TA shares Particular 7,000,000 222,000 1134,000 50,000 shares shares shares 916,000 ACR shares PNB 44,700 shares shares shares 50,000 APC VUL VUL ABS VUL S 5 5,025,390.00 6,430,033.8 6,336,225.00 5,431,050.00 -311,851.18 1,631,648.35 2,047,978.56 5,495,332.4 1,910,673.57 -94,968.00 Amount Amount 2 6

Thursday, 25 Amount[04/29/2013] Net Payable Cr. As of Settlement Date Due Clearing (04/29/2013) Wednesday, 24 April 2013 Wednesday, 24 April 2013 (04/29/2013) Date 45861 45859 Ref nO Transaction BUY BUY TA shares Particular 1,000,000 2,000,000 TA shares C 5,431,050.00 8,096,287.50 7,569,048.5 2,665,237.50 -527,238.94 Amount 6 April 2013 7?

Monday, 29 April 2013 18 Amount(04/30/2013] Net Payable Thursday, 25 April 2013] Thursday, 25 April 2013] Date 45864 53509 no. Ref Transaction SELL BUY Particular 2,000,000 508,000 shares shares SUN ACR 1,185,267.0 1,890,810.00 -705,542.99 Amount

Amount(05/03/2013) Monday, 29 April 2013 Net Payable Date 45952 Ref no Transaction BUY TA shares Particular 1,000,000 G 2,765,812.5 2,765,812.50 Amount 0

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Tuesday, 30 April 2013 79

Monday, 6 May 2013 80 Amount(05/06/2013) Net Payable Tuesday, 30 April 2013] Tuesday, 30 April 2013 Tuesday, 30 April 2013 Date Tuesday, 30 April 2013 46053 53691 46000 45999 Ref o. Transaction SELL BUY BUY BUY Particular SLI shares 2,000,000 TA shares 2,000,000 1,342,000 SLI shares SLI shares 658,000 S 1,920,737.70 1,368,051.32 5,732,775.01 5,861,725.6 681,637.00 Amount

Tuesday, 7 May 2013 81 Amount(05/09/2013) Net Payable Date Monday.6 May 2013 Monday,6 May 2013 46140 46139 Ref mO Transaction BUY BUY Particular 121,500 shares 20,100 shares H20 H20 S 1,231,390.0 1,063,128.04 168,261.98 Amount 2

Tuesday, 21 Tuesday, 14 May 2013 May 2013 3 82 Amount(05/17/2013) Amount(05/10/2013) Tuesday, 14 May 2013 Net Payabie Net Payable Tuesday, 7 May 2013 Tuesday, 14 May 2013 Date Tuesday,7 May 2013 Date Tuesday,7 May 2013 Tuesday, 7 May 2013 54151 46549 46888 46228 46229 247 12 Ref O nO Ref Transaction Transaction SELL BUY BUY BUY BUY CM Particular TA shares 2,000,000 1,295,000 TA shares 20,000,00 Particular 29,000 TA 1,971,000 TA shares Dividend shares O BHI shares Cash S 5,531,625.00 1,944,604.5 3,587,020,49 9,194,680.4 5,257,920.21 4,002,885.00 -144,000.00 77,875.23 Amount Amount

Wednesday, 22 May 2013 84 Amount(05/24/2013 Net Payable Tuesday, 21 May 2013 Tuesday, 21 May 2013 Tuesday; 21 May 2013 Tuesday, 21 May 2013 Date 54340 46791 46761 46760 DO Ref Transaction SELL BUY BUY BUY TA shares Particular 356000 1500000 shares 85400 13000 VUL shares H20 share H20 3,059,288.3 3,240,858.41 -975,519.22 105,905.47 688,043.65 Amount

Wednesday, 22 May 2013 Date 46804 Ref no Transaction BUY Particular 40,200 shares H20 332,344.05 Amount

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Tuesday, 4 June Friday, 24 May Friday, 31 May Monday,17 Monday, 10 June 2013 Tuesday, 28 June 2013 May 2013 2013 2013 2013 90 88 8 85 86 8 Amount(06/14/2013 Net Payable Monday, 17 June 2013 06/20/2013 (06/20/2013) Amount(06/07/2013 Monday, 10 June 2013 Due Clearing Cr. As of Settlement Date Net Payable Amount(06/20/2013 Amount(06/05/2013 Date Monday,10 June 2013 Date Amount(05/27/2013 Amount(05/29/2013) Date Date Tuesday, 4 June 2013 Tuesday, 4 June 2013 Tuesday, 4 June 2013 Net Payable Friday, 24 May 2013 Friday, 24 May 2013 Net Payable Net Payable Amount(05/31/2013) Date Net Payable Tuesday, 28 May 2013 Friday,31 May 2013 Net Payable Date Friday, 24 May 2013 Tuesday, 28 May 2013 47591 47425 47437 47298 54730 47037 47234 47291 54435 54464 47014 46902 Ref Ref no. Ref Ref DO DO no. Ref no. no Ref Transaction Transaction Transaction Transaction Transaction Transaction BUY BUY BUY SELL SELL BUY SELL BUY BUY BUY BUY BUY Particular Particular 1500,000 Particular 3,000,000 Particular 3,000,000 TA shares 1,500,000 Particular 4,000,000 Particular 4600 H20 2000000 2,000,000 500,000 644,000 150000 MEG 300000 COSCO DMPL shares MEG shares shares shares shares shares MEG shares shares shares SUN LCB shares MMI shares MEG VUL S S S 6,177,266.2 5,317,460.59 1,197,236.11 1,799,739.34 5,317,460.59 4,120,224.4 3,017,250.00 5,664,487.5 4,377,526.88 1,637,287.88 5,310,360.01 11,334,802.5 10,980,675.0 8,066,115.00 2,982,588.75 3,446,238.3 634,298.36 3,017,250.0 600,432.75 332,344.05 Amount 33,865.61 Amount Amount Amount Amount Amount 2 8 0 I 2 0 1

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Wednesday, 19 Monday, 24 June 2013 June 2013 91 92 Wednesday, 19 june 2013 Amount(06/24/2013) Net Payable Date Wednesday, 19 June 2013 Date 47637 55111 Ref no. TD Ref Transaction Transaction BUY SELL Particular Particular 1,000,000 TA shares 500,000 shares MEG O S 2,309,101.43 1,760,865.00 548,236.43 Amount Amount

Wednesday, 26 Friday, 28 June Tuesday, 25 June 2013 June 2013 2013 9 5 983 94 Amount(07/01/2013 Amount(06/27/2013) Amount(06/28/2013) Date Wednesday, 26 June 2013 Net Payable Monday, 24 June 2013 Net Payable Date Tuesday, 25 June 2013 Net Payable 47795 47734 47760 Ref Ref no no. Transaction Transaction BUY BUY BUY Particular Particular 300,000 100000 734000 shares shares MCP CYBR MCP shares S S 2,715.525.00 2,715,525.0 824,715.00 443,334.59 824,715.00 443,334.59 Amount Amount 0

Wednesday, 3 Thursday, 4 July 2013 91 Due Clearing Amount(07/03/2013) Wednesday, 3 July 2013 Wednesday, 3 July 2013 Wednesday, 3 July 2013] Wednesday, 3 July 2013 Wednesday, 3 July 2013] (07/08/2013 Cr. As of Settlement Date (07/08/2013 Net Payable Amount(07/08/2013) Date Friday, 28 June 2013 Date Friday, 28 June 2013 Net Payable 55533 55520 55528 55405 48073 47879 48005 Ref nO Ref nO Transaction Transaction SELL SE LL SELL SELL BY BUY BUY TA shares Particular Particular 3,000,000 3000000 200,000 146000 500000 135000 shares PGOLD PGOLD shares shares 69500 shares CYBR Shares shares MCP MEG MEG 5,922,459.56 7,125,399.57 5,281,870.0 1,282,068.00 2,512,917.57 10,047,442.5 9,685,372.50 2,922,042.9 -324,968.62 -640,589.52 357,041.25 Amount Amount 0 3 4

July 2013 97

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Friday, 12 July Thursday, 11 July 2013 2013 99 9 Amount(07/16/2013) Cr. As of Settlement Date Thursday, 11 July 2013 Due Clearing (07/16/2013 Net Payable Amount(07/09/2013) (07/16/2013 Thursday, 4 July 2013 Thursdav, 4 July 2013 Thursday,11 July 2013 Thursday, 11 july 2013 Net Payable Date Thursday, 4 July 2013 Thursday, 4 July 2013 Thursday, 4 July 2013 Thursday, 4 July 2013 Thursday,4 July 2013 Date Thursday,4 July 2013 48276 48275 48076 48274 48037 48039 4800 55556 48022 48038 48017 Ref IO. Ref no Transaction Transaction BUY BUY BUY BUY SELL BUY BUY BUY BUY BUY BUY Particular 5000000 LC shares Particular LC shares 609500 1000000 390500 4000000 1000000 COSCO COSCO 145000 shares shares 109400 shares shares 15700 shares CYBR shares shares shares shares 47300 MCP MMI MCP 72600 MCP MCP MCP S 8,289,666.33 4,654,766.6 2,609,921.25 1,389,797.31 4,023,022.10 6,311,489.58 12,944,432.9 5,393,761.1 1,196,842.51 2,312,520.97 1,122,919.88 488,903.13 164,037.83 733,964.17 764,370.00 Amount Amount C

Wednesday, 17 Amount(07/17/2013) Date Friday, 12 July 2013 Net Payable 48283 Ref O Transaction BUY Particular 500000 BLOOM shares S 5,257.793.4 5,257;393.49 Amount 9

Thursday, 18 Tuesday, 23 July 2013 July 2013 101 100 Amount(07/22/2013) Amount(07/23/2013) Wednesday, 17 July 2013 Thursday, 18 July 2013 Net Payable Net Payable Date Date 485 87 48514 Ref DO Ref n Transaction Transaction BUY BUY Particular LC shares Particular 2000000 TA shares 1000000 S 4,928,175.00 4,928,175.0 522,990.00 522,990.00 Amount Amount 0

july 2013 102

Date Ref 10 Transaction Particular Amount

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Thursday, 25 July 2013 103 Due Clearing Amount(07/26/2013 Tuesday, 23 July 2013 07/26/2013) Cr. As of Settlement Date (07/26/2013) Net Payable Tuesday, 23 July 2013 Tuesday, 23 July 2013 48776 48844 48758 BUY BUY BUY TA shares TA shares 1631000 419000 400000 SMPH shares 3,776,117.43 13,002,569.3 7,442,501.74 1,131,046.32 4,429,021.27 9,226,451.9 3 E

Date Ref no. Transaction Particular $ Amount

Wednesday, 14 Thursday, 22 August 2013 August 2013 Thursday, 8 August 2013 Thursday, 1 106 105 104 Amount(08/19/2013) Amount(08/06/2013) Amount(08/13/20i3) Wednesday, 14 August Net Payable Thursday, 8 August 2013 Date 2013 Cr. As of Settlement Date Net Payable Due Clearing (08/06/2013 Net Payable Date Thursday, 1 August 2013 Thursday,1 August 2013 Thursday, 25 July 2013 Net Payable Amount(07/30/2013) Date (08/06/2013) Thursday, 25 July 2013 Thursday, 25 July 2013 493 67 492 3 48601 49180 Ref 56168 Ref nO. 488 48848 Ref nO no. Transaction Transaction Transaction BUY BUY BUY SELL CN BUY BUY Particular Particular TSI shares 10000000 LC shares Particular of Account 100000 sh ares 50000 SECB Payment 100000 ALPHA 10800 ALPHA shares 29200 shares shares MCP S S 6,739,530.7 1,158,624.00 6,739,530.75 6,736,800.01 4,470,293.00 1,158,624.0 6,436,800.01 2,266,507.0 1,036,734.00 972,487.99 300,000.00 1,468,395.00 Amount 540,826.99 Amount Amount 5

August 2013 August 2013 Friday, 30 108 107 Amount(08/28/2013) Net Payable Thursday, 22 August 2013 Date Thursday, 22 August 2013 Date 49554 49553 Ref Ref DO 0 Transaction Transaction BUY BUY IRC shares IRC shares Particular Particular 600000 400000 S 1,005,448.26 1,665,803.5 660,355.32 Amount Amount

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Wednesday, 4 September September Monday, 2 2013 2013 110 109 Amount(09/04/2013) Amount(09/05/2013 Friday, 30 August 2013 Monday, 2 September 2013 Net Payable Net Payable Date Monday, 2 September 2013 Friday, 30 August 2013 Friday, 30 August 2013 Friday, 30 August 2013 56922 56886 49847 49822 56885 49821 Ref no. Transaction SELL SELL SELL BUY BUY BUY Particular LC shares 4703000 1000000 1000000 1786000 500000 777000 SMPH shares SUN shares shares shares shares SUN SUN SUN S 2,475,687.16 8,146,575.00 5,670,887.8 1,638,524.46 3,311,130.14 1,671,832.50 1,411,186.7 1,410,413.53 Amount 4

Monday, 9 (09/09/2013 Net Payable Amount(09/09/2013 Cr. As of Settlement Date Wednesday, 4 September Date 2013 Due Clearing [09/09/2013 49917 Ref nO Transaction BUY Particular 159,000 SMPH shares S 2,558,628.00 2,558,628.00 1,708,388.9 -850,239.07 Amount 3

Tuesday, 10 September 2013 111 Monday, 9 September 2013 Monday,9 September 2013 Monday, 9 Septermber 2013 Net Payable Amount(09/12/2013) Date 57107 57111 49997 Ref no Transaction SELL SELL BUY Particular 563000 500000 359000 shares shares SMPH shares SMPH SUN 8,196,862.50 1,579,056.9 5,774,588.60 843,216.92 Amount 8 September 2013 112

Monday, 16 September 2013 113 Amount(09/19/2013) Amount(09/13/2013) Net Payable Net Payable Date Monday, 16 September 2013 Date Tuesday, 10 September 2013 50236 50039 Ref Ref O. Do. Transaction Transaction BUY BUY Particular Particular 100000 100000 GSM shares shares GSMI S 2,110,536.21 2,110,536.2 2,162,493.25 2,162,493.2 Amount Amount 5

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October 2013 October 2013 October 2013 Thursday, 3 Tuesday, 1 Tuesday, 8 Monday, 23 Tuesday, 17 September September September Friday, 20 2013 2013 2013 119 117 116 115 18 114 Amount(10/08/2013) Amount(09/25/2013) Amount[09/26/2013 Amount(10/04/2013) Date Thursday, 3 October 2013 Amount(09/20/2013 Tuesday, 1 October 2013 Net Payable Tuesday, 8 October 2013 Friday, 20 September 2013 Monday, 23 September Monday, 23 September Net Payable Date Tuesday, 1 October 2013 Net Payable Date Tuesday, 17 Septemher Tuesday, 17 September Net Payable Net Payable Date 2013 Tuesday, 17 September Tuesday, 17 September Tuesday, 17 September 2013 Tuesday, 17 September 20 13 Tuesday, 17 September Friday, 20 September 2013 2013 Date Tuesday, 17 September 2013 Tuesday, 17 September 2013 2013 2013 2013 Date 2013 2013 50785 50905 57767 50502 57590 50692 57302 50483 57548 50315 50317 50318 50319 57303 57314 57315 50316 O Ref Ref O Ref Ref Ref mO Ref no no. O Transaction Transaction Transaction Transaction Transaction Transaction SELL BUY BUY SELL BUY SELL SELL SELL BUY SELL SELL BUY BUY BUY BUY BUY BUY Particular 100000 PX Particular MA shares Particular MA shares Particular 491900 PX TSI shares MA shares Particular 71500000 Particular TSI shares 26300000 TSI shares 2200000 50800 TSI 39600 TSI TSI shares 9750000 1000000 500000 100000 198000 100000 86900 111600 GSM1 shares 250000 8100 PX GSMI shares shares shares 'shares shares shares VITA shares LCB shares shares LCB S S 6 1,697,553.00 2,320,114.39 2,320,114.3 2,673,484.65 8,277,322.50 4,136,400.47 5,029,902.3 893,265.31 975,931.65 872,991.00 1,351,828.58 2,988,063.14 4,347,803.21 299,128.35 949,850.41 975,577.50 -676,449.15 605,139.65 476,339.30 -116,236.87 -56,585.10 Amount Amount -68,350.24 Amount Amount Amount Amount B

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Wednesday, 30 October 2013 October 2013 October 2013 October 2013 Monday, 21 October 2013 Thursday, 10 October 2013 Thursday, 17 Monday. 14 Friday, 18 125 124 123 120 121 122 Amount(10/24/2013) Amount(11/05/2013 Amount(10/23/2013) Monday, 21 October 2013 Monday, 21 October 2013 Net Payable Wednesday, 30 October Net Payable Amount(10/22/2013) Friday, 18 October 2013 Date Monday, 21 October 2013 Date 2013 2013 Amount(10/15/2013 Thursday, 17 October 2013 Net Payable Friday, 18 October 2013 Friday, 18 October 2013 Net Payable Wednesday, 30 October Thursday, 10 October 2013 Net Payable Amount(10/17/2013 Date Amount(10/11/2013) Thursday, 10 October 2013 Net Payable Date Monday, 14 October 2013 Date Net Payable Date Thursday, 10 0ctober 2013 51581 51585 51285 51315 51270 51284 51034 S8057 51125 51176 51271 51272 51033 TO Ref Do. Ref Ref Ref nO Ref no. no Ref no Transaction Transaction Transaction Transaction Transaction Transaction BUY BUY BUY BUY BUY BUY BUY BUY BUY SELL BUY BUY BUY Particular Particular Particular Particular Particular 1700000 Particular 20000000 BHI shares 1500000 1000000 300000 246000 354000 shares MARC shares TUGS shares TUGS shares shares 648400 MARC 50000 45000 shares 57000 shares 97000 PRIM shares shares PRIM PRIM BKD BKD shares shares GSM shares 51600 MCP MCP S S S S G 3,382,618.86 4,974,077.42 3,949,861.8 6,235,831.0 567,243.00 2,614,950.00 326,235.13 496,277.26 765,476.33 3,072,551.13 2,614,950.0 1,282,331.25 1,282,331.2 7,825,135.30 872,991.00 5,372,212.6 165,848.18 90,386.75 619,628.51 70,000.20 Amount Amount Amount Am ount Amount Amount 6 5 8

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November Monday, 4 2013 126 Date Ref no. Transaction Particular Amount

2

Friday, 8 Net Payable Monday, 4 November 2013 Amount(11/07/2013) 51756 BUY 798000 shares MARC 2,773,838.39 2,773,838.3 9

Wednesday, 13 Tuesday, 3 December November Tuesday, 12 November 2013 November 2013 2013 20 13 130 129 128 12 Amount(11/18/2013) Date Net Payable Wednesday, 13 Noyember Wednesday, 13 November Wednesday, 13 November 2013 Amount(11/15/2013 2013 Wednesday, 13 November 2013 Wednesday, 13 November 2013 2013 Net Payable Date Amount(11/13/2013 Tuesday, 12 November 2013 Friday,8 November 2013 Tuesday, 12 November 2013 Tuesday, 12 November Tuesday, 12 November Friday, 8 November 2013 Net Payable Date 2013 2013 Friday, 8 November 2013 Friday, 8 November 2013 Date 52078 52079 52080 52076 52077 Ref 52020 No. 52021 52019 52018 Ref 51878 58926 no 51870 S1871 Ref no. Ref nO Transaction Transaction Transaction Transaction BUY BUY BUY BUY BUY BUY BUY SELL BUY BUY BUY BUY BUY Particular Particular Particular 265000 shares shares 138000 23000 LMG Particular shares shares LMG shares 96000 185000 78000 MG LMG 110000 LMG shares shares 1988000 shares 40000 shares PRIM 512000 700000 70000 65000 PRIM PRIM shares PRIM S sh ares TUGS shares shares LTG BKD BKD S S 1,289,371.50 2,859,910.5 109,948.59 461,699.61 358,650.47 640,240.35 814,637.41 Amount 381,430.69 225,489.15 4,997,159,40 15,930,187 10,912,387.5 1,177,207.49 127,659.86 Amount 1,197,848.25 80,057.71 Amount Amount 67 N

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Thursday, 26 Tuesday, 17 Monday, 16 December December December 2013 2013 2013 13 132 131 Amount(12/20/2013) 12/19/2013 Cr. As of Settlement Date (12/19/2013 2013 Net Payable Amount(12/06/2013 Due Clearing Amount(12/19/2013) Tuesday, 17 December Tuesday, 3 December 2013 Monday,16 December 2013 Monday, 16 December 2013 Net Payable Date Tuesday, 3 December 2013 Net Payable Date 52793 52500 49366 52728 27311 Ref nO Ref nO. Transaction Transaction BUY C BUY BUY CM Particular Particular BHI shares 5500000 Dividend 500000 Payment Balance 600000 SMPH of Net shares shares Credit SMPH Cash S 7,533,067.51 9,777,607.27 7,533,067.5 807,770.25 9,351,873.84 9,184,919.3 -592,687.93 425,733.43 851,870.25 -44,100.00 Amount Amount A

Thursday, 26 December Thursday, 26 December Amount(01/03/2014) Thursday, 26 December 2013 Net Payable Date 2013 2013 60013 52985 52984 Ref DO Transaction SELL BUY BUY BHI shares Particular 5460000 283000 717000 VMC shares VMC shares 1,478,301.64 1,293,952.2 -762,454.53 578,105.11 Amount 2

January 2014 January 2014 Monday, 20 Monday, 6 2014 135 134 Amount(01/09/2014) Monday, 6 (anuary 2014 Date Monday, 6 January 2014 Net Payable 53138 53137 Ref nO Transaction BUY BUY Particular 55000 shares 45000 shares PRMX PRMX 439,703.86 240,786.62 198,917.24 Amount

Amount{01/23/2014 Date Monday, 20 January 2014 Monday, 20 January 2014 Net Payable 53578 53577 Ref no. Transaction BUY BUY Particular shares shares 28000 PRIM 91000 PRIM 237,457.59 182,392.77 55,064.82 Amount

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January 2014 Tuesday, 21 136

Wednesday, 22 Amount(01/24/2014 Tuesday, 21 January 2014 Net Payable Tuesday, 21 January 2014 Tuesday, 21January 2014 Tuesday, 21 January 2014 Tuesday, 21 January 2014 Date Tuesday, 21 January 2014 53631 53632 53633 53613 53630 53608 Ref nO Transaction BUY BUY BUY BUY BUY BUY Particular 200000 NI 15000000 sh ares 4000 PRMX shares shares 13000 PRMX shares 25000 PRMX shares shares PRMX 15000 0 MA 3,700,315.1 2,866,387.50 485,465.47 165,445.87 45,490.08 51,283.19 86,243.06 Amount T January 2014 137

Wednesday, 29 Amount(01/27/2014 Net Payable Wednesday, 22 January Date 2014 53686 Ref no. Transaction BUY Particular 10000000 shares O MA S 1,910,925.00 1,910,925.0 Amount 2

Wednesday, 12 February 2014 January 2014 139 138 Amount(02/04/2014) Net Payable 2014 Wednesday, 29 January Date 53859 nO Ref Transaction BUY Particular 15000000 0 MA shares S 3,017,250.00 3,017,250.0 Amount 0

February 2014 Monday, 17 140 Amount(02/17/2014) Due Clearing (02/17/2014 Cr. As of Settlement Date (02/17/2014 Net Payable Wednesday, 12 February Wednesday, 12 February 2014 Date 2014 61036 54183 Ref nO Transaction SELL BUY Particular AR shares 15000000 1000000 shares 0 MA 3,012,089.30 2,029,557.3 3,017,250.00 -982,531.95 -5160.70 Amount

February 2014 Thursday, 20 141 Amount(02/20/2014 Monday, 17 February 2014 Net Payable Date 542 28 Ref no. Transaction BUY Particular 15000000 shares 0MA G 2,866,387.5 2,866,387.50 Amount 0

2014 Thursday, 20 February Thursday, 20 February Date Thursday, 20 February 2014 2014 54344 54358 54343 nO Ref Transaction BUY BUY BUY 178000 NI Particular 122000 NI 500000 shares shares shares VC 2,011,007.19 519,168.14 354,124.58 Amount

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Friday, 7 March February 2014 February 2014 Wednesday, 26 February 2014 Monday, 10 March 2014 March 2014 March 2014 Friday, 14 Monday, 3 Friday, 28 Friday, 21 2014 148 14 146 14 144 142 143 Amount(03/12/2014) Amount(03/i3/2014 Date Amount(03/03/2014 Amount(03/06/2014) Amount(03/05/2014 Friday, 7 March 2014 Monday,10 March 2014 Net Payable Friday, 28 February 2014 Friday, 28 February 2014 Monday; 3 March 2014 Monday, 3 March 2014 Net Payable Date Friday, 7 March 2014 Net Payable Date Amount(02/26/2014 Friday, 21 Fehruary 2014 Net Payable Amount(02/27/2014) Wednesday, 26 February Date Net Payable Wednesday, 26 February 2014 Wednesday, 26 February Net Payable Date Net Payable Date Wednesday, 26 February 2014 2014 Date 2014 5489 548 73 61748 5457 54658 54533 54534 61461 54613 54614 54657 54423 Ref Ref DO DO Ref no Ref no. Ref Ref O Ref no. O Transaction Transaction Transaction Transaction Transaction Transaction Transaction SELL BUY BUY SELL BUY BUY BUY BUY BUY BUY BUY BUY Particular BHI shares Particular Particular 10000 SCC Particular Particular 15000000 15000000 Particular UNI shares Particular 1310000 300000 326000 500000 174000 0 MA 690000 420000 shares shares 500000 80000 sh ares VMC shares shares PHES PHES. shares VMC VMC shares shares shares shares LRW LRW VMC S S G G 2,358,483.7 2,358,483.76 4,023,000.00 2,522,587.50 1,933,976.7 1,500,412.5 225,237.71 1,262,316.82 1,959,522.84 1,247,783.74 671,659.95 2,884,299.9 1,959,522.8 1,980,478.50 684,412.88 24,132.12 189,835.31 35,402.40 Amount 72,414.00 Amount Amount Amount Amount Amount Amount 0

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Tuesday, 1 March 2014 April 2014 Friday, 21 150 149 Amount(03/26/2014 Cr. As of Settlement Date Net Payable Friday, 21 March 2014 Friday, 21 March 2014 Due Clearing Amount(03/19/2014) (03/26/2014 (03/26/2014 Friday, 14 March 2014 Net Payable Date 55215 49987 54997 Ref O Transaction BUY C BUY Particular Payment Balance 500000 226000 MARC shares of Net Credit shares GERI 2,436,643.75 2,036,643.75 2,145,722.9 475,055.95 -290,920.81 400,000.00 475,055.95 Amount

Wednesday, 2 Thursday, 3 April 2014 April 2014 152 151 Amount(04/04/2014) Amount(04/07/2014) Date Wednesday, 2 April 2014 Net Payable Tuesday, 1 April 2014 Date Net Payable Tuesday, 1 April 2014 Date 55508 55397 62239 Ref Ref DO I0. Ref O Transaction Transaction Transaction SELL BUY BUY Particular Particular Particular 10000 1190000 shares 137000 LRW shares LRW VMC Shares C G 1,059,054.75 1,039,746.5 1,059,054.7 1,615,737.38 -575,990.81 Amount Amount Amount C

Friday, 4 April Tuesday, 8 April 2014 2014 15 4 153 Amount(04/14/2014) Tuesday, 8 April 2014 Net Payable Tuesday, 8 April 2014 Amount(04/10/2014) Amount(04/08/2014) Date Thursday, 3 April 2014 Net Payable Tuesday, 8 April 2014 Net Payable Date Fridav, 4 April 2014 Thursday, 3 April 2014 55 680 55712 62626 55564 55608 55558 Ref nO. Ref O Transaction Transaction SELL BUY BUY BUY BUY BUY SLI shares Particular DD shares DD shares Particular 2000000 1001000 SLI shares 99900 2000000 500000 shares 500000 LRW shares VMC S 3,928,550.02 4,126,511.80 1,478,780.36 6,576,281.4 1,462,400.73 2,360,374.56 3,822,775.2 658,766.25 658,766.25 Amount Amount 6 O

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Monday, 5 May Wednesday, 30 Monday, 21 April 2014 Monday, 14 Tuesday, 15 April 2014 April 2014 April 2014 158 155 157 156 Amount(04/24/2014) Net Payable Amount(05/06/2014) Wednesday, 30 April 2014 Net Payable Monday, 21 April 2014 Date Amount(04/21/2014) Net Payable Monday, 21 April 2014 Net Payable Date Tuesday, 15 April 2014 Amount(04/22/2014) Date Date Monday, 14 April 2014 Tuesday, 15 April 2014 Monday,14 April 2014 56012 56013 56334 56024 55851 55852 55995 Ref Ref n Ref nO. o Ref A Transaction Transaction Transaction Transaction BUY BUY BUY BUY BUY BUY BUY MB shares Particular MB shares SGI shares MB shares Particular MB shares Particular Particular 17000 SGI 483000 118000 600000 382000 516000 400000 MARC shares shares S 2,262,696.13 2,262,696.1 750,410.19 1,031,899.51 1,804,315.5 852,705.02 576,174.07 823,809.83 174,236.12 772,416.00 28,895.19 Amount Amount Amount Amount 1 1

2014 159

Tuesday, 6 May Wednesday, 7 Tuesday, 13 May 2014 2014 161 160 Amount(05/09/2014) Amount(05/12/2014) Wednesday, 7 May 2014 Wednesday, 7 May 2014 Net Payable Net Payable Date Amount(05/08/2014) Tuesday, 6 May 2014 Tuesday,6 May 2014 Date Net Payable Date Monday, 5 May 2014 56516 63771 63525 5 6413 56443 Ref nO Ref O Ref NO. Transaction Transaction Transaction SELL SELL BUY BUY BUY Particular Particular 200000 NI Particular TA shares 2000000 250000 500000 250000 CNPF shares shares shares shares CNPF CNPF S S 6 4,847,151.77 3,635,576.84 1,211,574.9 3,759,150.00 4,035,412.5 7,794,562.50 629,599.50 629,599.50 Amount Amount Amount 3 D

May 2014 162

Date Do Ref Transaction Particular S Amount

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Wednesday, 21 Thursday, 29 Thursday, 22 Thursday, 15 May 2014 May 2014 May 2014 May 2014 16 165 164 163 Thursday, 29 May 2014 Wednesday, 21 May 2014 Amount(05/26/2014 Net Payable Amount 05/27/2014) Thursday, 29 May 2014 Wednesday, 21 May.2014 Thursday, 22 May 2014 Date Amount(05/20/2014) Wednesday, 21 May 2014 Net Payable Date Net Payable Net Payable Amount(05/16/2014) Tuesday, 13 May 2014 Thursday, 15 May 2014 Thursday, 15 May 2014 Date Tuesday, 13 May 2014 Tuesday, 13 May 2014 Tuesday, 13 May 2014 Tuesday, 13 May 2014 Date Tuesday,13 May 2014 Tuesday, 13 May 2014 Tuesday, 13 May 2014 Tuesday,13 May 2014 57579 575 87 57305 57238 57265 64241 63854 56941 56942 56842 63828 63851 Ref 56839 56840 56841 56843 56847 Ref no. DO Ref Ref nO O Transaction Transaction Transaction Transaction BUY BUY SELL BUY BUY SELL BUY BUY SELL SELL BUY BUY BUY BUY BUY BUY BUY Particular Particular Particular Particular 1000000 5000000 500000 5354000 2646000 500000 HOUSE CEI shares shares shares LRW shares 2500000 shares shares 5000000 CYBR shares 2000000 195000 151000 PHA 205000 shares 223000 682000 CYBR GTCAP shares MARC shares PHA PHA shares shares shares B KR BKR BRD shares shares 6600 shares 2 00 CPM 5000 B KD B KD shares BKD S S 4,123,575.00 2,881,795.58 3,594,370.64 804,317.20 482,760.00 593,392.50 1,516,892.26 482,760.00 1,981,327.50 4,805,775.23 4,377,431.24 1,011,953.28 3,560,419.9 549,048.99 432,824.52 981,873.51 2,051,227.12 Amount -227,527,50 210,905.78 Amount 657,358.20 Amount 99,901.14 Amount 0

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Monday, 2 June Friday, 30 May 2014 2014 168 167 Amount(06/04/2014) Net Payable Friday, 30 May 2014 Friday, 30 May 2014 Net Payable Amount(06/03/2014) Date Friday, 30 May 2014 Thursday,29 May 2014 Thursday, 29 May 2014 64634 64561 57617 57618 64546 nO Ref Transaction SELL BUY BUY SELL SELL Particular DD shares DD shares DD shares DD shares 105300 394 700 361400 500000 250000 shares BKR 3,731,513.54 3,432,143.52 4,550,550.00 634,392.10 156,155.85 -650,431.88 975,192.31 Amount

Friday, 6 June Thursday, 5 June 2014 2014 170 169 Amount(06/10/2014 Thursday, 5 June 2014 Due Clearing (06/10/2014 Cr. As of Settlement Date (06/10/2014) Net Payable Thursday, 5 June 2014 Thursday, 5 June 2014 Amount(06/05/2014 Date Date Monday, 2 June 2014 Net Payable Monday, 2 June 2014 5786 57985 57664 64687 57961 Ref no nO Ref Transaction Transaction BUY BUY SEDL BUY BUY Particular Particular DD shares 1000000 1465000 400000 535000 200000 HOUSE shares shares shares PHA shares SUN SUN 3,113,986.8 2,333,863.00 3,713,500.56 4,012,318.94 1,561,036.50 2,451,282.4 -599,513.73 897,782.73 481,854.83 Amount Amount 3

Tuesday, 10 June 2014 171 Tuesday, 10 June 2014 Tuesday, 10 June 2014 Amount(06/11/2014) Tuesday, 10 June 2014 Net Payable Date Date Friday, 6 June 2014 Friday,6 June 2014 58239 65174 58225 58064 58065 Ref IO. No. Ref Transaction Transaction SELL BUY BUY BUY BUY Particular Particular 2000000 2000000 4130000 2000000 870000 shares VITA SINO shares SINO shares shares shares SINO SINO S S 1,857,740.94 2,403,877.50 2,655,180.00 1,431,976.80 6,415,156.27 7,847,133.0 Amount Amount T

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Tuesday, 17 June 2014 12 Tuesday, 17 June 2014 Amount(06/20/2014) Net Payable Amount(06/16/2014) Date Tuesday, 17 June 2014 Tuesday, 17 June 2014 Tuesday, 17 June 2014 Net Payable Tuesday, 10 June 2014 58467 58464 58465 58466 65189 Ref IO Transaction SELL BUY BUY BUY BUY Particular IMI shares 88000 IMI 15500 IMI IMI shares 2000000 103400 shares 198900 shares VITA shares 1,091,133.16 2,266,025.1 1,685,108.23 423,935.21 585,849.36 504,413.79 84,628.85 Amount

G

Wednesday, 25 Thursday, 26 Thursday, 3 Tuesday, 24 June 2014 July 2014 June 2014 June 2014 176 175 173 174 Amount(07/01/2014) Thursday, 3 July 2014 Thursday, 3 July 2014 Net Payable Amount(07/08/2014) Thursday; 3 July 2014 Thursday,3 July 2014 Amount(06/30/2014) Thursday, 26 June 2014 Thursday, 3 July 2014 Due Clearing Amount(06/27/2014) Wednesday, 25 June 2014 Net Payable Date Net Payable Date Thursday,3July 2014 Tuesday, 24 June 2014 (06/27/2014) Cr. As of Settlement Date (06/27/2014 Net Payable Date Date Tuesday, 24 June 2014 59146 59147 66069 59134 59145 66038 58907 58776 58804 58824 Ref n Ref nO. Ref Ref nO. O Transaction Transaction Transaction Transaction SELL SELL BUY BUY BUY BUY BUY BUY BUY BUY Particular Particular Particular Particular 3000000 IMI shares 1100000 2000000 80000 129000 233000 138000 200000 DAVIN shares 300000 shares 74000 COAL SINO BRN shares shares BRN shares shares shares shares shares BRN APX APX NOW S 3,798,263.6 1,766,469.13 4,125,586.50 1,810,153.88 3,419,353.88 2,975,433.5 4,525,875.00 4,525,875.0 214,777.92 1,609,200.00 1,766,469.1 396,305.73 238,543.78 -920,002.50 -256,947.80 -443,920.29 Amount Amount Amount Amount R

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Wednesday, 23 Monday, 7 July Tuesday, 8 July Wednesday, 9 Tuesday, 15 Monday, 21 July 2014 July 2014 July 2014 July 2014 2014 2014 182 180 181 177 179 178 Amount(07/18/2014) Amount(07/11/2014) Net Payable Amount(07/24/2014) Date Amount(07/14/2014 Net Payable Monday, 21 July 2014 Date 07/10/2014 Amount(07/10/2014) Net Payable Date Monday,7 July 2014 Monday,7 July 2014 Due Clearing Net Payable Wednesday, 9 July 2014 Wednesday, 9 July 2014 Date Tuesday,15 July 2014 Monday, 21 July 2014 Monday, 21 July 2014 Monday 7July 2014 Cr. As of Setttement Date 07/10/2014 Net Payable Tuesday, 8 July 2014 Date Wednesday,9 July 2014 Wednesday, 9 July 2014 Wednesday, 9 July 2014 Date Wednesdav, 9 July 2014 59536 59541 59327 66247 66259 66282 59489 59535 59207 59208 59209 59264 59326 59365 Ref Ref Ref Ref O Ref no. no. no. Ref O no. Transaction Transaction Transaction Transaction Transaction Transaction SELL SELL SELL BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY Particular Particular Particular 330000 PX Particular Particular Particular ION shares ION shares OM shares ION shares 1000000 3313000 1824000 2000000 2000000 2000000 861000 100000 A shares 51000 501000 1900 31000 48000 shares VITA PHA shares shares VITA shares shares shares shares ATN shares ATN APX ATN ATN S S S 1,647,378.24 4,055,787.45 2,954,410.74 2,505,715.50 2,092,797.96 4,281,457.6 1,189,158.57 2,327,275.9 979,349.06 1,411,912.09 951,225.76 704,025.00 979,349.06 140,251.84 110,350.90 112,402.62 -460,686.33 805,334.20 -198,008.27 85,418.33 704,025.00 Amount Amount Amount Amount Amount Amount Z

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Tuesday, 5 Monday, 28 July 2014 183 Amount(07/31/2014) Net Payable Monday,28 July 2014 Amount(07/28/2014) Date Monday, 28 July 2014 Wednesday, 23 July 2014 Wednesday, 23 July 2014 Net Payable Wednesday, 23 July 2014 Wednesday, 23 july 2014 Wednesday, 23 July 2014 5 9679 66577 59605 66534 5963 59604 29952 Ref TO Transaction SELL BUY SELL BUY BUY BUY CM Particular 20000 SCC 3000000 100000 Dividend shares shares shares 201100 shares ATN shares 31300 shares 17600 PHA PXP PXP Cash PXP S 7,040,250.00 6,773,152.5 1,399,788.74 639,154.93 -267,097.50 1,638,132.42 144,624.85 256,359.65 Amount -173.25 0

Wednesday, 6 August 2014 August 2014 185 184 Clearing(08/08/2014) Cr. As of Settlement Date (08/08/2014) Amount(08/08/2014) Net Payable Tuesday, 5 August 2014 Tuesday, 5 August 2014 Date Due 59860 5 9858 Ref Do Transaction BUY BUY Particular 5000000 shares 7000 shares ATN APC S 4,927,672.13 4,191,661.7 4,727,025.00 -736,010.34 200,647.13 Amount 9

Date Ref O Transaction Particular Amount

Monday, 11 August 2014 186 Amount(08/11/2014) Wednesday, 6 August 2014 Net Payable Wednesday, 6 August 2014 5914 5 904 BUY BUY 600000 103100 shares PERC shares SUN 1.553,561.9 740,463.33 813,098.59 2

Tuesday, 12 August 2014 18 Amount(08/14/2014) Net Payable Monday, 11 August 2014 (08/14/2014) Cr. As of Settlement Date (08/14/2014) Mondav, 11 August 2014 Date Due Clearing 60025 60024 Ref no. Transaction BUY BUY Particular 531000 969000 COAL shares COAL shares S 1,289,019.50 1,966,361.96 1,114,466.1 -851,895.78 677,342.46 Amount 8

Date Ref no. Transaction Particular S Amount

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Wednesday, 20 August 2014 Tuesday, 26 Wednesday, 13 August 2014 Tuesday, 2 September Tuesday, 19 August 2014 August 2014 2014 192 1 1 190 189 188 Amount(09/05/2014) Amounit[08/29/2014 (09/05/2014 Cr. As of Settlement Date 09/05/2014 Net Payable Date Tuesday, 2 September 2014 Tuesday, 2 September 2014 Tuesday, 2 September 2014 Due Clearing Tuesday, 26 August 2014 Net Payable Net Payable Amount(08/27/2014) Amount(08/26/2014) Wednesday, 20 August 2014 2014 Wednesday, 20 August Wednesday, 20 August Wednesday. 20 August Date Tuesday, 19 August 2014 Net Payable 2014 2014 Amount(08/15/2014 Wednesday, 13 August Amount(08/18/2014) Tuesday, 19 August 2014 Date Wednesday, 20 August Tuesday, 12 August 2014 Date 2014 Wednesday, 13 August 2014 Net Payable Date 2014 Net Payable Wednesday, 13 August Tuesday, 12 August 2014 2014 60714 60689 606 0 60434 60386 60385 67348 603 05 60353 60384 Ref O 60306 60164 67118 60138 60074 60112 Ref n Ref no. Ref no Ref O Transaction Transaction Transaction Transaction Transaction BUY BUY BUY BUY SELL BUY BUY SELL BUY BUY BUY BUY BUY BUY BUY BUY Particular 10510000 18000000 CEl shares 9490000 CEI shares CEI shares Particular IS shares CEI shares Particular 13290000 CEI shares 5000000 CEI shares Particular Particular 20000000 CEI shares 1000000 CEI shares 2000000 2960000 3750000 569000 9470000 1000000 1000000 182000 249000 COAL shares VUL shares shares shares VUL shares shares VUL shares VUL VUL VUL S 7,371,115.1 1,547,296.10 1,733,550.92 4,495,199.62 7,776,046.64 -404,931.49 1,184,963.22 2,657,062.1 704,025.00 1,054,901.00 704,025.00 1,967,860.52 5,630,958.5 3,356,238.04 966,465.39 343,745.23 475,518.60 1,536,454.11 1,910,925.00 4,204,035.00 1,929,314.49 546,8 76.56 3,447,379.1 419,588.83 Amount Amount Amount Amount Amount 3 5

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Wednesday, 3 Thursday, 11 September 2014 1 3 Wednesday, 3 September Wednesday, 3 September Net Payable Amount(09/08/2014) 2014 2014 Date 67804 60808 Ref no. Transaction SELL BUY Particular 20000000 3000000 IS shares shares MRC S 3,459,780.00 2,815,778.2 -644,001.75 Amount 5

Friday, 12 September 2014 194 Amount(09/16/2014 2014 Net Payable Date Thursday, 11 September Thursday, 11 September Thursday, 11 September 2014 2014 68142 61138 61128 Ref no Transaction SELL BUY BUY Particular 1000000 1000000 100000 shares shares shares MED MED CMT S 3,692,422.5 2,987,077.50 784,485.00 -79,140.00 Amount C September 2014 195

Tuesday, 16 September 2014 196 Friday, 12 September 2014 Amount(09/17/2014 Friday,12 September 2014 Friday, 12 September 2014 Friday, 12 September 2014 Friday, 12 September 2014 Net Payable Friday,12 September 2014 Friday, 12 September 2014 Friday, 12 September 2014 Friday, 12 September 2014 Date 68199 61214 61230 61296 61213 61210 61211 61212 61185 Ref nO Transaction SELL BUY BUY BUY BUY BUY BUY BUY BUY Particular 2000000 EG shares 2700000 100000 535000 shares sh ares 300000 264000 shares LRW 218000 483000 shares shares PHES MED sh ares shares shares MAC MAC 39000 MAC MAC MAC 4,215,705.4 -561,003.67 833,766.76 1,387,130.41 908,423.58 823,105.80 602,927.01 74,425.50 108,912.66 38,017.35 Amount 0

Tuesday, 16 September Tuesday, 16 September 2014 Tuesday, 16 September Date Tuesday, 16 September 2014 2014 2014 61357 61358 61318 61317 Ref nO Transaction BUY BUY BUY BUY Particular 11150000 CEI shares CEI shares 3850000 174000 26000 TAPET shares TAPET shares S 1,030,270.18 1,937,406.40 677,624,07 152,572.28 Amount

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Wednesday, 24 Thursday, 18 Tuesday, 23 September September September 2014 2014 2014 1 9 197 198 Amount(09/26/2014 Tuesday, 23 September Amount(09/19/2014 Net Payable Amount(09/23/2014) Date 2014 Date 2014 Thursday, 18 September 2014 Thursday, 18 September 2014 Net Pavable Tuesday, 16 September Net Payable Thursday, 18 September 2014 Tuesday, 16 September Tuesday, 16 September 2014 Tuesday, 16 September 2014 Tuesday, 16 September 2014 2014 61540 6819 61453 68301 68307 68308 68309 61434 68300 Ref Ref DO o. Transaction Transaction SELL SELL SELL BUY SELL SELL BUY BUY SELL Particular Particular 10000000 CEl shares 2000000 2000000 10050000 3290000 IS shares IS shares 1450000 266000 594000 shares shares CPM PHES PHES shares 40000 shares shares LRW shares LRW LRW S C 1,887,651.96 1,887,651.9 2,102,017.51 1,176,613.96 1,698,020.7 225,424.12 1,992,606.68 772,617.15 -372,017.35 -856,245.34 -291,433.04 -60,146.40 Amount Amount 6 0

Thursday, 25 September 2014 200 Thursday, 25 September Thursday, 25 September Thursday, 25 September Thursday, 25 September Thursday, 25 September 2014 Amount(09/29/2014) 2014 2014 Thursday, 25 September 2014 2014 Wednesday, 24 September Wednesday, 24 September Wednesday, 24 September Net Payable 2014 Date 2014 Wednesday, 24 September 2014 2014 Date 2014 61702 61704 61701 61703 68610 61679 68594 61641 68591 61639 Ref no. Ref MO. Transaction Transaction SELL BUY SELL BUY BUY BUY SELL BUY BUY BUY CEI shares IMI shares IMl shares Particular 44100 IMI 10000000 CEI shares 19000 IMI Particular CEI shares 2000000 1680000 1680000 shares 254000 182900 shares 300000 300000 shares MED shares RWM shares RWM S 2,222,858.36 1,618,759.66 1,856,129.76 1,601,968.66 165,234.65 2,926,646.01 2,816,394.75 377,528.37 -322,416.36 120,697.93 332,863.03 Amount Amount

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October 2014 Wednesday, 8 October 2014 Thursday, 9 Thursday, 2 201 202 Amount(09/30/2014) Net Payable Amount(10/07/2014) Wednesday, 8 October Date Wednesday, 8 October Net Payable Amount(10/13/2014 Date Thursday, 2 0ctober 2014 2014 Net Payable 2014 Thursday, 25 September 2014 Thursday, 25 September 2014 62120 62071 61904 68663 68613 Ref Ref no O Transaction Transaction BUY SELL BUY BUY SELL Particular Particular 2000000 400,000,0 5000000 IS shares 2000000 273000 shares 00 AR shares LRW shares shares CPM MED S G 1,408,050.00 2,129,856.6 3,293,026.6 3,293,026.65 1,951,790.23 1,426,547.96 751,881.75 721,806.67 Amount Amount T 5

October 2014 October 2014 Tuesday, 14 204 203 Date Thursday, 9 October 2014 Thursday, 9 October 2014 Net Payable Amount(10/14/2014 69022 62122 Ref no Transaction SELL BUY Particular 150000 50000 ATNB shares LRW shares 318,562.21 -129,097.12 447,659.33 Amount

Thursday, 16 October 2014 205 Net Payable Amount(10/17/2014 Tuesday, 14 October 2014 Date Tuesday, 14 October 2014 Tuesday, 14 October 2014 69121 62238 62228 Ref DO. Transaction SELL BUY BUY Particular AR shares 30000000 2000000 100000 shares shares LRW O AR S 2,202,592.50 2,419,104.2 231,322.50 -14,810.75 Amount 5

October 2014 Friday, 17 206 Friday, 17 October 2014 Friday,17 October 2014 Amount(10/21/2014) Friday, 17 October 2014 Thursday, 16 October 2014 Date Thursday, 16 October 2014 Net Payable Date Thursday, 16 0ctober 2014 62339 62340 6206 62309 62310 691 0 Ref Ref nO O Transaction Transaction SELL SELL BUY BY BUY BUY FPI shares Particular CEl shares 1505000 Particular 70000 FPI FPI shares CEI shares FPI shares 2945000 1920000 1000000 760000 shares S 625,354.39 133,864.99 490,806.01 327,431.98 412,357.50 -304,491.15 25,998.64 Amount Amount

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October 2014 Monday, 20 207 Amount(10/22/2014 Net Payable 192,883.60

October 2014 October 2014 Thursday, 23 Monday, 27 October 2014 Tuesday, 21 210 209 208 Amount(10/28/2014) Thursday, 23 October 2014 Tuesday, 21 October 2014 Thursday, 23 October 2014 Net Payable Net Payable Amount(10/24/2014) Thursday, 23 October 2014 Thursday, 23 October 2014 Tuesday, 21 October 2014 Date Tuesday, 21 October 2014 Monday, 20 October 2014 Tuesday, 21 October 2014 Tuesday, 21 October 2014 Tuesday, 21 0ctober 2014 Tuesday, 21 October 2014 Monday, 20 October 2014 Monday, 20 October 2014 Net Payable Amount(10/23/2014 Date Tuesday, 21 October 2014 Monday, 20 October 2014 Tuesday, 21 October 2014 Date Monday, 20 October 2014 69420 69433 62543 69392 69331 62450 69275 69317 69329 62440 69245 62430 6234 62435 Ref 62367 62390 69266 62366 no. Ref nO HO Ref Transaction Transaction Transaction SELL SELL SELL SELL SELL SELL BUY SELL SELL BUY BUY SELL BUY BUY BUY BUY BUY BUY Particular CEI shares UNI shares CEI shares CEI shares 2500000 CEl shares Particular FPI shares 25600000 3575000 5000000 Particular 7500000 1130000 FPI shares IS shares 1000000 6170000 200000 100000 400000 IS 100000 IS 500000 IS 2370000 7500000 5000000 MRC shares 1270000 shares shares shares WIN shares shares shares 100000 0 AR WIN WN shares shares shares WIN WIN 2,239,414.69 3,190,627.4 231,269.49 1,722,086.40 -405,602.39 1,048,796.10 3,216,639.95 1,858,374.57 741,237.75 -33,139.87 1,312,503.75 -71,226.00 -170,151.00 -600,038.44 -207,742.50 284,631.83 486,003.56 149,605.31 330,238.02 Amount -27,699.00 40,230.00 Amount Amount 0

Net Payable Monday, 27 October 2014 Monday, 27 October 2014 Monday, 27 October 2014 Amount(10/30/2014) Date 62623 62638 69525 Ref DO Transaction SELL BUY BUY 300000 IS 300000 IS Particular 10000000 shares shares shares 0 AR S 895,878.00 905,175.00 156,897.00 166,194.00 Amount

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Wednesday, 5 Thursday, 6 November October 2014 November October 2014 Thursday, 30 Friday, 31 2014 2014 214 213 212 211 Cr. As of Settlement Date (11/10/2014) Net Payable Amount(11/10/2014 (11/10/2014 Friday, 31 October 2014 Net Payable Wednesday. 5 November : 2014 Wednesday, 5 November Due Clearing Amount(11/05/2014 Wednesday, 5 November Wednesday, 5 November 2014 Friday,31 October 2014 Wednesday, 5 November 2014 2014 Friday, 31 October 2014 Friday, 31 0ctober 2014 2014 Friday, 31 October 2014 Friday, 31 October 2014 Date Net Payable Amount(11/04/2014) Friday, 31 October 2014 Thursday, 30 October 2014 Thursday, 30 October 2014 Date Thursday, 30 October 2014 Thursday, 30 October 2014 Date Thursday, 30 October 2014 Thursday, 30 October 2014 Thursday, 30 October 2014 Thursday, 30 October 2014 Thursday, 30 0ctober 2014 63 086 69956 63068 63082 63084 69753 69773 69794 6803 62892 62900 62891 69736 69740 Ref 62822 62823 62829 69716 6 730 no 62809 62821 Ref DO Ref nO Transaction Transaction Transaction SELL SELL BUY BUY SELL SELL BUY BUY SELL BUY BUY BUY SELL SELL SELL SELL BUY BUY BUY BUY BUY 48300000 Particular BHI shares IS shares 29000000 41104000 IS shares SFI shares 43385000 1300000 FPI shares UNI shares Particular 20000000 60000 UNI SFI shares SFI shares 10000000 5000000 UNI shares 100000 IS 2960000 Particular FPI shares SFI shares SFI shares SFI shares 1050000 300000 4000 shares 5000000 0 AR 100000 4000 150000 150000 MRC shares MRC shares 600000 600000 shares shares O AR shares shares MRC shares MRC S S 1,009,382.77 2,597,047.65 28,402,702.9 10,801,844.3 9,792,461.6 1,483,875.00 31,696,824.7 4,265,989.20 2,924,389.5 5,833,350.00 644,685.75 1,257,187.50 1,467,023.2 -939,787.50 -483,149.70 -69,247.50 -264,871.69 -100,903.51 Amount 148,046.41 49,784.63 17.314.58 341,955.00 -66,279.75 95,797.69 90,517.50 -34,425.90 Amount Amount D 6 N 5

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Thursday, 6 November Thursday, 6 November Date 2014 2014 2014 Thursday, 6 November 63132 63149 63154 O Ref Transaction BUY BUY BUY Particular 18000000 BHI shares SFI shares 4800000 4700000 shares MRC 1,692,677.25 1,013,735.65 712,996.29 Amount

Monday, 17 November November Friday, 14 Tuesday, 11 November 2014 2014 2014 217 216 215 Due Clearing Friday, 14 November 2014 (11/19/2014 Cr. As of Settlement Date Amount(11/14/2014) Friday, 14 November 2014 Friday, 14 November 2014 (11/19/2014 Net Payable Amount(11/19/2014) Amount(11/11/2014) Net Payable Date Friday, 14 November 2014 Net Payable Tuesday, 11 November Tuesday, 11 Novemher Tuesday, 11 November Tuesday, 11 November Thursday, 6 November Tuesday, 11 November 2014 2014 Thursday, 6 November Tuesday, 11 November 2014 2014 Tuesday, 11 November 2014 Tuesday, 11 November 2014 2014 Thursday, 6 November Thursday, 6.November 2014 2014 2014 2014 Date 2014 2014 Thursday, 6 November 63419 51821 63420 63423 70166 63281 63282 63283 63284 63286 63162 69975 31354 63277 63161 70012 63160 nO Ref n. Ref Transaction Transaction BUY BY SELL BUY BUY CN SELL BUY BUY BUY BUY SELL BUY BUY BUY CM BUY PLC shares IRC shares 50000 IRC 1900000 UNI shares Particular SFI shares SFI shares UNI shares Particular FPI shares SFI shares 27000000 BHI shares 10180000 300000 20000000 BHI shares 3140000 1580000 Payment Balance 150000 Dividend 2900000 250000 Partial of Net Credit shares 195000 766000 30000 shares shares shares sh ares Cash LRW 80000 LRW LRW LW 4,848,512.70 4,107,563.46 1,316,116.52 3,532,396.1 1,370,837.25 2,161,759.05 1,683,189.09 2,243,619.00 4,767,288.7 254,957.61 4,314,265.20 1,096,317.79 400,000.00 85,991.63 5.345.714.0 688,285.02 349,598.70 162,931.50 -136,021.87 170,072.33 442,530.00 Amount Amount -173.25 8 3 9

Date Ref no Transaction Particular S Amount

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Monday. 17 November 2014 Monday, 17 November Monday, 17 November 2014 2014 63439 63455 63437 BUY BUY BUY IRC shares FPI shares SFI shares 4800000 5000000 100000 2,100,006.00 975,577.50 175,000.50

Tuesday, 18 November 2014 218 Amount(11/20/2014) Monday, 17 Novemher 2014 Net Payable Monday, 17 November Monday. 17 November 2014 Monday, 17 November 2014 Monday, 17 November 2014 2014 70326 63478 63479 63480 63477 SELL BUY BUY BUY BUY IRC shares 300000 281000 shares 52300 shares 84000 shares LRW shares 32700 LRW LRW LRW 5,707,729.8 1,865,263.94 342,084.76 215,386.40 556,240.11 -521,829.37 A

Tuesday, 18 November Tuesday, 18 November 2014 Date 2014 63517 63499 Ref o Transaction BUY BUY UNI shares Particular 5000000 FPI shares 1940000 2,187,506.25 857,200.73 Amount

Wednesday, 19 Amount(11/21/2014 Net Payable Tuesday, 18 November 2014 635 26 BUY 900000 shares SUN 1,261,994.98 4,306,701.9 6

Monday, 24 November 2014 219 Amount(11/24/2014) Net Payable Wednesiay, 19 November Wednesday, 19 November Wednesday, 19 November Wednesday, 19 November Date 2014 2014 2014 2014 70433 63569 63574 63565 Ref no Transaction SELL BUY BUY BUY PLC shares Particular SFI shares 2000000 iS shares 5900000 9000000 3400 shares SUN S 4,115,280.00 4,461,786.1 7,241,400.00 1,290,528.12 45,138.06 Amount B November 2014 220

Friday, 28 November 2014 221 Amount(11/27/2014) Net Payable Monday, 24 November Monday, 24 November Monday, 24 November 2014 Monday, 24 November Date 2014 2014 2014 63748 70597 70606 63745 Ref no Transaction SELL SELL BUY BUY Particular 963000 690000 979000 TUGS 63600 TUGS shares shares LRW shares shares 2GO 1,665,778.29 1,648,080.62 4,654,026.67 1,583,237.4 243,069.66 Amount

Date Ref DO Transaction Particular S Amount

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Wednesday, 3 December December Tuesday, 2 December Friday, 5 2014 2014 2014 224 222 223 Friday, 5 December 2014 Friday, 5 December 2014 Friday, 5 December 2014 Date Friday, 5 December 2014 Amount[12/05/2014] Wednesday, 3 Decemher Amount(12/08/2014 Friday, 5 December 2014 Friday, 5 December 2014 Date Wednesday, 3 December Wednesday, 3 December 2014 Net Payable Cr. As of Settlement Date Tuesday, 2 December 2014 Tuesday, 2 December 2014 Net Payable 2014 Due Clearing 12/03/2014 Amount(12/03/2014) Tuesday, 2 December 2014 Tuesday, 2 December 2014 Tuesdav, 2 December 2014 2014 Friday, 28 November 2014 (12/03/2014) Net Payable Tuesday, 2 December 2014 Friday, 28 November 2014 Friday, 28 Novemher 2014 Date 64146 64148 71001 6143 64144 64145 64085 70870 70872 64027 64028 64023 64024 64026 64029 Ref 51916 51943 63959 no. Ref nO Ref DD. Transaction Transaction Transaction SELL BUY SELL SELL BUY BUY BUY BUY BUY BUY C BUY BUY BUY BUY BUY BUY C Particular Particular 1190000 X 500000 X Particular 15920000 CEI shares CEI shares 20898000 IS shares 1073000 320000 190000 IS shares 2642000 3980000 145400 466000 131000 shares shares CMT shares Payment 151000 411000 shares shares shares shares CMT CMT CMT shares Payment Balance Balance shares LRW 56700 31700 LRW shares CMT of Net Credit Of Net Credit shares LRW shares LRW LRW S S 10,456,782.7 1,380,532.67 3,952,597.50 1,515,887.12 3,001,489.89 8,092,257.6 393,379.00 965,520.00 -526,281.00 2,519,735.65 13,298,469.0 14,098,469.0 1,856,904.40 2,364,819.99 6,917,701.4 12,241,564. 916,187.96 -848,637.99 600,432.75 326,413.15 190,111.91 400,000.00 Amount 400,000.00 Amount Amount 62 5

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Wednesday, 17 Wednesday, 10 Thursday, 11 December December December 2014 2014 2014 227 226 225 Amount(12/16/2014) Net Payable Amount(12/15/2014) Thursday, 11 December Thursday, 11 December 2014 Net Payable Thursday, 11 December Thursday, 11 December Thursday, 11 December 2014 Wednesday, 10 December Thursday, 11 December Thursday. 11 December Thursday, 11 December 2014 2014 2014 Thursday, 11 Decemher 2014 Wednesday, 10 December Wednesday, 10 December 2014 2014 2014 Friday, 5 December 2014 Net Payable Amount(12/10/2014) Wednesday, 10 December 2014 Wednesday, 10 December 2014 Date 2014 2014 Date Wednesday, 10 December 2014 2014 Friday,5 December 2014 71110 64236 71105 71106 71108 64225 64231 64232 71032 64230 64192 64193 64195 64196 71033 71004 71003 Ref DO Ret no. Transaction Transaction SELL SELL SELL SELL BUY SELL SELL BUY BUY BUY BUY SELL BUY SELL BUY BUY BUY 798000 IS 169900 X Particular 122100 X 7900000 IS shares 391000 X 396900 X 725100 X 2152000 Particular 2950000 IS shares IS shares shares 467300 X 838500 X 258900 X 522700 X shares shares shares 1338000 shares shares 462000 share 119200 shares shares 252300 shares shares shares shares LRW CMT LRW shares CMT 6,242,924.25 1,043,144.34 4,498,739.3 3,460,454.87 3,552,695.20 1,467,303.08 4,248,682.26 3,592,817.49 1,482,038.00 4,048,445.47 4,745,469.45 1,252,271.79 6,194,663.3 1,087,399.82 -378,922.33 6,640,323.80 1,395,367.48 2,058,907.21 468,007.05 650,233.47 Amount Amount 6

December Friday, 19 2014 228 Amount(12/22/2014) Wednesday, 17 December Net Payable Wednesday, 17 December Wednesday, 17 December 2014 Date Wednesday, 17 December 2014 Wednesday, 17 December 2014 2014 2014 643 75 71246 71247 643 74 71244 Ref O Transaction SELL SELL SELL BUY BUY Particular 5200 LRW 10000000 IS shares 495000 X 2990000 885700 Q UPM shares LRW shares shares shares 1,307,475.00 4,575,758.19 1,168,353.70 4,221,238.56 468,692.05 -24,948.88 Amount

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Monday, 29 Monday, 22 December December 2014 2014 230 229 Net Payable Amount 12/29/2014 Monday, 29 December 2014 Net Payable Amount(01/07/2015 Amount(12/29/2014 Date Monday, 22 December 2014 Date Monday,29 December 2014 Monday, 29 December 2014 Due Clearing Cr. As of Settlement Date Net Payable Monday, 22 December 2014 Monday, 22 December 2014 Friday, 19 December 2014 Friday, 19 December 2014 (12/29/2014) (12/29/2014) Date Friday, 19 December 2014 64504 64570 64571 71401 64465 64466 64506 71342 64454 Ref Ref Ref DO o no. Transaction Transaction Transaction SELL SELL BUY BUY BUY BUY BUY BUY BUY Particular Particular Particular 100000 X 173800 950000 600000 274600 553000 shares shares 56300 10000 CHIPS shares MAXS shares shares shares 47000 MAXS PSPC MAXS shares PSPC shares PSPC PSPC shares S S 1,391,057.87 6,904,473.75 2,634,401.22 4,149,548.49 2,904,606.00 1,762,843.50 5,291,310.9 8,107,574.1 1,412,814.04 1,582,557.69 1,221,587.1 -187,957.50 915,232.51 136,611.02 Amount Amount Amount 8 O

Wednesday, ? 2015 January 2015 231 (01/12/2015 Net Payable Amount Wednesday, 7 January 2015 Wednesday,7January 2015 Wednesday, 7 January 2015 Date Ref. NO. 64676 64685 71535 BUY SELL BUY Transaction Particular LC shares 77000 LRW shares 500000 IS shares 9900000 8 325,259.55 2,688,369.75 -230,000.62 2,783,628.6 Amount

Thursday, 8 January 2015 232 Thursday, 8 January 2015 Thursday,8 January 2015 Date Ref. NO. 64717 64720 Transaction BUY BUY Particular IS shares 418000 LRW shares 20140000 8,605,800.46 2,148,855.27 Amount

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(01/13/2015 Net Payable Amount Thursday,8January 2015 Thursday, 8 January 2015 Thursday, 8 January 2015 Thursday, 8 [anuary 2015 71565 71551 64721 71564 SELL SELL SELL BUY shares MAXS shares CHIPS 329400 MAXS 1500 372000 LRW shares 18900 shares 8,296,725.96 4,012,461.9 -351,692.21 -38,061.37 A 1,944,285.72

Wednesday, 14 January 2015 233 (01/19/2015 Net Payable Amount Wednesday, 14 January Wed nesday, 14 January Wednesday, 14 January Wednesday, 14 January 2015 Wednesday, 14 January 2015 Wednesday, 14 January 2015 Wednesday, 14 January 2015 2015 Date 2015 2015 71743 71747 64893 648 5 Ref NO. 64889 64891 64888 SELL BUY SELL BUY BUY BUY Transaction BUY 17270000 sh ares UNI shares 8000 X IS shares 950000 PSPC Particular 1950000 3100000 shares 1454000 FNI shares FNI shares MED 1446000 shares S 3,729,101.6 6,536,518.83 2,448,186.01 92;689.92 A 5,284,673.17 1,104,816.38 1,128,451.51 5,103,175.50 Amount

January 2015 Monday, 19 234 01/22/2015 Net Payable Amount Date Monday, 19 [anuary 2015] Ref. No. 64931 BUY Transaction Particular IS shares 10530000 S 4,130,313.5 4,130,313.53 Amount

January 2015 Tuesday, 20 23'5 (01/23/2015) Net Payable Amount Tuesday, 20 January 2015 Tuesday, 20 January 2015 Tuesday, 20 January 2015 Tuesday, 20 January 2015 Tuesday, 20 January 2015 Tuesday, 20 January 2015 Date Ref. NO. 64960 71785 71804 64952 64959 64961 SELL BUY SELL Transaction BUY BUY BUY ISM shares ISM shares ISM shares 117900 CHIPS 100000 IS 721000 shares shares Particular 1900000 IS shares 279000 1400000 3,388,923.8 2,157,702.64 764,370.00 1,411,278.46 2,876,445.00 -38,333.44 Amount 532,866.45

Thursday, 22 January 2015 236 Thursday, 22 January 2015 Date Ref. NO. 65032 BUY Transaction UNI shares Particular 5300000 2,130,178.50 Amount

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(01/27/2015) Net Payable Amount 2,130,178.5

Tuesday, 27 January 2015 237 (01/30/2015) Date Net Payable Amount Tuesday, 27 January 2015 NO. Ref. 65138 Transaction BUY Particular CAL shares S 300000 1,309,486.5 1,309,486.51 Amount

January 20i5 Wednesday, 28 238 02/02/2015 Wednesday, 28 January Wednesday, 28 January Wednesday, 28 January Net Payable Amount Date 2015 2015 2015 No. Ref. 65169 72043 72045 BUY SELL Transaction SELL 8690000 IS shares 198000 X Particular 20000000 IS shares shares S 7,844,850.01 3,266,701.35 2,390,572.08 2,187,576.5 Amount R

Monday, 2 February 2015 239 02/05/2015 Net Payable Amount Monday, 2 February 2015 Monday, 2 February 2015 Date Monday, 2 February 2015 Monday, 2 February 2015 Monday, 2 February 2015 Monday, 2 February 2015 Ref. NO. 65282 65301 65 303 65 304 72167 65302 BUY BUY BUY BUY SELL Transaction BUY Particular shares 44800 LRI 81500 LRI shares LRI shares 186000 4000 2GO 103700 LRI shares 400 MAXS shares shares 0 18,154.71 517,788.26 4,903,191.6 952,662.48 2,207,420.10 Amount 1,220,564.11 13,398.06

Wednesday, 4 February 2015 240 Net Payable Amount (02/09/2015 Wednesday, 4 February Wednesday, 4 February Wednesday. 4 February Wednesday, 4 February Wednesday, 4 February 2015 2015 Wednesday, 4 February 2015 2015 Date 2015 2015 Ref. NO 65379 72268 72236 72238 72271 65377 SELL BUY SELL SELL SELL Transaction BUY SFI shares 67000 shares CAL shares LRI shares Particular 35680000 IS shares 2GO shares CAL 201000 390000 7990000 200000 5 3,936,981.54 5,589,350.8 10,215,503.3 1,324,773.89 -870,619.13 -874,892.70 -268,432.99 Amount

February 2015 Thursday, 12 241 Date Thursday, 12 February 2015 Ref. No. 65633 BUY Transaction IS shares Particular 1900000 464,354.77 Amount

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02/17/2015 Thursday, 12 February 2015 Thursday, 12 February Thursday, 12 February Due Clearing Cr. As of Settlement Date 02/17/2015 Net Payable Amount (02/17/2015 2015 2015 65643 72529 72543 SELL SELL BUY 20000000 IS shares 8000000 UNI shares 1900000 IS shares 2,159,925.84 5,028,750.01 2,927,190.74 1,508,433.7 -405,988.20 -651,492.09 E

Friday, 13 February 2015 242

Net Payable Amount 02/18/2015 Date Friday, 13 February 2015 Friday, 13 February 2015 Friday, 13 February 2015 Ref. No. 65682 65689 65683 BUY BUY Transaction BUY shares 455000 CPM 490000 NI Particular 1525000 CPM shares shares S 521,682.53 1,621,973.03 3,856,045.5 1,712,389.95 Amount

Tuesday, 17 February 2015 2 43 (02/20/2015 Net Payable Amount Date Tuesday, 17 February 2015 Ref. NO 65764 BUY Transaction Particular FNI shares 1990000 5,433,866.1 0 5,433,866.10 Amount

Wednesday, 18 February 2015 244 Wednesday, 18 February Wednesday, 18 February Wednesday, 18 February Wednesday, 18 February 2015 Wednesday, 18 February Wednesday, 18 February Wednesday, 18 February Wednesday, 18 February 2015 Wednesday, 18 February 2015 Wednesday, 18 February 2015 2015 Wednesday, 18 February 2015 Wednesday, 18 February Wednesday, 18 February 2015 2015 2015 2015 2015 Date 2015 2015 65828 65829 65831 65833 65826 72685 Ref. NO. 65806 65816 65827 65800 65822 65823 65825 BUY BUY SELL BUY BUY BUY BUY BUY BUY BUY BUY BUY BUY Transaction OM shares 4900000 62000 LW Particular SFI shares FPI shares 1900000 SFI shares shares FNI shares FPI shares 238000 LW LW shares 127000 LRW 4800 LRW 268000 LRW 990000 2950000 50000 UNI 1000000 4940000 309000 shares shares shares share shares S 593,452.83 835,526.81 1,930,537.13 1,429,985.39 225,680.24 1,266,641.55 1,566,958.50 1,096,247.38 -274,774.07 2,628,628.20 22,126.50 344,871.68 498,449.71 Amount

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(02/23/2015 Wednesday, 18 February Wednesday, 18 February Net Payable Amount Wednesday, 18 February Wednesday, 18 February Wednesday, 18 February 2015 2015 2015 2015 2015 72729 72715 72719 72726 72711 SELL SELL SELL SELL SELL UNI shares SFI shares 50000 UNI 920000 2950000 shares 3580000 564000 MED shares FNI shares 8,264,055.4 1,376,145.67 -496,108.87 -27,204.37 1,472,953.67 -527,863.80 N Monday, 23 February 2015 245 Net Payable Amount (02/27/2015 Monday, 23 February 2015 Monday, 23 February 2015 Monday, 23 February 2015 Monday, 23 February 2015 Monday, 23 February 2015 Date Ref. ND. 72829 72840 72862 65 926 72817 SELL SELL BUY SELL SELL Transaction 188000 UNI shares UNI shares FNI shares 477000 OM shares Particular UNI shares 426000 3268000 113 79000 1,972,050.09 7,286,809.62 1,070,408.07 3,776,861.5 -363,341.63 -104,148.24 Amount

February 2015 Th ursday, 26 246 (03/03/2015 Net Payable Amount Thursday, 26 February Thursday, 26 February Date 2015 2015 Ref NO 66059 72991 Transaction BUY SELL Particular iS shares IS shares 52400000 54410000 17,100,163.8 15,619,466.0 1,480,697.7 A Amount

March 2015 Tuesday, 3 247 (03/06/2015) Cr. As of Settlement Date Net Payable Amount Due Clearing 03/06/2015 (03/06/2015 Tuesday, 3 March 2015 Tuesday, 3 March 2015 Tuesday, 3 March 2015] Tuesday, 3 March 2015 Tuesday, 3 March 2015 Tuesday, 3 March 2015 Tuesday, 3 March 2015 Date 73093 73096 66167 66168 Ref. 66152 66166 NO. 66143 SELL SELL BUY BUY BUY BUY BUY Transaction SFI shares 8160000 4940000 SFI shares 6600 220400 MARC shares 2000000 IS shares LRW shares 1150000 3020000 SFI shares Particular IS shares S 1,592,542.85 1,034,288.0 2 2,626,830.92 1,039,663.87 1,295,143.91 323,851.51 563,220.00 591,039,02 1,666,045.00 -261,844.57 Amount

March 2015 Thursday, 5 248 Date No. Ref. Transaction Particular Amount

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Due Clearing (03/10/2015) (03/10/2015) Thursday, 5 March 2015 Thursday, 5 March 2015 Cr. As of Settlement Date Net Payable Amount (03/10/2015) 66250 66251 BUY BUY 76000 2GO shares shares 248100 2GO 2,656,725.85 618,618.73 2,038,107.12 2,472,076.6 -184,649.23

Friday, 6 March 2015 249 Friday,6 March 2015 03/11/2015 Date Net Payable Amount Ref. NO. 62 8 BUY Transaction Particular IS shares 10000000 3,168,112.5 Amount 3,168,112.51

Monday, 9 March 2015 250 (03/12/2015) Monday,9 March 2015 Monday,9 March 2015 Monday,9 March 2015 Net Payable Amount Date Monday, 9 March 2015 Ref. NO. 66333 66336 7320 9 73229 BUY SELL Transaction BUY SELL 100000 2GO Particular H20 IS shares sh ares 18740000 313000 2GO shares 12600 shares 603,450.00 2,895,470.44 5,928,292.80 3,517,736.4 7 Amount -118,535.89

Tuesday, 10 March 2015 251 (03/13/2015 Date Tuesday, 10 March 2015 Net Payable Amount Tuesday, 10 March 2015 Tuesday, 10 March 2015 Tuesday, 10 March 2015 Ref. NO. 66384 66385 66391 66383 BUY BUY BUY BUY Transaction shares 2490000 3000 H20 UNI shares Particular 124000 H20 3000 H20 shares shares 18,024.70 18,094.69 2,217,269.2 663,573.73 1,517,576.17 Amount 9

Monday, 16 March 2015 252 Date Monday, 16 March 2015 Monday, 16 March 2015 Monday 16 March 2015 Monday.16 March 2015 Monday,16 March 2015 Ref. NO. 66545 66577 66578 66579 73483 SELL BUY BUY BUY Transaction BUY 534000 NI 10000 GTCAP 384000 NI 572000 NI 200000 NIKL Particular shares shares shares shares shares 1,995,729.83 13,474,168.5 6 1,540,617.93 2,301,156.00 5,372,413.95 Amount

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(03/19/2015) Monday, 16 March 2015 Net Payable Amount Monday,16 March 2015 Monday, 16 March 2015 73485 73 501 73484 SELL SELL SELL NKL shares 200000 NIKL shares 192500 shares 7500 NIKL -205,264.40 5,381,520.00 5,217,561.69 3,134,912.2 R

Tuesday, 17 March 2015 253 (03/20/2015 Net Payable Amount Date Tuesday,17 March 2015 Tuesday, 17 March 2015 Tuesday, 17 March 2015 Tuesday, 17 March 2015 Tuesday,17 March 2015 Tuesday,17 March 2015 Ref. NO 66604 66615 66616 73521 73545 66620 Transaction BUY SELL BUY BUY SELL BUY 90000 NI Particular 14590000 IS shares FNI shares 1410000 IS shares 1100000 NI shares shares 825000 FNI shares 665000 S 1,930,869.02 Amount 1,571,735.82 4,740,904.35 453,794.40 4,144,245.23 4,214,428.1 0 -338,630.17

Thursday, 19 March 2015 254 03/27/2015 Net Payable Amount Date Thursday, 19 March 2015 Thursday,19 March 2015 Thursday,19 March 2015 Ref. 66707 NO. 6699 66698 Transaction BUY BUY BUY 305000 Particular 300000 2GO shares 2GO shares 13260000 IS shares 2,171,780.34 2,292,607.14 3,851,067.05 8,315,454.5 3 Amount

Monday, 23 March 2015 Tuesday, 24 March 2015 255 256 Net Payable Amount 03/31/2015 Monday,23 March 2015 Monday,23 March 2015 Monday.23 March 2015 Date Tuesday, 24 March 2015 Date Monday, 23 March 2015 Tuesday, 24 March 2015 Tuesday, 24 March 2015 Tuesday,24 March 2015 Ref. Ref. 66804 NO 66845 66846 No. 66754 73690 73738 73650 66816 BUY Transaction BUY BUY SELL BUY BUY Transaction SELL SELL 20000 PPC 11000 20000 PPC shares Particular 201900 2GO shares shares 2G0 shares 20000 PPC shares Particular 1660000 GBO 498000 PPC 25000 PPC shares shares shares 692,861.17 50,538.94 1,385,249.3 76,638.15 2,036,110.70 1,469,881.48 -78,783.87 -56,387.23 -98,281.96 Amount Amount

Page 118 of 216

(03/31/2015 Net Payable Amount 2,707,328.0

Thursday, 26 March 2015 257 Date Ref. O Transaction Particular C Amount

Cr. As of Settlement Date Thursday, 26 March 2015 Due Clearing (03/31/2015 Thursday, 26 March 2015 Thursday, 26 March 2015 Thursday, 26 March 2015] Thursday, 26 March 2015 03/31/2015 Net Payable Amount (03/31/2015 66927 66928 66923 66925 66926 BUY BUY BUY BUY BUY 6720 73500 AGF shares 7600 AGF AGF 64200 AGF 115000 AGF shares shares shares shares 1,348,264.6 511,195.57 2,376,457.51 1,028,192.91 59,558.50 512,148.02 818,811.25 474,744.17

Friday, 27 March 2015 258 Net Payable Amount 04/01/2015 Friday, 27 March 2015 Friday,27 March 2015 Friday, 27 March 2015 Friday,27 March 2015 Friday, 27 March 2015 Friday,27 March 2015 Friday, 27 March 2015 Friday, 27 March 2015 Friday, 27 March 2015 Date Ref. 66977 66980 73847 73856 No. 66978 66988 73 846 73849 73854 SELL SELL SELL Transaction BUY BUY BUY SELL BUY SELL BHI shares 5510000 ACR ACR 95000 shares 250000 SFI shares shares 42000 4000000 PRMX shares 29000000 BHI shares 195000 PRMX shares shares 1168000 ACR 5384000 ACR shares Particular 6,460,333.79 12,355,158.7 2,660,329.45 3,500,010.00 -95,146.07 -752,769.78 -42,537.75 12,451,476.6 1,568,970.00 -474,840.00 Amount

March 2015 Tuesday, 31 259 Tuesday, 31 March 2015 Tuesday, 31 March 2015 Date Tuesday, 31 March 2015 Tuesday, 31 March 2015 67093 67094 Ref. 67103 No. 67092 BUY BUY BUY BUY Transaction Particular 148000 11000 4920 2G0 shares shares 2GO shares 2G0 shares PPC 18000 76,980.11 346,289.77 125,065.02 538,619.34 Amount

Page 119 of 216

Net Payable Amount Tuesday, 31 March 2015 (04/03/2015) Tuesday, 31 March 2015 Tuesday, 31 March 2015 Tuesday, 31 March 2015 73968 67105 73 924 67104 SELL SELL BUY BUY ACR 7000 PPC 95000 PPC 145000 shares 99000 PPC shares shares shares 371,624.63 1,500,567.3 378,363.14 -308,398.68 -27,975.99

Tuesday, 7 April 2015 260

Friday, 10 April 2015 261 (04/13/2015 Net Payable Amount Tuesday, 7 April 2015 Tuesday, 7 April 2015 Tuesday, 7 April 2015 Tuesday, 7 April 2015 Date Tuesday, 7 April 2015 74039 67205 67207 67208 Ref. 67203 No. SELL BUY BUY BUY BUY Transaction sh ares Particular FNI shares 247600 1500 GTCAP shares 1593000 995000 NI 352400 NIKL NIKL shares shares S 20,033,044.5 2,236,372.5 6 4,032,876.48 8,546,043.82 6,049,309.67 A 3,641,187.13 Amount

(04/15/2015 Date Friday, 10 April 2015 Net Payable Amount No. Ref. 67276 Transaction BUY Particular 195000 MEG shares 1,151,146.2 1,151,146.25 5 Amount

April 2015 Monday, 13 262 (04/16/2015 Monday, 13 April 2015 Monday, 13 April 2015 Net Payable Amount Monday, 13 April 2015 Monday, 13 April 2015 Monday, 13 April 2015 Monday, 13 April 2015 Monday,13 April 2015 Monday, 13 April 2015 Date 74169 74150 74167 74149 67307 67308 Ref. NO. 67304 67306 SELL SELL SELL SELL BUY BUY BUY BUY Transaction 1195000 MEG shares GERI shares 143000 400000 GER shares GO GER shares Particular 1000000 MEG 7000000 GEO 2990000 shares 1652000 GERI shares shares 2195000 shares 3 3,849,304.2 2,455,803.22 6,738,276.37 -217,852.62 3,102,738.75 1,383,308.55 -605,421.00 5,853,465.00 3,527,145.14 Amount

Thursday. 16 April 2015 263

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(04/21/2015 Net Payable Amount Thursday, 16 April 2015 Thursday, 16 April 2015] Thursday, 16 April 2015 Thursday, 16 April 2015 Thursday, 16 April 2015 Thursday, 16 April 2015 Thursday, 16 April 2015 Date 74269 74254 74265 67405 67408 Ref. No. 67404 67406 SELL SELL BUY BUY SELL BUY BUY Transaction 27000 UNI shares MEG shares MEG 2040000 GEO shares 495000 shares 305300 NIKL 495000 NIKL 107500 shares share: Particular 232200 shares NIKL 12,062,144. 41 2,156,490.93 6,138,890.82 2,663,477.45 2,585,503.80 -102,832.53 -787,047.30 4,578,668.84 Amount

Friday, 24 April 2015 Tuesday, 21 April 2015 215 264 (04/24/2015) Net Payable Amount (04/24/2015) Tuesday, 21 April 2015] Cr. As of Settlement Date Tuesday, 21 April 2015 Due Clearing (04/24/2015) Tuesday, 21 April 2015 Tuesday. 21 April 2015 Tuesday, 21 April 2015 Date 74352 67477 74351 Ref. 67474 67476 NO. SELL Transaction BUY SELL BUY BUY shares 1700 2GO Particular shares POPI shares 2900000 POPL 65000 2GO shares shares 95000 2GO 2000000 4,795,274.12 -609,851.68 4,185,422.4 2,750,726.25 -444,218.77 -11,608.32 668,803.63 1,831,S71.33 A Amount

(04/29/2015 Net Payable Amount Friday, 24 April 2015 Friday, 24 April 2015 Date 67560 Ref. NO. 67551 B UY Transaction BUY shares 300000 IS Particular 68000 AGF shares 75,431.25 565,028.33 640,459.58 Amount

Monday, 27 April 2015 266 (04/30/2015 Net Payable Amount Monday, 27 April 2015 Monday,27 April 2015 Date 67574 67603 Ref NO BUY Transaction BUY Particular IS shares 6200000 670000 CAL shares S 4,901,975.2 1,682,770.61 3,219,204.60 Amount

Page 121 of 216

April 2015 Tuesday, 28 267 (05/04/2015) Tuesday, 28 April 2015 Date Net Payable Amount Ref. 67628 No BUY Transaction 990000 Particular CROWN shares S 2,787,939.0 2,787,939.00 Amount

O

Monday, 4 May 2015 268 05/07/2015) Date Monday, 4 May 2015 Net Payable Amount Monday, 4 May 2015 Ref. 67714 67715 NO BUY BUY Transaction Particular POPI shares 806500 shares 1443500 POPI 932,808.00 2,581,891.0 1,649,083.03 Amount

Tuesday, 5 May 2015 269 05/08/2015 Net Payable Amount Tuesday, 5 May 2015 Tuesday, 5 May 2015 Tuesday, 5 May 2015 Tuesday, 5 May 2015 Tuesday, 5 May 2015 Date Tuesday, 5 May 2015 Tuesday, 5 May 2015 67752 74641 74647 74653 Ref. No. 67743 67744 67737 BUY SELL SELL SELL BUY Transaction BUY BUY 1450000 shares POPI 109000 TA shares shares POPI shares AGF shares 1480000 1881000 TA shares 5000 TAPET 485000 75000 Particular POPI shares G 3,983,948.3 27,658.13 -593,550.00 1,633,330.89 1,741,104.11 269,641.58 4,714,583.88 -542,158.45 Amount

Friday, 8 May 2015 270

Friday,8 May 2015 Cr. As of Settlement Date (05/13/2015) Net Payable Amount 05/13/2015 Friday,8 May 2015 Friday, 8 May 2015 Due Clearing 05/13/2015 Date Friday,8 May 2015 Friday,8 May 2015 74742 Ref. 67817 67818 No. 67814 74741 SELL BUY BUY BUY SELL Transaction shares shares 49700 NIKL 91300 350300 N(KL 398700 MAXS shares MAXS Particular 195000 TAPET shares shares 4,846,159.84 2,056,850.97 2,789,308.8 1,113,968.70 11,578,400.2 0 2,662,069.39 9,195,553.59 1,312,724.86 Amount

Page 122 of 216

Monday, 11 May 2015 2 71 05/14/2015 Monday, 11 May 2015 Monday,11 May 2015 Monday,11 May 2015 Net Payable Amount Date Ref. 67863 67861 74772 No. BUY SELL Transaction BUY Particular 250000 LRW shares TA shares shares 1130000 195000 TAPET S Amount 1,156,612.50 2,606,853.71 2,258,816.9 1,504,649.25

May 2015 Tuesday, 12 272 (05/15/2015) Net Payable Amount Tuesday, 12 May 2015 Tuesday, 12 May 2015 Date Ref. No. 67890 74818 BUY SELL Transaction 301000 BRN shares Particular BRN shares 3000000 2,413,800.00 2,161,511.5 0 -252,288.41 Amount

Thursday, 14 May 2015 273 Thursday, 14 May 2015 Net Payable Amount (05/19/2015 Date Thursday, 14 May 2015 Ref 67985 NO 67966 BUY BUY Transaction Particular shares 400000 IS shares 1059000 POPI 94,540.50 Amount 1,251,776.56 1,346,317.0 6 Tuesday, 19 May 2015 274

05/22/2015 Tuesday, 19 May 2015 Net Payable Amount Tuesday, 19 May 2015 Tuesday, 19 May 2015 Tuesday,19 May 2015 Date 68047 Ref. NO 68043 68045 68046 BUY BUY BUY BUY Transaction 346000 shares shares 114000 CAL sh ares 130000 CAL shares CAL 2990000 APC Particular 4,869,328.6 1,494,946.80 2,335,975.08 556,330.62 482,076.11 Amount

Friday, 22 May 2015 275

Friday, 22 May 2015 Friday; 22 May 2015 Friday, 22 May 2015 Date Ref. NO 68123 68122 68124 BUY BUY BUY Transaction shares shares shares 175000 CAL 115000 CAL Particular 193000 CAL 898,748.27 822,150.34 542,954.14 Amount

Page 123 of 216

Net Payable Amount (05/27/2015) Friday, 22 May 2015 68126 BUY 990000 PXP shares 4,420,583.0 2,156,730.29 4

May 2015 Monday, 25 27 (05/28/2015) Net Payable Amount Monday,25 May 2015 Date Monday,25 May 2015 Ref. No. 68140 75069 Transaction BUY SELL 60000 shares 200 GTCAP shares CAL Particular 2,866,387.50 2,583,264.1 -283,123.35 5 Amount

Friday, 29 May 2015 27 Net Payable Amount 06/03/2015) Cr. As of Settlement Date (06/03/2015 Date Friday,29 May 2015 Friday,29 May 2015 Friday, 29 May 2015 Friday,29 May 2015 Friday, 29 May 2015 Friday,29 May 2015 Due Clearing (06/03/2015 Ref. NO 68228 68233 75155 75157 68230 75153 SELL SELL BUY BUY SELL Transaction BUY Particular 990000 PXP 970000 990000 MHC 7262000 FNI shares 2990000 MHC shares shares FNI shares 570000 shares shares PXP 13,088,456.8 12,193,783.4 2,100,508.87 1,535,316.00 1,133,304.56 1,262,101.25 11,826,355. 63 Amount 2,079,780.38 -616,995.23 0

Monday, 1 June 2015 2 78 (06/04/2015) Net Payable Amount Monday,1 June 2015 Mondav, 1 June 2015 Monday,1 June 2015 Monday, 1June 2015 Date Monday,1june 2015 Ref. N 75175 75177 75180 75168 68 255 SELL SELL SELL SELL Transaction BUY Particular FNI shares FNI shares 1121000 shares 1995000 266000 FNI shares MHC 800000 PXP 3617000 shares 2,851,523.01 7,394.94 5,527,954.01 -698,638.03 1,583,581.50 -386,816.53 Amount

Wednesday, 3 June 2015 29 Wednesday, 3 June 2015 Date Ref. NO. 68295 Transaction BUY Particular shares 2776000 CROWN 6,011,347.63 Amount

Page 124 of 216

(06/08/2015) (06/08/2015) Cr. As of Settlement Date Net Payable Amount Wednesday, 3 June 2015 Due Clearing (06/08/2015 68297 BUY 990000 shares VITA 834,249.52 1,410,219.54 5,435,377.6 6,845,597.15

Thursday, 4 June 2015 280 (06/09/2015 Net Payable Amount Thursday, 4 June 2015 Thursday,4 June 2015 Date Thursday, 4 June 2015 Ref. NO. 68312 75244 75245 SELL BUY SELL Transaction Particular PXP shares 5800000 PHA shares 300000 PXP shares 571000 S 2,461,984.0 g Amount -617,390.93 1,259,641.70 4,339,016.72

Monday, 8 June 2015 281 (06/11/2015) Date Monday,8 June 2015 Net Payable Amount Ref. NO. 68341 Transaction BUY Particular FNI shares 2990000 5,190,283.5 5,190,283.51 Amount K Thursday, 11 June 2015 282 06/17/2015 Net Payable Amount Date Thursday, 11June 2015 Ref. No 68384 Transaction BUY POPL shares Particular 10000 12,813.91 12,813.91 Amount

Wednesday, 17 June 2015 283 (06/22/2015 Wednesday, 17 June 2015 Wednesday, 17 June 2015 (06/22/2015) Cr. As of Settlement Date Net Payable Amount Date Due Clearing (06/22/2015 Ref. NO 68445 68441 BUY Transaction BUY Particular 90000 TAPET 3524000 POPI shares shares S 4 1,070,916.93 5,204,570.8 5,204,434.41 1,071,053.34 6,275,487.75 Amount

June 2015 Thursday, 25 284 06/30/2015 Cr. As of Settlement Date Thursday, 25 June 2015 Due Clearing 06/30/2015 Date Ref. 68537 N BUY Transaction Particular 1000000 POPI shares Amount 1,780,177.50 1,780,177.50 -231,829.91

Page 125 of 216

06/30/2015 Net Payable Amount 1,548,347.5

Friday, 26 June 2015 285 (07/01/2015} Date Friday, 26 June 2015 Net Payable Amount Ref. No. 68554 BUY Transaction Particular 100000 PPC shares 315,694.87 315,694.87 Amount

June 2015 Tuesday, 30 286 (07/03/2015) Date Tuesday, 30 June 2015 Net Payable Amount Ref. No. 68595 BUY Transaction Particular POPI shares 2500000 5,016,057.4 5,016,057.44 Amount

Thursday, 2 July 2015 287 Date Net Payable Amount (07/07/2015) Thursday, 2 July 2015 Ref. NO. 68618 BUY Transaction Particular shares 15000 ICT 1,697,203.13 1,697,203.1 Amount 3 Fri day, 3 July 2015 288 07/08/2015 Net Payable Amount Date Friday,3 July 2015 Ref. NO 68643 BUY Transaction Particular 11900000 IS shares 2,661,888.35 2,661,888.3 5 Amount

Wednesday, 8 July 2015 289 (07/13/2015 Net Payable Amount Due Clearing (07/13/2015 Cr. As of Settlement Date Wednesday, 8 July 2015 (07/13/2015) Date Wednesday,8|uly 2015 Ref. 68692 NO 68689 BUY BUY Transaction POPI 590000 Particular 52000000 0 AR shares shares 1,102,483.04 4,602,493.04 2,970,222.06 1,632,270.9 R 3,500,010.00 Amount

Thursday, 9 July 2015 2 (07/14/2015 Date Thursday, 9 July 2015 Thursday, 9 July 2015 Net Payable Amount Ref. 75 628 NO 68 718 BUY SELL Transaction Particular 29800000 0 AR shares 420000 POPL shares -814,350.60 1,013,901.7 5 Amount 1,828,252.35

Tuesday, 14 July 2015 291

Page 126 of 216

Tuesday 14 July 2015 (07/17/2015 Net Payable Amount 07/17/2015 Due Clearing (07/17/2015 Cr. As of Settlement Date Date NO. Ref. 68773 BUY Transaction Particular 49800000 0 AR shares S 2,288,200.6 3,255,612.75 -967,412.14 Amount

Wednesday, 15 July 2015 2 2 (07/20/2015) Net Payable Amount Wednesday, 15 July 2015 Date Ref. NO. 68794 BUY Transaction LIB shares 990000 Particular 3,082,834.9 3,082,834.98 Amount 0 Thursday. 16 July 2015 293 07/21/2015 Thursday, 16July 2015 Net Payable Amount Thursday, 16 July 2015 Thursday; 16 July 2015 Date Ref. 68807 75712 75719 N. SELL SELL BUY Transaction AR shares Particular PLC shares 252000 LIB shares 35000000 1990000 S -718,057.00 2,106,005.9 3,042,192.60 -218,129.63 7 Amount

Wednesday, 22 July 2015 294 (07/27/2015) (07/27/2015 Net Payable Amount Due Clearing Wednesday, 22 July 2015 (07/27/2015 Date Cr. As of Settlement Date Ref. NO. 68873 BUY Transaction Particular MCP shares 495000 3,584,493.00 1,758,284.28 1,826,208.7 3,584,493.00 Amount

Monday, 27 July 2015 2 5 Net Payable Amount 07/30/2015 Monday, 27 July 2015 Monday,27 July 2015 Monday, 27 [uly 2015 Date NO. 68939 Ref. 68938 75895 BUY BUY SELL Transaction Particular PPC 20000 2GO 559000 PPC 441000 shares shares shares 3,754,054.2 9 2,154,457.30 1,764,326.90 -164,729.91 Amount

Tuesday, 28 July 2015 296 (07/3i/2015) Net Payable Amount Date Tuesday, 28 July 2015 Ref. NO. 68959 Transaction BUY Particular shares 800000 PPC 2,865,240.9 2,865,240.95 5 Amount

Page 127 of 216

July 2015 Wednesday, 29 297 (08/03/2015) Wednesday, 29 July 2015 Net Payable Amount Date Ref. No. 68987 Transaction BUY Particular TA shares 2000000 4,623,261.77 4,623,261.7 Amount

August 2015 Tuesday, 4 2 8 (08/07/2015) Net Payable Amount Due Clearing Cr. As of Settlement Date (08/07/2015) Date Tuesday, 4 August 2015 08/07/2015 Ref. No 69070 BUY Transaction shares Particular 15000000 DO AR 1,213,040.53 9,252,900.00 8,039,859.4 9,252,900.00 Amount

Friday, 7 August 2015 29 9 (08/12/2015) Friday, 7 August 2015 Friday,7 August 2015 Net Payable Amount Date Ref. NO. 69108 69107 Transaction BUY BUY 30000000 shares Particular 500000 CAL shares Q AR 1,750,005.00 3,617,501.7 Amount 1,867,496.72 2

August 2015 Tuesday, 11 3 00 Tuesday, 11 August 2015 08/14/2015 Tuesday, 11 August 2015 Net Payable Amount Tuesday, 11 August 2015 Date Tuesday, 11 August 2015 76152 69136 69142 76106 Ref. NO. BUY SELL Transaction BUY SELL Particular SBS shares SBS shares 917000 100000 POPI 130000 CAL shares 521000 shares S 231,322.50 2,886,235.80 2,064,562.0 5,256,954.68 0 Amount -537,479.29

Friday, 14 August 2015 301 (08/19/2015) Friday, 14 August 2015 Friday, 14 August 2015 Net Payable Amount Date Ref. NO. 69210 76187 Transaction BUY SELL Particular 50000000 shares POPI 0 AR 2305000 shares 5,762,323.95 2,868,825.00 2,893,498.9 5 Amount

Thursday, 20 August 2015 302 Thursday, 20 August 2015 Date Ref. 69290 No. BUY Transaction PA shares Particular 20000000 S Amount 1,119,429.93

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Net Payable Amount (08/26/2015 1,119,429.9

August 2015 Monday, 24 303 (08/27/2015) Net Payable Amount Date Monday, 24 August 2015 Ref. NO 69315 Transaction BUY Particular 40000000 PA shares S 2,031,615.0 2,031,615.00 0 Amount

August 2015 Friday, 28 304 Date Ref. NO. Transaction Particular Amount

(09/02/2015) Net Payable Amount Friday, 28 August 2015 69 379 BUY LIB shares 1000000 2,524,211.24 2,524,211.2

September 2015 Monday, ? 305 Date Ref. NO. Transaction Particular S Amount

Monday, 7 September 2015 Net Payable Amount (09/10/2015) Monday, 7 September 2015 Monday,7 September 2015 Monday, 7 September 2015 76403 69446 76400 69444 SELL BUY SELL BUY LIB shares SBS shares SBS shares 222000 500000 SBS shares 500000 500000 2,522,587.50 2,208,839.6 2,604,892.51 2,675,677.21 -549,142.54

Tuesday, 22 September 2015 306 (09/25/2015 09/25/2015) Net Payable Amount Due Clearing Cr. As of Settlement Date 09/25/2015 Date Tuesday, 22 September 2015 Ref. 69 730 No. BUY Transaction Particular UNI shares 4000000 S 757,401.24 1,568,970.00 -811,568.76 1,568,970.00 Amount

Wednesday, 23 September 2015 307

09/28/2015 Net Payable Amount Wednesday, 23 Septemher Wednesday, 23 September Wednesday, 23 September 2015 Date 2015 2015 Ref. 6 765 69 75 9 NO. 69758 BUY BUY BUY Transaction ION shares 1212000 1050000 UNI shares Particular ION shares 1588000 S 9,103,314.8 3,802,740.75 416,430.78 4,884,143.27 Amount

Septermber Tuesday, 29 2015 308

Date Tuesday, 29 September 2015 Ref. NO. 69849 BUY Transaction shares Particular 149000 DAVIN 290,722.10 Amount

Page 129 of 216

Net Payable Amount (10/02/2015) Tuesday, 29 September Tuesday, 29 September Tuesday, 29 September 2015 2015 2015 76737 76741 69872 BUY SELL SELL 5000000 ION shares 28000 690000 MED shares UNI shares 1,039,444.53 4,002,885.00 3,021,936.1 -232,226.43

Thursday, 1 October 2015 309 (10/06/2015 Date Thursday. 1 October 2015 Net Payable Amount Thursday, 1 October 2015 Thursday, 1 October 2015 Thursday, 1 October 2015 NO. Ref. 69927 69928 69921 76807 SELL BUY Transaction BUY BUY ION shares 563000 LIB shares ION shares Particular LIB shares 1490000 1490000 737000 S 2,607,879.57 4,279,871.41 6,433,407.7 4,743,519.30 3,361,880.30 Amount

Friday, 9 October 2015 310 (10/14/2015) Friday, 9 October 2015 Friday, 9 October 2015 Friday, 9 October 2015 Net Payable Amount Friday, 9 October 2015 Date Friday, 9 October 2015 NO. 70094 70095 76963 76970 Ref. 70087 BUY BUY BUY SELL SELL Transaction 777000 1980000 shares 515000 shares GERI SPH GERL shares 641000 shares Particular SPH shares SPH 1980000 2,512,407.2 1,623,763.26 2,061,546.13 2,555,737.28 1,177,603.19 2,560,438.35 Amount

Monday, 12 October 2015 311 (10/15/2015) Monday, 12 October 2015 Net Payable Amount Monday, 12 October 2015 Mondav, 12 October 2015 Date Monday, 12 October 2015 Ref. 76983 70127 70128 NO. 70110 BUY BUY SELL Transaction BUY shares shares GTCAP NOW shares 1500000 SUN 8000 Particular PBR shares 9000000 177000 7,241,922.99 1,910,925.00 10,636,416.0 1,688,708.2 3,172,276.30 9 D Amount

Tuesday, 13 October 2015 3 12 Tuesday, 13 October 2015 Date Ref NO 70161 Transaction BUY Particular 625000 ION shares 1,759,459.06 Amount

Page 130 of 216

(10/16/2015) Net Payable Amount Tuesday, 13 October 2015] Tuesdav, 13 October 2015 Tuesdav, 13 October 2015 Tuesday, 13 October 2015 77036 77023 70166 77027 SELL BUY SELL SELL shares SUN shares NOW NW shares 710000 5000 PBB 5257000 116000 shares 4,885,472.8 4,253,125.67 -89,507.34 -949,561.33 -88,043.25

October 2015 Friday, 16. 313 (10/21/2015) Friday, 16 October 2015 Friday, 16 0ctober 2015 Net Payable Amount Date Friday, 16 October 2015 NO. 77103 Ref. 70234 77098 SELL SELL Transaction BUY NOW shares 100000 shares Particular 7000000 NOW shares 2000000 NOW 8,297,437.50 1,998,285.00 -99,914.25 6,199,238.2 Amount

Wednesday, 21 October 2015 314

Wednesday, 21 October Cr. As of Settlement Date (10/26/2015) 10/26/2015 Wednesday, 21 October 10/26/2015 Net Payable Amount Due Clearing Date 2015 2015 Ref. NO. 70303 70304 BUY Transaction BUY Particular SFI shares 17930000 SFI shares 5000000 1,005,750.00 4,452,827.39 1,340,056.46 3,112,770.9 3,447,077.39 Amount

October 2015 Thursday, 22 315 (10/27/2015) Net Payable Amount Thursday, 22 October 2015 Date Ref. 70319 No BUY Transaction 2300000 NOW shares Particular 2,124,194.2 2,124,194.29 Amount O

October 2015 Friday, 23 316 10/28/2015) Date Net Payable Amount Friday, 23 October 2015 Ref. O 70335 Transaction BUY Particular 5000000 NOW shares 4,763,674.5 4,763,674.51 Amount

Tuesday, 27 October 2015 317 Tuesday, 27 October 2015 Date Ref. NO 70372 BUY Transaction Particular 1236000 PPC shares Amount 3,835,669.03

Page 131 of 216

Net Payable Amount Tuesday, 27 October 2015 (10/30/2015 Tuesday, 27 0ctober 2015 Tuesday, 27 October 2015 70373 70374 77250 BUY BUY SELL 690000 PPC shares 891000 PPC shares 3097000 NOW shares 6,384,614.4 2,957,206.72 2,260,755.02 2,669,016.29 8

October 2015 Wednesday, 28 318 (11/02/2015) Net Payable Amount Wednesday, 28 October Wednesday, 28 October 2015 Date Wednesday, 28 October 2015 2015 Wednesday, 28 October 2015 Ref. NO 70389 77 254 77262 70385 SELL BUY SELL Transaction BUY Particular 1000000 145000 BKR 100000 PBB shares 450000 BKR shares PXP shares share: S 611,572.47 1,880,332.77 Amount 964,011.38 1,807,604.30 -279,710.44

Thursday, 29 October 2015 319 (11/03/2015 Net Payable Amount Thursday, 29 October 2015 Date Ref. No. 70403 Transaction BUY Particular shares 744000 NOW S 676,024.92 676,024.92 Amount

October 2015 Friday, 30 320 (11/04/2015 Friday, 30 October 2015 Net Payable Amount Friday, 30 October 2015 Date Friday, 30 October 2015 Ref. NO 77 290 70419 77285 SELL SELL BUY Transaction shares LIB shares 170000 LIB shares NOW Particular 626000 731000 2,552,050.40 1,263,087.3 -633,090.32 Amount -655,872.75

Thursday, 5 November 2015 3 21

Thursday, 5 November Thursday, 5 November Thursday, 5 November Thursday, 5 November 2015 2015 Date Thursday, 5 November Thursday, 5 November 2015 2015 2015 2015 77471 77472 Ref. 77470 70490 70491 77465 NO. SELL SELL SELL SELL BUY Transaction BUY LIB shares SFI shares 897000 100000 9210000 790000 SFI shares Particular 26000 LlB shares PRIM 1472000 LIB shares shares S 1,377,688.91 -122,241.62 6,684,858.19 1,144,562.25 4,322,089.92 -136,516.50 Amount

Page 132 of 216

(11/10/2015 Net Payable Amount Thursday, 5 November Thursday, 5 November 2015 Thursday, 5 November 2015 2015 77477 77479 77476 SELL SELL SELL PRIM 422000 LIB shares LIB shares 500000 shares 400000 3,954,604.6 1,760,865.00 -682,582.50 1,827,886.68

Tuesday, 10 November 2015 3 22 Tuesday, 10 November Tuesday, 10 Novembe Net Payable Amount (11/13/2015 Tuesday, 10 November Tuesday, 10 November Tuesday, 10 November 2015 2015 2015 Tuesday, 10 November 2015 2015 2015 Date Ref. NO. 70547 77374 77376 77382 77375 70546 SELL Transaction BUY BUY SELL SELL SELL LIB shares ION shares LIB shares 8680000 Particular 2309000 ION shares 464000 843000 149000 8000 LIB shares SFI shares 287,017.05 4,819,724.98 992,886.44 -35,375.57 1,291,357.05 3,557,501.28 Amount -641,360.47

Wednesday, 11 November 2015 3 23

(11/16/2015 Wednesday, i1 November Net Payable Amount 2015 Wednesday, 11 November Wednesday, 11 November 2015 Wednesday, 11 November Wednesday, 11 November Wednesday, 11 November 2015 2015 Date 2015 2015 Ref. 70566 77398 7 7405 77406 70563 77396 No. SELL SELL BUY SELL SELL BUY Transaction 300000 LTG shares LIB shares LTG 200000 LIB shares 0 PA shares 300000 200000 shares 10000000 shares Particular 500000 LTG 0 3,993,430.95 1,953,951.4 1,307,857.71 2,746,158.00 -906,153.00 4,119,237.00 7,039,926.16 Amount

November Thursday, 12 2015 324 11/17/2015 Net Payable Amount Thursday, 12 November Thursday, 12 November Thursday, 12 November 2015 2015 Thursday, 12 November Date Thursday, 12 November 2015 2015 2015 Ref. 77419 77435 70592 77418 77423 No. SELL SELL SELL SELL BUY Transaction ION shares ION shares PA shares 700000 2023000 50000 ION 81000000 Particular 23050000 0 PA shares shares 4,234,791.29 2,773,856.99 1,513,235.94 9,107,569.12 477,856.65 -107,828.25 Amount

Page 133 of 216

Novemher Friday, 13 2015 325 (11/18/2015) Net Payable Amount Date Friday, 13 November 2015 Friday, 13 November 2015 Ref. NO. 70617 7448 Transaction BUY SELL Particular NOW 0 PA shares 5000000 shares 10320000 Amount 3,438,971.02 240,429.00 3,198,542.02

November Tuesday, 17 2015 326 (11/20/2015 Tuesday, 17 November 2015 Net Payable Amount Date Ref. NO 70645 BUY Transaction ION shares Particular 500000 1,221,091.1 Amount 1,221,091.11

Monday, 23 November 2015 37 Monday, 23 Novemher Date Monday, 23 November Monday, 23 November 2015 2015 2015 Ref. 70675 70676 70677 NO. BUY BUY Transaction BUY FiP shares FjP shares 125100 Particular 24900 FJP 300000 shares 2,062,793.25 188,928.15 960,100.01 Amount

(11/26/2015) Net Payable Amount Monday. 23 November 2015 70681 BUY shares 200000 YEHEY 4,106,938.9 895,117.50

Thursday, 26 November 2015 328

Date Ref. No. Transaction Particular Amount

12/02/2015 Cr. As of Settlement Date Net Payable Amount Due Clearing (12/02/2015 Thursday, 26 Novemher 2015 (12/02/2015 70723 BUY shares 1000000 CROWN 659,786.68 2,603,343.65 2,603,343.65 1,943,556.97

November Friday, 27 2015 329 Net Payable Amount (12/03/2015) Friday, 27 November 2015 Date Ref. NO. 70742 BUY Transaction CROWN Particular 1000000 shares 2,534,490.0 2,534,490.00 Amount

Wednesday, 2 December 2015 30

Date Ref. NO. Transaction Particular S Amount

Page 134 of 216

(12/07/2015) Net Payable Amount Wednesday, 2 December 2015 70773 BUY 2000000 NOW shares 1,689,660.0 0 1,689,660.00

Thursday, 3 December 2015 331 Net Payable Amount (12/08/2015) Date 2015 Thursday, 3 December Thursday, 3 December 2015 Ref. No. 70804 70806 BUY BUY Transaction Particular 200000 sh ares DAVIN 2000000 NON shares 0 333,909.00 1,679,602.50 2,013,511.5 Amount

2015 Friday, 4 December 332 (12/09/2015 Friday, 4 December 2015 Net Payable Amount Friday, 4 December 2015 Friday, 4 December 2015 Date Ref. 77755 70826 77750 No. SELL BUY SELL Transaction shares 2989000 shares NOW 58000 DAVIN Particular 2000000 DAVIN shares 1,015,936.7 9 2,353,188.33 3,459,780.00 -90,654.88 Amount

Monday, ? 2015 December 33 Net Payable Amount (12/10 2015 Date Monday, 7 December 2015 Monday, 7 December 2015 Ref. NO. 70864 77781 SELL Transaction BUY IDC shares 1011000 Particular NOW shares 1270000 5,793,693.28 4,963,583.9 3 Amount -830,109.35

Wednesday, 9 December 2015 334 (12/14/2015 Net Payable Amount Wednesday, 9 December Wednesday, 9 December 2015 Wednesday, 9 December 2015 Wednesday, 9 December 2015 Date 2015 Ref. 7099 70904 77818 NO. 70898 BUY BUY BUY Transaction SELL FJP shares shares 603000 CROWN shares 38300 FJP shares 200000 X Particular 361700 3,034,750.05 2,164,794.40 240,733.29 4,079,762.2 1,360,515.52 Amount

December Friday, 11 2015 35

Date Ref. No. Transaction Particular Amount

Page 135 of 216

(12/16/2015 Friday, 11 December 2015 Net Payable Amount 70934 BUY 1346000 NOW shares 1,197,224.6 1,197,224.68 G

Friday, 18 December 2015 36 Friday, 18 December 2015 Friday, 18 December 2015 (12/23/2015 Friday, 18 December 2015 Net Payable Amount Date Friday, 18 December 2015 Ref. NO. 71004 71005 77984 71007 SELL BUY BUY Transaction BUY Particular jAS shares JAS shares 5915000 NOW 212000 288000 5300000 shares NOW shares 490,091.91 973,546.82 707,293.70 4,717,741.95 4,941,580.74 Amount

Wednesday, 23 December 2015 337 Wednesday, 23 December Wednesday, 23 December Date 2015 2015 Ref. NO. 71053 71048 BUY BUY Transaction Particular PLC shares JON shares 5000000 1000000 G 2,514,375.00 3,136,833.68 Amount

Net Payable Amount 01/01/2016 Wednesday, 23 December 2015 78043 SELL 31000 CHIB shares 4,514,144.9 1,137,063.73 E Monday, 28 December 2015 338 Net Payable Amount 01/04/2016 Date Monday, 28 December 2015 Monday, 28 December 2015 Ref. NO 71063 71068 BUY BUY Transaction IDC shares PLC shares Particular 300000 5000000 S 4,296,755.0 Amount 3,268,687.50 1,028,067.57

January 2016 Tuesday, 5 2016 339 Tuesday, 5 January 2016 Tuesday, 5 January 2016 01/08/2016 Tuesday, 5 January 2016 Due Clearing Date 71104 71105 71106 Ref no. Transaction BUY BUY BUY 10000000 Particular 1532000 1968000 shares 0 EG shares shares MCP MCP 3,256,266.49 4,309,880.12 8,672,471.6 1,106,325.00 Amount

(01/08/2016 Cr. As of Settlement Date 2,459,924.2

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January 2016 Tuesday, 12 340 (01/08/2016 Tuesday, 12 January 2016 Tuesday, 12 january 2016 Net Payable Amount Date 71193 71194 Ref no. Transaction BUY BUY LIB shares PLC shares Particular 1740000 374000 1,674,553.64 6,212,547.3 778,752.23 Amount

01/15/2016 Due Clearing 2,453,305.8 1 Cr. As of Settlement Date 01/15/2016 1,875,718.2 E

Wednesday, 13 January 2016 341 Wednesday, 13 January 01/15/2016 Wednesday, 13 January Net Payable Amount 2016 2016 Date 71200 71202 no. Ref Transaction BUY BUY LIB shares Particular PLC shares 5000000 300000 2,358,383.17 1,333,624.50 577.587.62 Amount

January 2016 Monday, 18 342 (01/18/2016) Monday 18 january 2016 Net Payable Amount Date 71264 Ref no Transaction BUY PLC shares Particular 4310000 2,109,912.65 3,692,007.6 Amount

Wednesday, 20 January 2016 343 (01/21/2016 Wednesday, 20 January Wednesday, 20 January Net Payable Amount 2016 2016 Date 78294 71301 Ref O Transaction SELL BUY PLC shares Particular 2500000 1910000 DAVIN shares S 6,761,154.38 2,109,912.6 982,523.10 Amount 5

January 2016 January 2016 Monday, 25 Friday, 22 345 344 Monday, 25 January 2016 Net Payable Amount Monday,25 January 2016 Monday, 25 January 2016 01/25/2016 Friday, 22 January 2016 01/27/2016 Monday, 25 January 2016 Friday, 22 January 2016 Net Payable Amount Date Date 71371 78348 71369 713 49 78328 78353 Ref Ref no. no. Transaction Transaction SELL SELL BUY BUY SELL BUY PLC shares Particular PLC shares PLC shares Particular 5000000 5000000 5065000 160000 500000 500000 DAVIN DAVIN DAVIN shares share. shares G 3,209,297.96 3,153,116.76 3,066,675.00 1,370,111.25 1,408,050.00 5,778,631.2 427,356.00 Amount Amount 37,938.75 R

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January 2016 Thursday, 28 January 2016 Tuesday, 26 347 346 (01/29/2016) Thursday, 28 January 2016 Thursday, 28 January 2016 (01/28/2016) Net Payable Amount Tuesday, 26 [anuary 2016 Thursday,28 January 2016 Net Payable Amount Thursday, 28 January 2016 Thursday,28[anuary 2016 Date Date 71423 71439 71440 78438 71437 71384 Ref Ref no. No. Transaction Transaction SELL BUY BUY BUY BUY BUY Particular PLC shares Particular PLC shares 50000 LIB FNI shares 2220000 1780000 100000 500000 200000 shares shares COAL shares COAL 0 2,868,383.7 203,392.83 355,703.61 683,155.70 893,106.00 203,392.83 147,845.25 Amount Amount 74,193.75

January 20 16 Friday, 29 348 (02/02/2016) Friday,29 anuary 2016 Friday, 29 January 2016 Net Payable Amount Friday, 29 January 2016 Friday, 29 January 2016 Date 78443 71459 71465 78470 Ref nO Transaction SELL SELL BUY BUY Particular PLC shares PLC shares 100000 3000000 4000000 1160000 shares COAL COAL shares 2,383,627.50 1,636,021.65 2,005,616.8 518,564.69 Amount 78,150.75

February 2016 February 2016 Tuesday, 2 Monday, 1 350 349 (02/04/2016 Net Payable Amount (02/03/2016) Monday, 1 February 2016 Monday, 1 February 2016 Monday, 1 February 2016 Net Payable Amount Date 78500 71481 71484 Ref DO Transaction SELL BUY BUY SSI shares Particular SsI shares 10000 SSI 99000 990000 shares C 3,236,776.53 3,215,885.62 1,188,019.7 Amount 13,304.59 34,195.50 C

Tuesday; 2 February 2016 Tuesday, 2 February 2016 Tuesday, 2 February 2016 Tuesday, 2 February 2016 Date 71505 71503 71504 78522 Ref no. Transaction SELL BUY BUY BUY Particular IRC shares SSI shares 10000 ssr 1000000 1000000 500000 shares shares MCP S 1,380,824.32 2,406,709.47 1,795,263.75 Amount 34,524.82

(02/05/2016) Net Payable Amount 5,548,272.7

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February 2016 Tuesday, 9 351 Tuesday, 9 February 2016 Tuesday, 9 February 2016 Date 71595 71597 Ref no Transaction BUY BUY 20000000 Particular 10870000 shares 0 MAB shares 0 MA 2,614,950.00 1,421,225.33 Amount

February 2016 Friday, 12 352 02/12/2016 Friday, 12 February 2016 Friday, 12 February 2016 Friday, 12 February 2016 Friday, 12 February 2016 Net Payable Amount Date 71676 71678 71673 78706 Ref no. Transaction SELL BUY BUY BUY 360000 LC PLC shares Particular 60000 LC 50000000 PA shares 1000000 shares shares 1,709,775.00 4,036,175.3 116,039.03 825,499.47 Amount 19,314.88 3

February 2016 Monday, 15 353 (02/17/2016 Monday, 15 February 2016 Monday, 15 February 2016 Monday,15 February 2016 Monday,15 February 2016 Monday, 15 February 2016 Monday, 15 February 2016 Net Payable Amount Date 78727 716 9 71702 78720 78724 71705 Ref nO. Transaction SELL SELL SELL BUY BUY BUY PLC shares Particular PLC shares 25000000 11000000 Lc shares 50000000 PA shares 2196000 4000000 LC shares 4160000 shares LCB 8,272,293.74 1,421,728.20 3,577,261.66 3,423,645.85 1,494.954.60 1,921,598.33 2,438,550.3 Amount

Wednesday, 17 (02/18/2016) Net Payable Amount 6,431,084.8 2

February 2016 February 2016 Friday, 19 355 354 Friday, 19 February 2016 02/22/2016 Friday, 19 February 2016 Friday, 19 February 2016 Friday, 19 February 2016 Wednesday, 17 February Wednesday, 17 February Wednesday, 17 February Net Payable Amount 2016 2016 2016 Date Date 78825 78836 71797 71800 71752 71760 78785 Ref no Ref o. Transaction Transaction SELL SELL BUY BUY SELL BUY BUY 15000000 30000000 Particular 11340000 LC shares Particular 15000000 PLC shares PLC shares LC shares 2680000 LC shares 3000000 3701000 LC shares shares LC S 2,591,948.51 3,951,893.49 4,674,206.25 4,701,881.25 9,956,925.00 3,002,729.89 4,291,099.8 835,124.85 Amount Amount

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Friday,19 February 2016 78839 SELL 5000000 shares LCB 1,582,800.00

February 2016 Monday, 29 356 Monday, 29 February 2016 Monday, 29 February 2016 Monday, 29 February 2016 Monday,29 February 2016 Monday, 29 February 2016 Monday, 29 February 2016 Monday, 29 February 2016 (02/24/2016 Monday, 29 February 2016 Monday, 29 February 2016 Monday, 29 February 2016 Monday, 29 February 20i6 Net Payable Amount Date 78943 71874 55323 37434 55320 55322 55317 55318 55319 55321 37433 Ref O Transaction SELL CD BUY C CN CN CN CN CN CM CM 10000000 IS shares Particular 30000 IS Dividend Payment Payment Balance Dividend Payment Payment Payment Balance shares Payment Payment Balance Balance Of Net Of Net Balance of Net Oof Net Credit Credit Balance Balance Of Net Credit Credit of Net of Net Credit Credit Credit Cash Cash 2,313,225.00 6,816,687.3 162,720.74 400,000.00 400,000.00 400,000.00 400,000.00 400,000.00 400,000.00 Amount 7,349.38 246.81 13.50 0

(03/03/2016) Due Clearing 4,868,336.0 5

(03/03/2016 Cr. As of Settlement Date 2,539,608.6

March 2016 Tuesday, 1 357 (03/03/2016 Net Payable Amount 2,328,727.4

Wednesday, 2 Thursday, 3 March 2016 358 (03/07/2016 Net Payable Amount (03/04/2016 Wednesday, 2 March 2016 Net Payable Amount Tuesday, 1 March 2016 Date Date 71929 71899 Ref Ref O Do Transaction Transaction BUY BUY PLC shares Particular Particular 5000000 1000000 IS shares S 4,626,450.00 4,626,450.0 218,499.19 218,499.19 Amount Amount 0

March 2016 359

Date Ref no Transaction Particular Amount

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Thursday, 3 March 2016 71963 BUY ION shares 1500000 4.140.944.32

March 2016 Tuesday, 360 (03/08/2016 Tuesday, 8 March 2016 Net Payable Amount Tuesday, 8 March 2016 Date 72088 72101 Ref DO Transaction BUY BUY Particular 4000000 500000 shares DAVIN shares VITA G 3,479,895.00 2,832,192.00 4,140,944.3 Amount

(03/11/2016 Due Clearing 6,312,087.0

(03/11/2016) Cr. As of Settlement Date 2,361,850.6

Monday, 14 March 2016 361 (03/11/2016) Monday, 14 March 2016 Net Payable Amount Date 72220 Ref no. Transaction BUY Particular 300000 DAVIN shares 1,810,350.00 3,950,236.4 Amount

Monday, 28 Thursday, 17 Monday, 21 March 2016 March 2016 363 362 (03/28/2016) Monday, 21 March 2016 (03/22/2016 Monday, 21 March 2016 Net Payable Amount Net Payable Amount (03/17/2016 Thursday, 17 March 2016 Thursday,17 March 2016 Thursday, 17 March 2016 Net Payable Amount Date Date 723 69 72370 72319 72322 79416 Ref nO Ref no. Transaction Transaction SELL BUY BUY BUY BUY Particular 10000000 Particular 940000 560000 5000000 IS shares 350000 shares DAVIN shares shares shares PXP 0 QV PXP S 2,453,396.40 1,520,694.00 2,205,681.25 3,974,090.4 1,433,193.75 1,307,475.00 534,987.50 1,810,350.0 Amount Amount 0 2

March 2016 364

(03/31/2016 Monday, 28 March 2016 Monday, 28 March 2016 Due Clearing Date 72447 72446 Ref no. Transaction BUY BUY 2000000 1000000 IS shares Particular shares BRN 2,151,832.29 2,438,471.0 286,638.75 Amount

Cr. As of Settlement Date (03/31/2016 1,135,540.0

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Tuesday, 29 March 2016 365 Tuesday, 29 March 2016 (03/31/2016) Tuesday, 29 March 2016 Tuesday, 29 March 2016 Tuesday, 29 March 2016 Net Payable Amount Date 72453 72485 72491 72484 Ref no. Transaction BUY BUY BUY BUY 23000000 Particular IS shares 2214000 53300 shares 36600 APC shares BCB shares BCB 6,664,652.66 1,358,305.59 609,808.36 403,040.22 302.930.9 Amount

Monday, 4 April 2016 3 66 (04/01/2016) Monday, 4 April 2016 Net Payable Amount Date 72624 Ref no. Transaction BUY Particular 4362000 STI shares 2,845,488.00 9,035,806.8 Amount

Thursday, ? April 2016 Tuesday, 5 April 2016 368 367 (04/08/2016 Net Payable Amount Tuesday, 5 April 2016 (04/07/2016 Tuesday, 5 April 2016 Tuesday, 5 April 2016 Net Payable Amount Tuesday, 5 April 2016 Date 797 0 79814 72651 72646 Ref o Transaction SELL BUY SELL BUY ISM shares Particular 2000000 iS shares 5000000 5000000 3000000 shares shares NOW NOW 9,271,164.40 1,568,752.66 4,901,743.62 3,086,988.71 5,887,656.8 2,845,488.0 Amount

Monday, 11 (04/12/2016) Thursday, 7 April 2016 Net Payable Amount Thursday, 7 April 2016 Thursday, 7 April 2016 Thursday, 7 April 2016 Thursday, 7 April 2016 Date 79875 79859 79842 72701 79841 Ref no. Transaction SELL SELL SELL SELL BUY ISM shares Particular 3000000 IS shares 3000000 1334000 537000 463000 shares NOW shares NOW shares NOW 1,901,823.25 6,487,087.50 1,882,633.2 920,002.50 956,209.05 826,419.44 Amount 16 April 2016 3 69 Monday, 11 April 2016 Date 72740 Ref no Transaction BUY Particular 8480000 shares ATN 2,889,771.18 Amount

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Thursday, 14 April 2016 30 (04/14/2016) Thursday, 14 April 2016 Thursday, 14 April 2016 Net Payable Amount Monday, 11 April 2016 Monday, 11 April 2016 Monday, 11 April 2016 Monday,11 April 2016 Monday, 11 April 2016 Date 72808 80029 79932 79916 79 24 Ref 72751 72745 O Transaction SELL BUY SELL SELL SELL BUY BUY Particular [SM shares STI shares 1000000 1308000 4000000 666000 NOW 1000000 2000000 639000 VITA shares shares shares W shares shares VITA BRN 4,827,600.00 2,277,481.03 2,413,800.00 1,653,764.80 1,080,498.43 3,856,027.3 1,218,568.03 802,242.18 Amount

Wednesday, 20 04/19/2016 Net Payable Amount 2,550,118.9 7

Friday, 22 April April 2016 2016 3 72 3 71 (04/25/2016 Net Payable Amount Wednesday. 20 April 2016 Date 72891 Ref nO Transaction BY Particular 1110000 IS shares 351,660.49 351,660.49 Amount

Wednesday, 27 Monday, 25 April 2016 3 73 04/28/2016 Monday, 25 April 2016 Monday, 25 April 2016 Net Payable Amount (04/27/2016 Monday, 25 April 2016 Monday, 25 April 2016 Net Payable Amount Friday, 22 April 2016 Friday, 22 April 2016 Friday, 22 April 2016 Friday, 22 April 2016 Date Date 80274 80243 73001 73000 80209 80203 72955 Ref 72948 mO nO Ref Transaction Transaction SELL SELL BUY BUY SELL SELL BUY BUY SLI shares 1000000 Particular 7000000 1100000 Particular 375000 1577000 shares NOW shares 2298000 1298000 NOW shares ARA 500000 shares shares share: VITA NOW shares NOW NOW 3,363,450.00 1,264,261.50 5,952,949.4 7,195,849.58 3,384,811.40 7,968,758.42 4,383,564.60 1,700,451.50 1,755,777.99 3,640,520.3 Amount Amount R

April 2016 374

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Thursday, 28 April 2016 375 (05/02/2016) Net Payable Amount Wednesday, 27 April 2016 Wednesday, 27 April 2016 Wednesday, 27 April 2016 Date 73059 80329 80322 Ref nO Transaction SELL SELL BUY 13810000 Particular 20000000 IS shares IS shares 755000 shares NOW 2,509,529.40 7,593,412.51 4 832,041.08 251,842.03 Amount

Thursday, 28 April 2016 Date 73081 Ref DO. Transaction BUY Particular 5000000 shares ATN S 1,985,199.64 Amount

Thursday, 28 April 2016 Thursday, 28 April 2016 Thursday, 28 April 2016 Thursday, 28 April 2016 8034 80355 80362 73090 SELL SELL SELL BUY 10000000 30000000 IS shares IS shares IS shares 5130000 238000 shares NOW 3,957,000.00 2,004,566.73 11,968,425.0 753,412.80

Wednesday, 4 (05/03/2016 Net Payable Amount 7,238,645.1 2

May 2016 376 Wednesday, 4 May 2016 Date 73169 Ref nO Transaction BUY Particular 12620000 ATN shares 6,317,216.32 Amount

Thursday, 5 May 2016 377 05/10/2016 Net Payable Amount 6,317,216.3

Tuesday, 10 05/11/2016 Thursday, 5 May 2016 Thursday, 5 May 2016 Thursday, 5 May 2016 Thursday, 5 May 2016 Net Payable Amount Thursday, 5 May 2016 Date 80471 73198 73201 73205 8049 Ref no. Transaction SELL SELL BUY BUY BUY Particular 3040000 IS shares 3040000 IS shares 6960000 IS shares 6000000 3000000 ATN shares shares ATN 2,590,007.40 1,448,280.00 2,730,963.12 1,112,708.40 1,325,883.4 1,131,267.60 Amount 8

May 2016 378

Wednesday, 11 May 2016 3 19 05/13/2016 Tuesday, 10 May 2016 Tuesday, 10 May 2016 Net Payable Amount Tuesday,10 May 2016 Date 80512 73234 73226 Ref O. Transaction SELL BY BUY Particular IS shares 3560000 IS shares 4330000 20000 PGOLD shares 1,524,434.24 1,271,066.85 573,359.11 826,726.50 Amount

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Wednesday, 11 May 2016 Date 73253 Ref no. Transaction BUY Particular 2000000 ACR shares 3,379,320.00 Amount

Thursday,12 May 2016 380 (05/16/2016 Wednesday, 11 May:2016 Wednesday, 11 May 2016 Wednesday, 11 May 2016 Wednesday, 11 May 2016 Net Payable Amount 80553 80526 80537 73255 SELL SELL SELL BUY 25000000 30000000 IS shares IS shares 1548000 452000 shares shares ACR ACR 9,190,132.50 2,526,742.35 2,490,787.4 11,566,125.0 737,782.66 0

Tuesday, 17 May 2016 3 81 05/20/2016) Tuesday, 17 May 2016 Tuesday, 17 May 2016 Due Clearing (05/17/2016 Thursday, 12 May 2016 Thursday, 12 May 2016 Net Payable Amount Thursday, 12 May 2016 Date Date 73346 7377 73290 80563 80565 Ref nO Ref no Transaction Transaction BUY BUY SELL SELL BUY Particular 12010000 14060000 Particular 500000 30000 PGOLD sh ares 900000 shares PXP ATNB shares shares ATN share ATN 1,267,245.00 2,459,370.54 3,726,615.5 6,237,518.03 7,356,357.22 673,676.69 Amount 445,162.50 Amount

Wednesday, 18 May 2016 3 82 (05/20/2016 Net Payable Amount (05/20/2016 Cr. As of Settlement Date 2,263,613.3 1,463,002.1 S

Friday, 20 May 2016 383 (05/23/2016) Net Payable Amount Wednesday, 18 May 2016 Wednesday, 18 May 2016 Wednesday, 18 May 2016 Date 73419 73425 3 9018 Ref nO Transaction BUY BUY CM 1225000 T LC shares Particular 30000000 Dividend shares Cash S 9,328,331.25 3,741,379.96 12,938,923. 130,787.72 Amount 4

Friday, 20 May 2016 Friday, 20 May 2016 Date 73470 73480 Ref no. Transaction BUY BUY Particular 1961400 shares shares 40900 ALT ALT C 10,284,306.7 266,520.51 Amount

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Friday, 20 May 2016 Friday,20 May 2016 80821 73481 SELL BUY 1000000 shares 38600 shares ALT ALT 3,862,763.03 258,165.97

Tuesday, 24 May 2016 384 (05/25/2016) Tuesdav, 24 May 2016 Net Payable Amount Date 73509 nO Ref Transaction BUY Particular 2000000 shares ACR S 3,967,723.98 6,946,230.1 Amount 5

Thursday, 26 Thursday, 2 June 2016 May 2016 3 86 385 (05/31/2016 Thursday, 2 June 2016 05/27/2016) Net Payable Amount Thursday, 26 May 2016 Net Payable Amount Thursday, 26 May 2016 Date Date 73643 73553 735 55 Ref Ref no. no Transaction Transaction BUY BUY BUY Particular Particular 11000000 4000000 600000 shares shares PHA shares ATN ALT 5,642,659.80 2,625,007.50 1,543,323.37 3,967,723.9 4,168,330.8 Amount Amount O

Monday, 6 June Thursday, 9 June 2016 2016 388 387 (06/09/2016 (06/07/2016 Monday,6 June 2016 Net Payable Amount Monday,6 June 2016 Monday,6 June 2016] Net Payable Amount Date Date 81068 81076 73659 Ref Ref o nO. Transaction Transaction SELL SELL BUY Particular Particular PLC shares 3000000 4190000 480000 shares shares PHA PHA S 1,818,439.36 3,318,975.00 1,286,857.6 5,642,659.8 Amount 213,678.00 Amount

Thursday, 9 June 2016 73712 BUY DD shares 300000 22,467,635.3 A

Friday, 10 June 2016 3 89 (06/14/2016) Thursday, 9 June 2016 Thursday, 9 June 2016 Net Payable Amount 81147 81146 SELL SELL 53000 DD DD shares 197000 shares 3,976,456.07 13,972,916.3 4,518,262.9

Date Ref O Transaction Particular Amount

Page 146 of 216]

Monday, 13 June 2016 3 0 (06/15/2016 Net Payable Amount Friday, 10 June 2016 Friday, 10 June 2016 81161 73732 SELL BUY DD shares DD shares 100000 100000 6,702,168.74 6,939,675.00 237,506.26

Wednesday, 15 June 2016 3 91 (06/16/2016) Net Payable Amount Monday, 13 June 2016 Monday, 13June 2016 Monday,13June 2016 Monday, 13 June 2016 Monday, 13 June 2016 Monday, 13 June 2016 Monday, 13 June 2016 Date 81174 81183 73751 81167 73749 73750 73746 Ref nO Transaction SELL SELL SELL BUY BUY BUY BUY 50000 DD 36950 DD Particular 1300000 1000000 shares NOW 31000 shares shares 565000 766000 shares shares NOW shares NOW NOW shares NOW 3,748,367.18 2,309,081.32 2,147,169.57 3,294,229.54 1,675,318.00 3,017,250.00 4,310,795.1 Amount 89,546.92

Tuesday, 21 June 2016 3 2 (06/20/2016 Wednesday, 15 June 2016 Wednesday, 15 June 2016 Wednesday, 15 June 2016 Net Payable Amount Wednesday,15June 2016 Wednesday, 15 June 2016 Wednesday,15 June 2016 Wednesday, 15 June 2016 Date 81220 81227 81231 81233 81215 73784 73777 Ref no. Transaction SELL SELL SEL SELL SELL BUY BUY 130000 IS Particular 25000000 5000000 130000 IS 2000000 180600 CYBR shares 450000 shares shares shares shares shares CYBR shares PXP CYBR APC G 2,967,750.00 10,676,481. 16,015,261.2 1,206,885.00 271,549.13 893,292.75 41,795.80 Amount 42,492.95 55 8

Thursday, 23 June '2016 393 (06/24/2016) Tuesday, 21 June 2016 Net Payable Amount Tuesday, 21 June 2016 Date Date 73860 73861 Ref nO o Ref Transaction Transaction BUY BUY Particular Particular 816000 129000 shares ALT shares ALT 3,380,104.51 3,930,652.0 550,547.57 Amount Amount D

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Thursday, 23 June 2016 Thursday,23 June 2016 81376 73909 SELL BUY 11550000 270000 shares shares ALT ATN 4,594,517.44 1,041,779.17

Tuesday, 28 June 2016 3 94 (06/28/2016) Tuesday, 28 June 2016 Tuesday, 28 June 2016 Tuesday, 28 June 2016 Tuesday, 28 June 2016 Net Payable Amount Date 73982 73 983 73984 73985 Ref RG Transaction BUY BUY BUY BUY Particular 1507000 T 873000 T 1162000 138000 shares shares shares shares APX APX S 4,634,274.73 3,183,701.65 1,886,515.46 3,552,738.2 582,480.12 Amount

Due Clearing (07/01/2016 10,286,971. 96 Cr. As of Settlement Date (07/01/2016 1,867,578.2

Thursday, 30 June 2016 395 (07/01/2016 Thursday, 30 June 2016 Net Payable Amount Date 74026 Ref nO Transaction BUY Particular 286400 HVN shares 6,335,420.40 8,419,393.7 Amount

Tuesday, 5 July 2016 3 96 (07/05/2016) Net Payable Amount 6,335,420.4 0

Friday, 8 july 2016 3 97 (07/11/2016 Net Payable Amount Tuesday, 5 July 2016 Tuesday, 5 July 2016 Date 81635 74085 Ref Do. Transaction SELL BUY Particular 1000000 1000000 NOW shares NOW shares 3,942,540.00 3,562,813.54 379,726.46 Amount

Friday,8 July 2016 Fridav,8 July 2016 Friday,8 July 2016 Friday,8 July 2016 Friday,8 July 2016 Friday, 8 July 2016 Date 74121 74124 74125 81692 74114 74115 Ref no. Transaction SELL BUY BUY BUY BUY BUY Particular 8000000 5000000 1931000 1069000 184000 816000 shares VITA shares shares shares APO shares shares VITA VUL APO VUL 8,317,552.50 4,946,249.99 2,819,620.12 1,607,540.52 1,229,046.61 268,655.94 Amount

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Wednesday, 13 July 2016 3 8 07/13/2016 (07/18/2016) Wednesday, 13 July 2016 Wednesday, 13 July 2016 Due Clearing Net Payable Amount Date 74198 74197 O Ref Transaction BY BUY Particular 888000 77900 shares shares PXP PXP 5,089,265.98 4,377,526.90 9,466,792.8 9,296,165.7 Amount

(07/18/2016) Cr. As of Settlement Date 2,191,714.0

Wednesday, 20 Thursday, 28 Thursday, 14 July 2016 July 2016 July 2016 401 40 399 (07/25/2016) (07/19/2016) Wednesday, 20 July 2016 Net Payable Amount Wednesday, 20 July 2016 Thursday, 14 July 2016 Thursday, 14 July 2016 Net Payable Amount (07/18/2016 Thursday, 14 July 2016 Thursday, 14 July 2016 Net Payable Amount Date Date 81978 74302 81843 8130 74229 74215 Ref nO Ref nO Transaction Transaction SELL BUY SELL SELL BUY BUY Particular Particular 910700 910700 1000000 shares 300000 500000 300000 shares shares ALT ALT shares shares ALT PXP PXP ALT hares 7,327,492.20 7,279,973.85 6,135,075.00 1,581,835.57 2,819,907.57 1,391,704.61 3,505,298.3 7,275,078.8 Amount 47,518.35 Amount

(08/02/2016) Thursday, 28 July 2016 (08/02/2016 Cr. As of Settlement Date Due Clearing Date 74492 Ref DO Transaction BUY Particular IDC shares 700000 2,307,477.3 4,021,042.83 4,021,042.8 Amount 2

Friday, 29 July 2016 402 08/02/2016 Net Payable Amount 4,021,042.8

Friday; 29 July 2016 Date 74526 Ref no. Transaction BUY BHI shares Particular 50000000 5,971,650.69 Amount

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August 2016 Tuesday, 2 403 08/03/2016) Net Payable Amount 5,971,650.6

Friday, 5 (08/05/2016 Net Payable Amount Tuesday, 2 August 2016 Tuesday, 2 August 2016 Tuesday, 2 August 2016 Tuesday, 2 August 2016 Tuesday, 2 August 2016 Date 82230 82240 82241 74559 74558 Ref no. Transaction SELL SELL SELL BUY BUY 20000000 20000000 Particular BHI shares BHI shares 3250000 5000000 5000000 shares MRC shares MRC shares MRC C 2,359,871.67 2,816,100.00 3,478,942.9 677,111.94 672,690.00 347.226.75 Amount 8 August 2016 404 Friday, 5 August 2016 Friday, 5 August 2016 Friday, 5 August 2016 Friday, 5 August 2016 Date 82286 74611 74619 82292 Ref no. Transaction SELL SELL BUY BUY BHI shares Particular BHI shares 6190000 20000000 7350000 3000000 shares shares MRC VITA S 2,112,075.00 4,978,462.50 1,013,387.70 630,716.12 Amount

Monday, 15 (08/10/2016 Net Payable Amount 5,446,433.6 D August 2016 405

Date Ref nO Transaction Particular S Amount

(08/18/2016) 08/18/2016 Cr. As of Settlement Date Monday, 15 August 2016 Due Clearing Monday, 15 August 2016 Monday, 15 August 2016 Monday, 15 August 2016 Monday, 15 August 2016 Monday, 15 August 2016 Monday, 15 August 2016 74745 74759 56887 56886 56883 56884 56885 BUY BUY CID CN C C CN 5000 FPH 3000000 Payment Balance Payment Payment Payment Balance Payment Balance Balance shares Balance Of Net Of Net Credit VITA shares of Net Of Net Credit Credit Of Net Credit Credit 5,943,982.50 8,130,422.6 918,340.30 229,549.80 356,890.39 400,000.00 400,000.00 400,000.00 400,000.00 O

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August 2016 Thursday, 18 August 2016 Tuesday, 23 August 2016 Monday, 22 August 2016 Tuesday, 16 407 408 49 40 (08/25/2016 Tuesday, 23 August 2016 (08/19/2016) (08/23/2016) Net Payable Amount Thursday, 18 August 2016 Monday, 22 August 2016 (08 18/2016) Tuesday, 16 August 2016 Net Payable Amount Thursday, 18 August 2016 Tuesday, 16 August 2016 Tuesday, 16 August 2016 Net Payable Amount Net Payable Amount Date Date Date Date 74904 82465 74825 82528 74856 74775 74776 Ref Ref Ref DO. no. Ret O no. Transaction Transaction Transaction Transaction SELL BUY SELL BUY BUY BUY BUY Particular Particular IMI shares 5000 FPH Particular 1000000 Particular 1787000 1000000 500000 shares shares TUGS 363000 637000 shares shares VITA NOW NOW shares NOW shares S S 1,709,775.00 4,019,221.40 3,641,646.89 3,810,788.86 1,450,291.51 2,564,883.76 377,574.51 370,116.00 7,212,082.3 204,386.41 370,116.00 Amount Amount Amount Amount

Wednesday, 24 August 2016 410 Wednesday, 24 August Wednesday, 24 August Wednesday, 24 August (08/26/2016) 2016 Net Payable Amount 2016 2016 Date 74912 74926 82640 Ref no. Transaction SELL BUY BUY Particular LR shares 200000 800000 113000 shares shares TUGS CAL S 3,186,065.15 1,709,775.0 178,856.40 719,111.25 Amount

Thursday, 25 August 2016 411 08/30/2016 Thursday, 25 August 2016 Thursday, 25 August 2016 08/31/2016 Thursday, 25 August 2016 Net Payable Amount Net Payable Amount Date 82660 82669 749 68 Ref no. Transaction SELL SELL BUY Particular LR shares 750000 800000 396000 shares TUGS shares CAL S 3,899,795.62 2,525,822.34 3,726,320.0 746,086.43 627,886.85 Amount

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Wednesday, 31 August 2016 August 2016 Tuesday, 30 413 412 Wednesday, 31 August (09/02/2016) Wednesday, 31 August Wednesday, 31 August 2016 Tuesday, 30 August 2016 2016 Tuesday, 30 August 2016 Tuesdav, 30 August 2016 Net Payable Amount 2016 Date Date 82721 82729 75040 82765 75016 9 288 Ref nO Ref nO. Transaction Transaction SELL SELL SELL BUY DM BUY Particular Particular IMI shares 3000000 1000000 4000000 400000 Interest shares VITA shares NOW shares 75000 NOW shares VITA S 3,867,108.75 2,621,887.40 8,814,217.50 12,277,431.6 841,326.74 284,904.00 226,966.70 Amount Amount

September Friday, 2 2016 414 (09/05/2016) Friday, 2 September 2016 Net Payable Amount Date 75103 LO Ref Transaction BUY Particular 5000000 MED shares 0 6,798,870.00 3,809,171.4 Amount

Thursday, 15 September September Monday, 5 2016 2016 416 415 (09/08/2016) Net Payable Amount (09/07/2016 Monday, 5 Septermber 2016 Monday, 5 September 2016 Net Payable Amount Date 75122 75130 Ref no. Transaction BUY BUY Particular 500000 50000 shares CAL shares NOW 2,110,898.28 2,297,967.7 6,798,870.0 187,069.50 Amount R

Thursday, 15 September Thursday, 15 September 2016 2016 Date 75218 75220 Ref no. Transaction BUY BUY Particular 12000000 1096000 shares shares MRC PXP 2,268,972.00 3,687,954.51 Amount

(09/20/2016 Due Clearing 5,956,926.5

(09/20/2016 Cr. As of Settlement Date 2,691,976.8

(09/20/2016 Net Payable Amount 3,264,949.6

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Thursday, 22 Septermber 2016 417 Thursday, 22 September 2016 Date 75291 Ref nO Transaction BUY Particular 20000000 shares MRC 4,958,347.51 Amount

Tuesday, 27 September September Friday, 23 2016 2016 418 419 (09/27/2016 Friday, 23 September 2016 Friday, 23 September 2016 (09/28/2016 Tuesday, 27 September Tuesday, 27 September Net Payable Amount Net Payable Amount 2016 2016 Date Date 75342 75306 83113 75333 Ref no. Ref no. Transaction Transaction BUY BUY SELL BUY FNI shares Particular Particular 20000000 15000000 6000000 1096000 shares MRC shares MRC shares PXP S 5,642,257.50 3,590,497.33 4,405,637.59 3,566,839.81 4,958,347.5 23,657.52 Amount Amount

Due Clearing (09/30/2016 10,047,895. 09 Cr. As of Settlement Date (09/30/2016 1,199,604.9

September Friday, 30 2016 4.20 (09/30/2016 Friday, 30 September 2016 Friday, 30 September 2016 Net Payable Amount Date 75378 83226 Ref To. Transaction SELL BUY 10000000 Particular 20000000 shares shares MRC MRC 2,252,274.93 4,716,967.50 8,848,290.1 Amount

October 2016 Monday, 3 421 Monday, 3 October 2016 10/05/2016 Monday, 3 October 2016 Monday. 3 October 2016 Monday, 3 October 2016 Net Payable Amount Date 75 399 83236 75397 83240 Ref n Transaction SELL SELL BUY BUY FNI shares Particular FNI shares 10000000 5000000 5000000 1000000 shares shares MRC PXP S 5,516.096.23 5,356,699.73 2,157,702.62 3,969,675.16 2,464,692.5 Amount

Wednesday, 5 October 2016 422 (10/06/2016 Net Payable Amount 1,971,369.0

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October 2016 Monday, 17 423 Net Payable Amount (10/10/2016) Wednesday, 5 October Wednesday, 5 October 2016 2016 Monday, 17 October 2016 Date Date 83 270 755 46 75428 Ref Ref no. Do. Transaction Transaction BUY SELL BUY Particular Particular 8773000 6000000 293000 shares shares MED shares PXP MRC 8.245,440.24 1,265,474.88 1,101,628.81 163,846.07 Amount Amount

Due Clearing (10/20/2016 8,245,440.2

(10/20/2016 Cr. As of Settlement Date 2,751,994.5

Thursday, 27 October 2016 424 (10/20/2016) Net Payable Amount Thursday,27 October 2016 Date 75655 nO Ref Transaction BUY Particular 5000000 shares LHC 5,159,145.51 5,493,445.6 Amount

Wednesday, 9 November 2016 425 (11/03/2016 Net Payable Amount Date Ref no. Transaction Particular G 5,159,145.5 Amount

Wednesday, 9 November Wednesday, 9 November 2016 Wednesday, 9 November 2016 2016 75751 75754 83731 SELL BUY BUY FNI shares 21593000 7000000 200000 shares SHLPH shares CPG 9,594,855.00 13,850,637.6 15,051,451.0

(11/14/2016) Due Clearing 10,795,668. 43

(11/14/2016) Cr. As of Settlement Date 4,280,468.7

Thursday, 10 November 2016 426 (11/14/2016) Thursday, 10 November 2016 Net Payable Amount Date 75778 Ref no. Transaction BUY Particular 8407000 shares CPG 5,495,971.16 6,515,199.6 Amount

Tuesday, 15 November 2016 427 11/15/2016 Net Payable Amount Date Ref no Transaction Particular S 5,495,971.1 Amount 6

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2016 Tuesday, 15 November Tuesday, 15 November 2016 83798 75828 SELL BUY 5000000 4513000 shares LHC shares CPG 5,798,148.77 2,819,362.50

Friday, 18 November 2016 428 (11/18/2016 Net Payable Amount Friday,18 Novemher 2016 Date 75 878 no. Ref Transaction BUY Particular 5000000 ALCO shares C 1,753,726.28 2,978,786.2 Amount T

Monday, 28 November 2016 429 (11/23/2016 2016 2016 Net Payable Amount Monday, 28 November 2016 Monday, 28 November Monday, 28 November Date 84 29 76022 76023 Ref O. Transaction BUY SELL BUY Particular 2033000 2000000 300000 LIHC LIHG shares shares shares WEB 3,414,752.59 4,520,836.19 3,379,050.47 1,753,726.2 Amount R

December Friday, 2 2016 430 (12/02/2016 Friday, 2 December 2016 Friday, 2 December 2016 Net Payable Amount Friday, 2 December 2016 Date 76092 76102 84136 Ref O Transaction SELL BUY BUY Particular 2000000 444900 100000 SHLPH shares shares shares LHC WEB 2,926,732.50 6,164,931.69 6,727,138.89 4,556,538.3 Amount

Due Clearing (12/07/2016) 2,364,525.3 0

(12/07/2016 Cr. As of Settlement Date 4,092,151.1

Tuesday, 6 December 2016 431 12/07/2016 Net Payable Amount Date Ref MO Transaction Particular G 1,727,625.8 Amount

Tuesday, 6 December 2016 Tuesday, 6 December 2016 Tuesday, 6 December 2016 579 29 57931 579 30 C CN CN Payment Payment Payment Balance Balance of Net of Net of Net Credit Credit 450,000.00 450,000.00 450,000.00

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Tuesday, 6 December 2016 Tuesday, 6 December 2016 Tuesday, 6 December 2016 Tuesday, 6 December 2016 Tuesday, 6 December 2016 Tuesday,6 December 2016 Tuesday, 6 December 2016 Tuesday, 6 December 2016 76136 57935 57936 57937 76139 57932 57933 57934 BUY BUY CN CV CN CN C C EW shares Payment Balance Payment 250000 Payment Payment Payment Payment Balance Of Net Balance 656000 Balance Balance Balance Balance of Net shares of Net Of Net Credit Of Net of Net Credit Credit Credit Credit Credit LIHC Credit 4,777,312.50 956,669.40 450,000.00 492,151.10 450,000.00 450,000.00 450,000.00 450,000.00

(12/09/2016) Due Clearing 9,826,133.0 0

(12/09/2016 Cr. As of Settlement Date 2,174,151.2

Thursday, 8 December 2016 432 12/09/2016) Net Payable Amount 7,651,981.7

Thursday, 8 December Thursday, 8 December Thursday, 8 December 2016 2016 2016 Date 84247 76183 84262 O Ref Transaction SELL BUY SELL Particular 30000000 100000 SHLPH SHLPH ALCO 82360 shares shares shares S 5,519,906.19 6,677,437.50 13,275,900.0 Amount

Monday, 12 December 2016 43 (12/13/2016 Net Payable Amount 1,078,556.3

Thursday, 15 December 2016 434 Net Payable Amount (12/15/2016) Monday. 12 December 2016 Monday, 12 December 2016 Monday, 12 December 2016 Date 76229 76235 84299 no. Ref Transaction SELL BUY BUY 61000000 Particular 500000 500000 SHLPH shares shares O APL shares LIHC 33,694,659.2 33,345,641.2 334,922.20 683,940.19 Amount 3

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Thursday, 15 December Thursday, 15 December Thursday, 15 December 2016 2016 2016 Date 843 56 84366 76293 Ref no. Transaction SELL SELL BUY Particutar 1000000 4500000 750000 shares PIZZA shares shares PIZZA ALCO 2,199,795.21 8,977,443.74 12,267,697.9 Amount

Wednesday, 21 December 2016 435 Wednesday, 21 December Wednesday, 21 December 2016 Wednesday, 21 December 2016 Wednesday, 21 December 2016 2016 Wednesday, 21 December 2016 2016 Wednesday, 21 December Net Payable Amount (12/20/2016 Date 58067 76393 76396 58065 58066 58064 Ref mO. Transaction C CN BUY BUY C/V C/ Particular 2000000 Payment Payment Payment Payment Balance Balance Balance Balance 210000 of Net Of Net Of Net Credit Of Net Credit Credit shares WEB shares Credit LHC S 2,471,127.75 2,398,713.75 1,090,459.0 489,549.24 475,000.00 475,000.00 475,000.00 Amount

Due Clearing (12/27/2016) 6,784,390.7

(12/27/2016) Cr. As of Settlement Date 5,314,090.0

Tuesday, 27 December 2016 436 (12/27/2016 Net Payable Amount 1,470,300.7 0

2016 Tuesday, 27 December Date 76459 Ref no Transaction BUY Particular 2000000 TUGS shares 5,613,342.19 Amount

01/03/2017 (01/03/2017) Due Clearing Cr. As of Settlement Date 5,613,342.1 526,832.32 0

Wednesday, 28 01/03/2017 Net Payable Amount 5,086,509.8 T

December 2016 437 Wednesday, 28 December 2016 Date 76477 Ref nO. Transaction BUY Particular 2102000 LIHC shares S 2,486,455.37 Amount

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Thursday, 29 December 2016 438 (01/04/2017) Thursday, 29 Decemher Net Payable Amount 2016 Date 76486 Ref no. Transaction BUY Particular 1000000 shares LIHC S 1,146,555.00 2,486,455.3 Amount

(01/05/2017) Net Payable Amount 1,146,555.0

January 2017 Tuesday, 3 2017 439 Tuesday, 3 January 2017 Date 76511 no. Ref Transaction BUY Particular 4950000 ALCO shares 2,330,222.18 Amount

January 2017 Thursday, 5 440 (01/06/2017 Thursday, 5 January 2017 Thursday, 5 January 2017 Net Payable Amount Thursday, 5 January 2017 Date 76574 84648 84655 no. Ref Transaction SELL SELL BUY Particular 2000000 3960000 841000 shares shares NOW shares ALCO LIHC 5,723,683.04 1,828,678.09 1,146,555.0 973,392.32 Amount

January 2017 Monday, 9 441 (01/10/2017) Monday, 9 January 2017 Monday, 9 January 2017 Monday, 9 January 2017 Monday,9 January 2017 Net Payable Amount Monday, 9 January 2017 Monday 9 January 2017 Date 76662 84753 84765 76654 76661 84736 Ref no. Transaction SELL SELL SELL BUY BUY BUY Particular 15000000 10000000 2896600 1000000 500000 20000 NOW shares shares shares Shares shares shares ALCO WEB WEB LIHC O PA 3,705,186.40 2,711,741.99 8,096,287.50 5,547,767.30 2,309,650.56 4,797,862.50 2,921,612.6 Amount

01/12/2017 Cr. As of Settlement Date Due Clearing (01/12/2017 4,738,914.4 888,782.05

January 2017 Tuesday, 17 442 01/12/2017 Net Payable Amount 3,850,132.4

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Tuesday, 17 January 2017 Date 76797 Ref no Transaction BUY Particular 10000000 ALCO shares 7,844,850.01 Amount

Tuesday, 17January 2017 Tuesday,17January 2017 76802 84954 SELL BUY 10000000 STI shares 100000 SHLPH shares 7,369,912.50 10,912,387.5 0

January 2017 January 2017 Thursday, 19 Friday, 27 443 444 Friday, 27 January 2017 Friday, 27 January 2017 Friday, 27 January 2017 Friday, 27 January 2017 Friday, 27 January 2017 Friday,27January 2017 Friday, 27 January 2017 (01/24/2017 Friday,27[anuary 2017 Thursday, 19 January 2917 Net Payable Amount Friday, 27 January 2017 Friday, 27 January 2017 Friday; 27 January 2017 (01/20/2017) Thursday, 19 January 2017 Thursday, 19 [anuary 2017 Net Payable Amount Date Date 58374 58373 76968 58371 58372 583 68 58369 58370 58366 58367 58365 76841 84996 85000 Ref Ref no. no. Transaction Transaction CN CN CN BUY C C/ C SELL SELL CN CN CN CN BUY Particular Payment Payment Balance Payment Balance 800000 Particular STI shares Payment Payment Payment Payment Payment Balance Balance Balance of Net Credit shares 5000000 Payment Payment Balance Credit 5000000 4530000 Balance Balance Credit of Net Credit Of Net Of Net LMG Balance Balance of Net Credit of Net Credit af Net Credit Credit of Net Credit of Net Credit of Net shares shares ALC# APL S 3,620,700.00 5,530,729.89 4,303,237.50 475,000.00 475,000.00 475,000.00 475,000.00 981,020.75 475,000.00 475,000.00 11,387,325. 475,000.00 475,000.00 475,000.00 246,471.64 475,000.00 Amount Amount 01

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Due Clearing (02/01/2017 8,370,700.0 2

Cr. As of Settlement Date (02/01/2017 3,416,553.7

January 2017 Monday, 30 445 (02/01/2017 Monday, 30 January 2017 Net Payable Amount Date 769 86 Ref O Transaction BUY Particular 600000 LMG shares 2,579,748.75 4,954,146.2 Amount

January 2017 Tuesday, 31 46 (02/02/2017) Tuesday, 31January 2017 Tuesday, 31 January 2017 Net Payable Amount Tuesday, 31 January 2017 Date 769 98 8189 77005 Ref no. Transaction SELL BUY BUY Particular 50000000 96000 STI 300000 shares shares LMG shares APL 1,267,245.00 3,117,825.00 2,579,748.7 100,666.08 Amount

February 2017 Monday, 6 447 Monday,6 February 2017 Net Payable Amount 02/03/2017 Date 77142 Ref nO Transaction BUY Particular 9399000 shares RLT S 8,202,997.57 4,284,403.9 Amount

February 2017 Tuesday, 7 448 02/09/2017 Tuesday, 7 February 2017 Net Payable Amount Tuesday, 7 February 2017 Date 85363 77158 Ref no. Transaction BUY SELL Particular 2000000 9900000 shares shares CPG RLT 5,675,447.25 1,786,268.93 8,202,997.5 Amount

February 2017 Friday, 10 49 Friday, 10 February 2017 Friday,10 February 2017 Friday, 10 February 2017 Friday, 10 February 2017 02/10/2017 Friday, 10 February 2017 Net Payable Amount Date 77243 77252 85427 85430 77245 Ref no. Transaction SELL SELL BUY BUY BUY Particular 50000000 PA shares 5000000 3640000 358000 20000 PGOLD shares shares LIHC ALCO shares shares APL S 3,369,262.50 8,111,373.75 3,889,178.3 890,088.75 216,052.20 364,776.05 Amount

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February 2017 Tuesday, 14 450 (02/15/2017) Tuesday, 14 February 2017 Tuesday, 14 February 2017 Tuesday, 14 February 2017 Tuesday, 14 February 2017 Net Payable Amount Date 85490 88518 77288 77297 Ref no. Transaction SELL SELL BUY BUY Particular 50000000 29980000 29980000 9370000 shares shares shares APL shares APL APL APL 1,839,295.49 3,369,262.50 1,828,885.83 11,789,896. 565,425.62 Amount 75

Februar'y 2017 February 2017 Thursday, 16 Friday, 17 452 451 (02/21/2017) Friday, 17 February 2017 Thursday, 16 February Net Payable Amount Friday, 17 February 2017 Thursday, 16 February 2017 (02/17/2017 Thursday, 16 February Thursday, 16 February 2017 Net Payable Amount Thursday, 16 February 2017 2017 2017 Date Date 8552 77364 85585 77351 85548 77335 77350 Ref nO Ref nO. Transaction Transaction SELL SELL BUY SELL BUY BUY BUY Particular Particular 32370000 4000000 3766000 700000 300000 171300 328700 shares shares LIHC sh ares shares sh ares shares shares LMG LMG LHC LMG LMG APL S 5,109,332.70 3,959,027.96 1,997,602.42 3,811,966.06 2,039,661.00 2,643,352.37 234,108.98 2,814,246.5 1,360,664.09 Amount Amount

February 2017 Monday, 20 453 (02/22/2017) Monday, 20 February 2017 Monday, 20 February 2017 Net Payable Amount Date 77382 77383 nO Ref Transaction BUY BUY Particular 451000 549000 PSPC PSPC shares shares S 1,214,744.85 1,150,304.7 976,804.52 Amount

February 2017 Friday, 24 454 (02/23/2017) Net Payable Amount 2,191,549.3

Friday, 24 February 2017 Date 58598 Ref no. Transaction CN Particular Payment of Net S 485,000.00 Amount

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Friday, 24 February 2017 Friday, 24 February 2017 Friday, 24 February 2017 Friday, 24 February 2017 Fridav, 24 February 2017 Friday, 24 February 2017 Friday, 24 February 2017 Friday, 24 February 2017 58601 58602 77460 77470 85691 58600 77469 58599 SELL CN BUY BUY BUY C CN CN 2205000 3000000 4964000 Payment Payment Payment 795000 Payment Balance Balance Balance Balance of Net of Net Credit shares LIHC shares Balance of Net Credit Of Net Credit Credit shares shares APX Credit APX RLT 2,021,557.50 5,040,617.83 4,840,331.00 1,851,756.73 485,000.00 471,140.45 485,000.00 485,000.00

Due Clearing (03/01/2017 6,484,741.5 Y

(03/01/2017) Cr. As of Settlement Date 5,484,145.4

Thursday, 2 March 2017 455 03/01/2017 Thursday, 2 March 2017 Thursday, 2 March 2017 Thursday, 2 March 2017 Net Payable Amount Date 85771 77525 77534 Ref no. Transaction SELL BY BUY Particular 20000000 7000000 228900 shares shares DFNN shares O APL LIHC 7,599,527.33 1,956,837.49 14,734,237.5 1,000,596.0 Amount

(03/07/2017) Due Clearing 9,091,547.6 6

March 2017 Monday, 6 456 Monday, 6 March 2017 Monday,6 March 2017 Monday,6 March 2017 (03/07/2017 Cr. As of Settlement Date (03/07/2017) Net Payable Amount Date 58670 58669 58671 Ref no. Transaction C CN C Particular Payment Payment Payment Balance Balance Credit Balance of Net of Net of Net Credit Credit S 8,635,405.8 456,141.84 480,000.00 480,000.00 480,000.00 Amount 2

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Monday,6 March 2017 Monday,6 March 2017 Monday,6 March 2017 Monday, 6 March 2017 Monday,6 March 2017 Monday,6 March 2017 Monday,6 March 2017 Monday,6 March 2017 Monday,6 March 2017 58678 77567 77568 58677 58672 58673 58674 58675 58676 BUY CN BUY C/N CD CN C CN C Payment Payment Payment 818000 Payment Payment Balance Payment shares Balance Balance Payment Of Net Balance Balance Balance 182000 of Net Balance of Net Credit shares Credit of Net Credit Of Net Credit Credit Of Net Credit of Net Credit LMG LMG 1,451,459.17 6,581,502.30 480,000.00 480,000.00 480,000.00 480,000.00 480,000.00 480,000.00 480,000.00

(03/09/2017) Due Clearing (03/09/2017) Cr. As of Settlement Date 12,832,961 908,034.71 47

March 2017 Tuesday, 7 457 (03/09/2017 Net Payable Amount Tuesday, 7 March 2017 Tuesday, 7 March 2017 Date 77589 775 0 Ref no Transaction BUY BUY Particular 10000000 O APL ALCO shares shares 5000 5,783,062.50 11,924,926 Amount 8,063.19 76

Monday, 20 March 2017 458 Monday,20 March 2017 (03/10/2017) Net Payable Amount Monday, 20 March 2017 Monday,20 March 2017 Monday,20 March 2017 Date 58774 58773 58775 58772 Ref no. Transaction CD CN C CN Particular Payment Payment Payment Payment Balance Balance Balance Balance of Net Credit of Net Credit Credit Of Net of Net Credit S 5,791,125.6 485,000.00 485,000.00 485,000.00 485,000.00 Amount

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Monday, 20 March 2017] Monday; 20 March 2017 Monday, 20 March 2017 Monday,20 March 2017 Monday, 20 March 2017 Monday,20 March 2017 58780 58776 58777 58778 58779 77728 C CN CN CN CN BUY Payment Payment Payment Payment Payment Balance Balance Of Net Balance Balance 700000 of Net Credit of Net Credit Balance Of Net Credit of Net Credit Credit shares LMG 3,787,654.51 485,000.00 485,000.00 485,000.00 485,000.00 480,662.47

(03/23/2017 Due Clearing 8,148,316.9 8

(03/23/2017 Cr. As of Settlement Date 2,273,690.9 0

Tuesday, 21 March 2017 45 9 (03/23/2017) Tuesday, 21 March 2017 Net Payable Amount Date 77750 nO. Ref Transaction BUY Particular 30000000 shares MRC 6,416,926.39 5,874,625.9 Amount 9

Wednesday, 22 March 2017 460 (03/24/2017) Wednesday, 22 March 2017 Wednesday, 22 March 2017 Wednesday, 22 March 2017 Net Payable Amount Date 77758 77766 86040 Ref no. Transaction BUY SELL BUY Particular MG shares 14650000 3000000 268100 DFNN shares shares RLT 2,291,953.39 4,657,628.25 6,416,926.3 1,929,037.50 Amount 0

March 2017 April 2017 Monday, 3 Friday, 24 461 462 (03/29/2017) Monday, 3 April 2017 03/27/2017 Friday, 24 March 2017 Monday, 3 April 2017 Net Payable Amount Net Payable Amount Date Date 77789 77872 77879 Ref Ref O no. Transaction Transaction BUY BUY BUY Particular Particular 400000 shares 71200 shares DFNN CHIB 3000 shares 2G0 2,917,167.82 5,229,900.00 5,020,544.1 Amount 25,646.63 Amount 25,646.63

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Monday,3 April 2017 Monday,3 April 2017 86169 86171 SELL SELL 15000000 100000 shares shares LMG MRC 3,333,287.75 524,302.50

(04/06/2017 Due Clearing 4,289,477.5 T

Tuesday, 4 April 2017 463 04/06/2017) Tuesday, 4 April 2017 (04/06/2017) Net Payable Amount Tuesday, 4 April 2017 Tuesday, 4 April 2017 Tuesday, 4 April 2017 Cr. As of Settlement Date Date 77891 778 9 7790 86194 Ref no Transaction SELL BUY BUY BUY Particular 28350000 160000 287000 355500 shares 0 APL CHIB shares shares shares 2O 2GO 6,557,349.21 3,624,093.42 4,820,678.45 12,225,349.3 4,570,293,6 280,816.09 Amount

Wednesday, 19 April 2017 464 (04/07/2017 Net Payable Amount Wednesday, 19 April 2017 Wednesday, 19 April 2017 Date 78064 78065 Ref no. Transaction BUY BUY Particular 1161000 139000 shares shares LMG LMG 6,984,491.23 2,776,771.7 806,873.00 Amount

(04/24/2017) Due Clearing 7,791,364.2 3

04/24/2017 Cr. As of Settlement Date 2,939,290.8

Wednesday, 10 May 2017 465 (04/24/2017) Wednesday, 10 May 2017 Wednesday, 10 May 2017 Net Payable Amount Wednesday, 10 May 2017 Date 78352 86816 86815 Ref O Transaction BUY SELL SELL Particular 15000000 196500 shares shares 15700 shares RLT 2GO 2GO S 12,257,497,6 3,212,955.39 4,852,073.4 259,331.88 Amount Q

Friday, 12 May 2017 466 (05/15/2017 Friday, 12 May 2017 Net Payable Amount Date 78389 Ref no. Transaction BUY Particular 6000000 WPI shares S 4,586,220.01 8,785,210.4 Amount

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Tuesday, 30 Thursday, 1 June 2017 May 2017 468 467 06/02/2017 (05/17/2017) Tuesday, 30 May 2017 Net Payable Amount Thursday,1June 2017 Net Payable Amount Tuesday, 30 May 2017 Date Date 78656 78581 87137 Ref Ref no. no. Transaction Transaction BUY SELL BUY Particular Particular 2000000 2000000 2000000 shares shares shares ACR RLT RLT S S 1,649,430.00 3,800,910.29 1,563,015.00 4,586,220.0 Amount 86,415.00 Amount

(06/06/2017 Due Clearing 3,800,910.2 9 Cr. As of Settlement Date (06/06/2017 2,303,883.3 0

Wednesday, 28 Friday, 2 June June 2017 2017 470 46 Friday, 2 June 2017 Friday, 2 June 2017 (06/07/2017) Net Payable Amount Wednesday, 28 June 2017 (06/06/2017) Friday, 2 June 2017 Friday, 2 June 2017 Net Payable Amount Date Date 79003 78682 78663 87244 87245 Ref o Ref no Transaction Transaction SELL BUY BUY SELL BUY Particular OM shares 6000000 Particular CLI shares 1121900 55310 SHLPH shares 30000 PGOLD shares shares 44690 SHLPH G 5,233,420.13 3,054,820.33 3,801,375.64 6,066,280.69 1,369,831.50 579,916.22 1,497,026.9 Amount Amount 0

Due Clearing (07/03/2017 5,233,420.1 3

07/03/2017) Cr. As of Settlement Date 2,518,432.6

September Friday, 22 2017 41 07/03/2017) Net Payable Amount 2,714,987.4

Friday, 22 September 2017 Friday, 22 September 2017 Date 46017 79886 Ref nO Transaction BUY CM Particular Dividend 3000000 shares Cash BKR S 7,337,187.62 Amount 562.27

09/27/2017 Due Clearing 7,336,625.3

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Cr. As of Settlement Date (09/27/2017) 81.00

Wednesday, 4 October 2017 472 09/27/2017) Wednesday, 4 October Wednesday, 4 October 2017 Wednesday, 4 October Net Payable Amount Wednesday, 4 October 2017 2017 2017 Date 80090 80092 60666 80091 Ref O Transaction BUY BUY BUY CV Particular Payment Balance 551700 236800 211500 of Net Credit shares shares shares PXP PXP PXP 4,634,618.71 3,264,525.00 2,011,583.47 1,807,435.35 7,336,544.3 Amount

(10/09/2017) Due Clearing 11,718,162. 53

(10/09/2017 Cr. As of Settlement Date 3,071,159.8

Monday, 6 November 2017 473 (10/09/2017) Monday, 6 November 2017 Monday, 6 November 2017 Monday,6 November 2017 Net Payable Amount Date 46535 80438 80456 Ref no Transaction BUY BUY CM Particular IDC shares Dividend 300000 150000 GSML shares Cash 3,510,937.48 2,712,789.37 8,647,002.7 Amount 173.25

11/09/2017 Due Clearing 6,223,553.6 0

(11/09/2017) Cr. As of Settlement Date 3,688,767.8

Wednesday, 15 November 2017 474 Wednesday, 15 November (11/09/2017) 2017 Net Payable Amount Date 80623 Ref nO Transaction BUY Particular IDC shares 300000 S 4,224,150.00 2,534,785.7 Amount

Friday, 24 November 2017 4 Friday, 24 November 2017 11/20/2017 Friday, 24 November 2017 Net Payable Amount Date 61102 80775 Ref no. Transaction CN BUY Particular Payment 1990000 Of Net Balance Credit TUGS shares 7,035,966.74 7,005,048.75 4,224,150.0 Amount

Page 167 of 216

Friday, 24 November 2017 89717 SELL 990000 shares TUGS 3,848,874.98

(11/29/2017 Due Clearing 10,192,140. 51 Cr. As of Settlement Date (11/29/2017) 7,035,966.7

Thursday, 14 Thursday, 7 December December 2017 2017 47 46 (12/12/2017) (11/29/2017) Thursday, 7 December Thursday, 7 December Net Payable Amount Net Payable Amount Thursday, 7 December 2017 2017 2017 Date 89985 80972 89984 no. Ref Transaction SELL SELL BUY 90600 MJC Particular 1400 MJC shares SHLPH 15000 shares shares 362,504.35 3,156,173.7 910,002.58 539,169.93 Amount 8,328.30

December Friday, 15 2017 4 (12/19/2017) Net Payable Amount Thursday, 14 December Thursday, 14 December 2017 2017 Date 90099 81053 Ref nO Transaction SELL BUY Particular 300000 shares shares 30000 CHIB MER 9,585,832.50 10,041,357.7 455,525.22 Amount 2

Date Ref nO. Transaction Particular Amount

$

Monday, 18 December 2017 47 9 (12/20/2017) Friday, 15 December 2017 Net Payable Amount Friday, 15 December 2017 Friday, 15 December 2017 Friday, 15 December 2017 Friday. 15 December 2017 90135 90126 90127 81072 81084 SELL SELL SELL BUY BUY 3000000 378600 100000 shares 40000 shares shares 21400 shares SMC CHIB TBGI shares DNL DNL 4,354,040.42 6,500,426.4 3,349,147.50 11,965,085.8 4,219,275.89 240,490.64 0

2018 (12/21/2017) Monday,18 December 2017 Net Payable Amount Date 8 1095 Ref O Transaction BUY Particular 86000 CHIB shares 2,880,266.85 2,880,266.8 Amount 5 Monday, 22 January 2018 480

Page 168 of 216

Monday, 22 January 2018 Mondav, 22 January 2018 Net Payable Amount (01/25/2018 Date 81362 81361 Ref. No. Transaction BUY BUY 1300000 Particular NDW 200000 NOW shares shares C 6,519,472.67 1,064.194.12 7,583,666.7 Amount 9

February 2018 Friday, 9 481 Date Ref. NO. Transaction Particular S Amount

(02/14/2018) Friday,9 February 2018 Friday, 9 February 2018 Due Clearing 81673 61596 BUY C balance 35000000 CEI shares Payment of net credit 9,006,491.26 9,956,318.49 18,962,809. 1S

(02/14/2018) Net Payable Amount Cr. As of Settlement Date (02/14/2018 9,956,318.4 9,006,491.2 6

Monday, 12 February 2018 482 (02/15/2018 Net Payable Amount Monday, 12 February 2018 Monday, 12 February 2018 Monday,12 February 2018 Monday,12 February 2018 Date 81694 81698 9081 90896 Ref. No. Transaction SELL BUY SELL BUY Particular 18000000 2000000 CEI shares 700000 NOW 1500000 CEI shares shares POPI shares 5,278,342.97 5,619,034.74 4,331,272.44 6,087,792.2 478,312.99 Amount :

Wednesday, 14 February 2018 483 (02/20/2018 Wednesday, 14 February Wednesday, 14 February Net Payable Amount 2018 Wednesday, 14 February 2018 2018 Date 81764 81760 81765 Ref. No. Transaction BUY BUY BUY Particular 1000000 NOW shares 688000 SSP shares SSP shares 1312000 15,387,975.0 1,707,240.49 3,296,124.37 20,391,339. Amount 86 0

Wednesday, 21 February 2018 484 (02/26/2018 Net Payable Amount Wednesday, 21 February 2018 Date 81942 Ref. No. Transaction BUY 840000 PXP shares Particular S 14,784,525.0 14,784,525. Amount 00 0

Thursday, 22 February 2018 485 Date Ref. No. Transaction Particular S Amount

Page 169 of 216

(02/27/2018 Net Payable Amount Thursday, 22 February Thursday, 22 February Thursday, 22 February 2018 2018 2018 81971 91153 91161 SELL BUY SELL shares 500000 PXP shares CHIB 526900 PXP 32200 shares 1,126,486.40 9,502,945.54 8,354,517.26 21,941.88

Wednesday, 28 February 2018 48 Due Clearing Wednesday, 28 February 2018 (03/05/2018 Date 82134 Ref. No. Transaction BUY Particular 22418000 TBGI shares S 13,314,088.3 13,314,088. Amount 3 2 2

03/05/2018 Net Payable Amount (03/05/2018) Cr. As of Settlement Date 9,365,119.3 3,948,968.9 6

Thursday, 1 March 2018 487 Net Payable Amount (03/06/2018 Thursdav, 1 March 2018 Date 82150 Ref. No. Transaction BUY shares Particular 12000000 MRC 10,620,720.0 10,620,720. Amount 00 O

Friday, 9 March 2018 488 (03/14/2018) Friday, 9 March 2018 Friday, 9 March 2018 Friday,9 March 2018 Friday,9 March 2018 Net Payable Amount Date 82336 82337 91550 82330 Ref. NO Transaction SELL BUY BUY BUY Particular ION shares 300000 DAVIN 1178000 822000 PRIM 1000000 shares PRIM shares shares 2,051,488.62 1,960,548.70 1,388,900.53 2,776,982.50 2,623,955.3 Amount 5

Tuesday, 20 March 2018 489 Due Clearing 03/23/2018 Tuesday, 20 March 2018 Tuesday, 20 March 2018 Date 82510 61801 Ref. NO. Transaction BUY CV of net 11790000 Payment balance Particular MRC credit shares 5,819,483.79 7,351,831.35 13,171,315. Amount 14

03/23/2018 03/23/2018 Net Payable Amount Cr. As of Settlement Date 8,107,900.2 5,063,414.9 4

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Wednesday, 4 April 2018 490 (04/10/2018 Net Payable Amount Wednesday, 4 April 2018 Date 82637 Ref. No. Transaction BUY Particular 15000000 MRC shares S 10,107,787.5 10,107,787. Amount 50 0

Thursday, 5 April 2018 491 (04/11/2018 Net Payable Amount Thursday, 5 April 2018 Thursday, 5 April 2018 Date 82648 82649 Ref. No. Transaction BUY BUY 9000000 Particular VUL 1000000 VUL shares shares C 9,578,712.73 1,056,037.51 10,634,750. Amount 24

Wednesday, 2 May 2018 492 Due Clearing (05/07/2018) Wednesday, 2 May 2018 Wednesdav, 2 Mav 2018 Date 62189 82821 Ref. No. Transaction BUY CV Particular 2460 Payment CHIB shares of net balance credit S 4,601,123.16 5,464,599.7 863,476.60 Amount 6

(05/07/2018 Net Payable Amount (05/07/2018 Cr. As of Settlement Date 2,384,903.2 3,079,696.5 0 G

Tuesday, 29 May 2018 4983 Due Clearing Tuesday, 29 May 2018 (06/01/2018 Tuesday, 29 May 2018 Tuesdav 29 May 2018 Date 92375 83051 92376 Ref. No. Transaction SELL SELL BUY Particular 391700 1000000 NOW NOW 8300 NOW sh ares shares shares 3,721,122.94 11,817,562.5 8,016,971.4 Amount -79,468.13 C 3

Net Payable Amount (06/01/2018) (06/01/2018) Cr. As of Settlement Date 3,921,349.7 4,095,621.7

Tuesday, 5 June 2018 494 Tuesday, 5 June 2018 Tuesday, 5 June 2018 Date 83119 83128 Ref. No. Transaction BUY BUY Particular 10000000 ABA shares 500000 NOW share: 3,017,250.00 5,219,023.81 Amount

Page 171 of 216

(06/08/2018 Net Payable Amount Tuesday, 5 June 2018 92465 SELL 79500 NOW shares 7,434,901.8 801,371.93 0

June 2018 Tuesday, 19 495 (06/22/2018 Net Payable Amount Tuesday, 19 June 2018 Date 83262 Ref NO. Transaction BUY ISM shares Particular 1531000 S 3,048,810.44 3,048,810.4 Amount

June 2018 Thursday, 21 496 (06/26/2018 Net Payable Amount Thursday, 21 June 2018 Date 8329 Ref. No. Transaction BUY Particular 50000 EAGLE shares 789,513.74 789,513.74 Amount

Monday, 25 June 2018 497 Monday, 25 June 2018 Net Payable Amount (06/28/2018) Monday,25 June 2018 Date 83355 83356 Ref. No. Transaction BUY BUY ISM shares Particular 894000 ISM shares 606000 2,543,400.97 1,767,505.06 4,310,906.0 Amount 3

Monday, 2 July 2018 498 Due Clearing Monday, 2 July 2018 (07/05/2018 Date 83433 Ref. N Transaction BUY ISM shares 2000000 Particular S 6,663,093.75 6,663,093.7 Amount 5

(07/05/2018 07/05/2018) Net Payable Amount Cr. As of Settlement Date 2,618,434.7 4,044,659.0

Thur'sday, 5 July 2018 499 07/10/2018 Thursday, 5 July 2018 Thursday, 5 July 2018 Net Payable Amount Date 83474 83475 Ref. NO. Transaction BUY BY Particular 2000000 1000000 ISM shares IRC shares 3,510,308.87 2,946,063.03 6,456,371.9 Amount

Tuesday, 10 July 2018 500 07/13/2018 Tuesday, 10 July 2018 Net Payable Amount Date 83532 Ref. NO. Transaction BUY Particular 5000 MER shares 1,777,771.75 1,777,771.7 Amount 5

Friday, 13 July 2018 501

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Friday,13July 2018 Friday, 13 Julv 2018 Due Clearing (07/18/2018) Date 83593 83608 Ref. NO. Transaction BUY BUY Particular 6000 BPI shares 8000000 TBGI shares 4,586,220.00 5,166,437.1 580,217.17 Amount

(07/18/2018 Net Payable Amount 07/18/2018 Cr. As of Settlement Date 4,960,729.7 205,707.44 3

Wednesday, 1 August 2018 502 Wednesday, 1 August 2018 Wednesday,1 August 2018 Wednesday, 1 August 2018 Due Clearing. (08/06/2018 Date 83779 93231 83771 Ref. No. Transaction BUY SELL BUY Particular 2000 MER shares 500000 PXP shares 2080 TFHI shares G 6,529,526.15 6,781,090.3 -532,518.51 784,082.70 Amount 4

(08/06/2018) Net Payable Amount (08/06/2018) Cr. As of Settlement Date 4,812,203.3 1,968,886.9

Monday, 6 August 2018 503 (08/09/2018 Net Payable Amount Monday, 6 August 2018 Monday, 6 August 2018 Due Clearing Cr. As of Settlement Date (08/09/2018 08/09/2018 Date 83834 93294 Ref. NO. Transaction SELL BUY Particular shares 7000000 ATN shares 20000 MBT -985,721.57 10,336,726.3 1,518,940.25 8,817,786.1 7,832,064.5 Amount 6 F

Wednesday, 8 August 2018 5 04 08/13/2018 Wednesday, 8 August 2018 Net Payable Amount Wednesday, 8 August 2018 Date 83 885 Ref. 93348 NO. Transaction SELL BUY Particular 60000 PXP shares 5000000 ATN shares S 9,622,448.77 7,757,762.49 1,864.686.2 Amount 8

August 2018 Friday, 24 505

Friday, 24 August 2018 Friday, 24 August 2018 Date 84050 84053 No. Ref. Transaction BUY BUY Particular SMC shares 2000 TFHI shares 41000 7,092,046.13 603,450.00 Amount

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Due Clearing Friday, 24 August 2018 Friday,24 August 2018 (08/30/2018) 93554 93542 SELL SELL CHIB PXP shares 100000 40000 shares 1,233,731.30 1,600,965.00 4,860,799.8 3

(08/30/2018 (08/30/2018) Net Payable Amount Cr. As of Settlement Date 2,204,805.4 2,655,994.3 0

August 2018 Friday, 31 506 Friday, 31 August 2018 (09/05/2018 Friday, 31 August 2018 Friday, 31 August 2018 Due Clearing Date 84094 840 7 63012 Ref. NO. Transaction BUY BUY CV Payment balance Particular 2000 SMC 100000 TUGS shares of net credit shares S 5,092,124.86 5,824,109.7 338,736.60 393,248.26 Amount 2

(09/05/2018) (09/05/2018 Net Payable Amount Cr. As of Settlement Date 5,092,124.8 731,984.86

Tuesday, 13 November 2018 507 (11/16/2018 Tuesday, 13 November Due Clearing Tuesday, 13 November 2018 2018 Date 84713 84714 Ref. No. Transaction BUY BUY 605900 ISM shares ISM shares Particular 394100 4,851,079.24 3,169,483.35 8,020,562.5 Amount 9

(11/16/2018) 11/16/2018 Cr. As of Settlement Date Net Payable Amount 6,144,257.0 1,876,305.5

Wednesday, 21 November 2018 508 Due Clearing Wednesday, 21 November (11/26/2018) 2018 Date 84830 Ref. No. Transaction BUY ISM shares Particular 1000000 S 6,788,812.50 6,788,812.5 Amount 0

(11/26/2018 Cr. As of Settlement Date (11/26/2018 Net Payable Amount 3,826,506.1 2,962,306.3 0

Tuesday, 27 November 2018 509

Date Ref. No. Transaction Particular Amount

Page 174 of 216

2018 (12/03/2018) Due Clearing. Tuesday, 27 November Tuesday, 27 November Tuesday, 27 November 2018 2018 84888 84886 84887 BUY BUY BUY NOW shares 400000 shares 702000 NOW shares 173000 NOW 2,820,505.19 5,079,520.2 1,583,724.37 675,290.72 3

Net Payable Amount (12/03/2018) Cr. As of Settlement Date (12/03/2018 4,722,413.4 357,106.85

Wednesday, 28 November 2018 510 Net Payable Amount (12/04/2018 Wednesday, 28 November Wednesday, 28 November 2018 2018 Date 84912 84913 Ref. No. Transaction BUY BUY Particular 27000 NOW sh ares 173000 NOW shares 773,723.47 103,843.68 669,879.79 Amount

Monday, 3 December 2018 5 1 (12/06/2018) Monday, 3 December 2018 Net Payable Amount Date 84955 NO. Ref. Transaction BUY Particular 5000 MBT shares G 385,705.12 Amount 385,705.12

Thursday, 20 December 20 18 5 12 Due Clearing (12/27/2018 Thursday, 20 December Thursday, 20 December 2018 2018 Date 85142 63808 Ref. No. Transaction BUY CV Particular af net balance 3000 BPI shares Payment Credit 3,658,687.11 3,942,308.6 283,621.50 Amount I

(12/27/2018 (12/27/2018) Net Payable Amount Cr. As of Settlement Date 3,262,170.1 680,138.44 7

2019

January 2019 Friday, 4 5 13 Friday, 4 January 2019 Friday, 4 January 2019 Friday, 4 January 2019 Date 85201 85207 63884 Ret no. C BUY BUY Transaction shares Balance ABA 2000 MER Particular Payment 500000 shares of Credit S 848,258.25 357,041.25 Amount 792,531.00

Page 175 of 216

Friday, 4 January 2019 Due Clearing (01/09/2019 85209 BUY 5000 shares PGOLD 2,237,872.8 240,042.36 6

Friday, 25 January 2019 514 Net Pavable(01/09/2019) Cr. As of Settlement Date (01/09/2019) Friday, 25 January 2019 Cr. As of Settlement Date Due Clearing (01/30/2019 (01/30/2019 Date 85435 Ref O. BUY Transaction Particular 6000000 PHA shares S 6,215,535.00 6,215,535.00 2,882,625.72 2,123,407.8 114,465.06 Amount 0

Monday, 28 January 2019 515 Monday, 28 January 2019 Net Payable(01/30/2019) Date 85453 Ref O Transaction BUY Particular 10000000 PHA shares S 12,958,334.4 3,332,909.2 Amount 4

Monday, 4 February 2019 Thursday, 7 Thursday, 31 January 2019 Wednesday, 30 January 2019 518 517 516 Monday, 4 February 2019 Net Payable(02/06/2019) Monday, 4 February 2019 Net Payable(02/07/2019 Net Payable(01/31/2019) Net Payable(02/04/2019) Wednesday, 30 January Cr. As of Settlement Date Thursday, 31January 2019 Wednesday, 30 January Due Clearing (02/04/2019) (02/04/2019) 2019 2019 Monday, 28 January 2019 Date Date Date 85546 85553 85517 85498 51968 95197 Ref no. Ref no. Ref no BUY BUY BUY Transaction BUY CM Transaction Transaction SELL shares 3000000 Particular 5000000 GEO shares 2000000 PHA Dividend Particular shares Particular 2000000 PHA 9000000 shares Cash PHA shares PHA 2,775,870.00 1,627,504.65 4,403,374.6 3,334,789.29 1,592,415.59 4,672,302.15 3,337,219.29 4,672,302.1 10,673,100.0 1,742,373.7 2,285,234.4 Amount Amount Amount -2,430.00 5 0 O E

February 2019 5 19 Date Ref no Transaction Particular Amount

Page 176 of 216

Thursday, 14 March 2019 Friday, 8 February 2019 Friday, 1 March Friday, 8 March 2019 2019 521 522 523 520 Net Payable(03/13/2019) Net Payable(02/12/2019) Due Clearing (03/13/2019) Cr. As of Settlement Date Net Payable(03/06/2019) Friday, 8 March 2019 Thursday, 14 March 2019 (03/19/2019 Friday,8 February 2019 Net Payable(02/13/2019) Fridav, 8 March 2019 Date(03/13/2019 Due Clearing (03/19/2019 Thursday, 7 February 2019 Friday,1 March 2019 Friday, 1 March 2019 Cr. As of Settlement Date Date Date Date 85961 85935 85617 85873 95598 642 76 85595 nO DO Ref Ref no. Ref Ref no. Transaction BUY BUY BUY Transaction BUY Transaction C BUY SELL Transaction balance 10000 2000000 shares shares 2000000 Particular shares shares credit PNB GREEN 2000000 PHA Particular PHA 4014000 PHA 3000000 X Particular Payment Of Net Particular shares shares S G 5,218,293.65 3,569,021.87 5,218,293.65 2,606,934.98 4,173,191.98 2,965,571.87 2,755,755.00 2,517,150.88 5,242,602.62 2,965,571.87 2,755,755.0 1,069,410.6 603,450.00 2,517,150.8 603,450.00 Amount Amount Amount Amount 8 A

Tuesday, 26 March 2019 Friday, 22 March 2019 5 25 524 Net Payable(03/27/2019) Friday, 22 March 2019 Cr. As of Settlement Date Net Payable(03/19/2019) Fridav, 22 March 2019 (03/27/2019] (03/27/2019) Friday,22 March 2019 Due Clearing Date 86007 64361 95760 Ref no CN BUY Transaction SELL Payment Balance 12000 COL shares Of Net Credit 10000 BPI shares Particular S 2,743,360.85 2,142,583.14 2,076,761.75 600,777.71 2,611,358.6 -226,506.90 893,106.00 Amount

Page 177 of 216

Wednesday, 24 Tuesday, 14 May 2019 Thursday, 23 May 2019 Thursday, 28 March 2019 April 2019 5 29 528 527 526 Net Payable(04/02/2019) (04/29/2019) Net Payable(04/29/2019) Net Payable(03/29/2019) Thursday, 28 March 2019 Wednesday, 24 April 2019 Due Clearing Net Payable(05/17/2019 Due Clearing (04/29/2019 Tuesday, 14 May 2019 Tuesday, 26 March 2019 Tuesday, 26 March 2019 Tuesday, 26 March 2019 Date Date Date Date Date 86028 86029 86046 86033 85 95 86218 Ref mO Ref Ref I. Ref O nO Ref no BUY BUY BUY Transaction Transaction BUY BUY Transaction Transaction BUY Transaction 7000000 -5000 GSMI PHA Particular 700000 shares shares Particular 2124000 SOC 400000 shares shares Particular PXP Particular shares 779000 SOC shares SOC Particular S S S S 6,969,847.51 6,329,399.98 6,329,399.98 6,969,847.5 3,195,227.54 1,242,785.15 5,905,985.4 5,081,692.6 145,471.68 -423,414.49 Amount 643,680.00 145,471.68 Amount Amount Amount Amount 9

Tuesday, 4 June 2019 Monday, 3 June 2019 5 31 5 30 Net Payable(06/07/2019) Due Clearing Net Payable(05/28/2019) 06/07/2019 Cr. As of Settlement Date 06/07/2019 Thursday, 23 May 2019 Due Clearing 05/28/2019 Cr. As of Settlement Date (05/28/2019 Monday,3 June 2019 Monday,3 June 2019 Thursday, 23 May 2019 Date 64915 86300 64856 86250 Ref no. C BUY BUY C Transaction Payment 3000 PNB Particutar Credit Balance shares Payment Balance shares of Net Of Net Credit 1500000 T 1,876,065.70 2,681,468.14 2,857,072.08 2,681,468.14 2,873,565.70 1,975,031.5 175,603.94 -898,534.20 Amount 175,603.94 997,500.00 0

Page 178 of 216

Friday, 14 June Thursday, 13 June 2019 2019 533 532 Net Payable(06/18/2019) Net Payable(06/10/2019) Thursday, 13 June 2019 Tuesday, 4 June 2019] Tuesday, 4 June 2019 Thursday, 13 June 2019 Date Date 86333 86329 86305 86306 Ref Ref no. Do BUY Transaction BUY BUY BUY Transaction Particular shares 1000 MER shares Particular 50000 CPM sh ares PB shares 3000 SMC 70000 S S 3,881,189.25 4,024,508.6 951,137.77 143,319.37 392,644.80 558,492.97 Amount Amount

Friday, 28 June June 2019 Friday, 21 June Wednesday, 26 2019 Wednesday, 19 2019 June 2019 537 536 535 534 Net Payable(06/26/2019) Net Payable(07/01/2019 Net Payable(06/24/2019) Friday, 21 June 2019 (07/01/2019) Cr. As of Settlement Date Wednesday, 26 June 2019 Due Clearing (07/01/2019) Net Payable(06/19/2019) Wednesday, 19 June 2019 Wednesday, 19 June 2019 Wednesday, 19 June 2019 Friday, 14 June 2019 Wednesday, 19 June 2019] Friday,14June 2019 Friday,14 June 2019 Date Date Date Date 86424 96234 96235 86402 86380 96226 86358 86353 96204 nO Ref Ref no Ref no. Ref O. BUY SELL Transaction Transaction Transaction SELL BUY BUY BUY SELL BUY SELL Transaction 20000 BPI Particular 2000 SMC shares shares 2000000 3000 PNB sh ares 3000 SMC sh ares Particular MHC 20000 EEE shares shares shares Particular shares shares Particular 12000 CPM PNB 1000 MER 12000 1,602.411.20 1 133,974.78 1,602,411.20 468,436.42 1,508,625.00 353,706.19 315,511.47 -202,393.60 -521,796.00 633,381.39 Amount -151,054.01 -378,697.40 Amount 353,706.19 660,174.30 Amount Amount 34,034.57

Friday, 28 June 2019 Date 65084 Ref nO Transaction CN Balance Particular Payment Credit Of Net 1,133,974.78 Amount

Page 179 of 216

Wednesday, 24 July 2019 Friday, 12 July Wednesday, 10 July 2019 20 19 Thursday, 4 July 2019 Friday, 5 July 2019 5 42 5 40 541 5 38 5 3 9 Net Payable(07/15/2019) Net Payable(07/17/2019) Net Payable(07/10/2019) Net Payable(07/03/2019) Friday, 12 July 2019 Wednesday, 10 July 2019 Wednesday, 10 julv 2019 Friday,12 July 2019 Friday, 12 July 2019 Thursday,4 July 2019 Net Payable(07/09/2019) Cr. As of Settlement Date Thursday, 4 July 2019 Friday,5 [uly 2019 Due Clearing (07/03/2019) (07/03/2019 Friday, 28 June 2019 Date Date Date Date Date 86537 86520 86532 96428 86478 86495 86522 86441 86487 Ref Ref no. o. Ref Ref no. Ref nD no BUY BUY Transaction Transaction BUY BUY Transaction SELL "Transaction BUY BUY Transaction BUY BUY shares Particular 5000 ALI shares shares shares Particular 5000 ALI CPM 3770 SMC 500000 PRIM 5000000 ABA shares Particular 8000 ALI 500000 shares Particular 1769000 PRIM shares Particular shares 10000 shares PRIM S S S 6,263,299.78 5,129,325.00 2,888,966.59 1,508,063.58 1,150,175.7 2,888,966.5 4,755,236.2 286,487.89 -868,543.28 Amount 263,506.50 668,431.51 Amount 258,226.32 63,394.73 415,978.20 734,197.50 Amount Amount Amount 28,261.57 0 0

Tuesday, 6 August 2019 543 Net Payable(07/29/2019) Wednesday, 24July 2019 Wednesday, 24 July 2019 Wednesday,24 July 2019 Wednesday, 24 July 2019 Wednesday, 24 July 2019 96507 86607 86616 86604 86606 BUY BUY BUY BUY SELL 15000 ALI shares SHLPH sh ares 500000 RCI shares 20000 EW 7000 GSMI 5000 shares shares 890,189.30 -741,187.50 250,230.60 408,334.51 191,343.94 781,467.75

Tuesday, 6 August 2019 Date 65306 Ref no. CN Transaction of Net Particular Payment Amount 455,794.37

Page 180 of 216

Thursday, 22 Tuesday, 20 August 2019 August 2019 Thursday, 15 August 2019 Monday, 19 August 2019 547 546 5 45 5 44 Thursday, 22 August 2019 Net Payable(08/28/2019 Thursday, 15 August 2019 Net Payable(08/20/2019) Monday, 19 August 2019 Monday, 19 August 2019 Net Payable(08/23/2019) Net Payable(08/27/2019 Net Payable(08/09/2019) Thursday, 15 August 2019 Monday, 19 August 2019 Tuesday, 6 August 2019 Tuesday, 6 August 2019 (08/09/2019 Monday, 19 August 2019 Monday; 19 August 2019 Monday,19 August 2019 Monday, 19 August 2019 Tuesday, 20 August 2019 Tuesday, 6 August 2019 Due Clearing Cr. As of Settlement Date (08/09/2019 Thursday, 15 August 2019 Monday, 19 August 2019 Date Date Date Date 86802 86701 96691 86693 96604 86751 86771 86778 86779 86780 86781 96689 96690 86784 86745 86755 Ref Ref Ref no O no. Ref o Transaction BUY BUY SELL BUY BUY BUY BUY SELL SELL Transaction BUY BUY BUY BUY BUY SELL Transaction Transaction BUY Particular 716000 shares PXP 3 100 KPP1 Particular 5504000 ABA Credit Particular 6043000 47800 ABA Balance 1682000 ABA shares shares 626000 ABA shares Particular 558000 ABA 3000 GSMI shares 20000 shares ABA 186500 KPPI 181000 KPPI shares 96600 KPPI shares 301300 KPPI 714500 KPPI shares KPPI shares shares shares 20000 SHLPH shares shares shares shares S 4,609,714.33 1,421,004.07 1,196,900.84 1,209,622.58 2,272,743.57 5,661,403.56 2,071,161.70 5,149,983.10 4,609,714.3 4,487,213.6 590,495.94 1,160,370.31 894,294.79 -381,625.57 -562,966.49 910,791.39 Amount 590,495.94 757,329.75 Amount 725,868.90 477,027.22 161,404.77 255,862.80 Amount Amount -24,876.24 2

Page 181 of 216

September September 2019 Friday, 20 2019 September Tuesday, 3 Tuesday, 27 Monday, 2 2019 August 2019 551 5 50 549 548 Net Payable(09/06/2019) Tuesday, 27 August 2019 Net Payable(08/30/2019 Net Payable(09/05/2019) Tuesday, 27 August 2019 Monday, 2 September 2019 Tuesday, 3 September 2019 Tuesday, 27 August 2019 Date Date Date 86918 86 03 86849 86850 96760 Ref no Ref Ret nO. no. BUY Transaction BUY BUY SELL Transaction Transaction BUY Particular 47000 1970000 2000 BDO CHIB Particular VUL shares Particular shares shares VUL 252000 VUL 2122000 shares share. S C 1,228,573.92 2,833,650.35 1,228,573.9 2,785,560.50 425,728.86 295,690.51 295,690.51 Amount Amount Amount 377,639.01 2

Tuesday, 1 Thursday, 26 September October 2019 Wednesday, 25 September 2019 2019 553 554 552 Net Payable(10/01/2019) 2019 Net Payable(09/25/2019) Net Payable(09/30/2019) Thursday, 26 September (09/25/2019 Cr. As of Settlement Date Wednesday, 25 September Friday, 20 September 2019 09/25/2019 2019 Friday, 20 September 2019 Due Clearing Date Date Date 87074 87066 65549 87050 Ref no. Ref nO. Ref no BUY BUY Transaction Transaction CN BUY Transaction 200000 2000 BDO shares Particular ABA shares Particular 30000 Payment of Net Credit Balance CHIB shares Particular S S 2,445,596.50 1,519,703.55 195,115.50 1,670,163.25 925,892.95 287,242.20 287,242.20 195,115.50 Amount Amount 775,433.25 Amount

Net Payable(10/04/2019) Tuesday, 1 October 2019 Date 87097 Ref no. BUY Transaction Particular shares 5000 GSMI 238,910.89 238,910.89 Amount

Page 182 of 216

Thursday, 31 October 2019 October 2019 Tuesday, 29 October 2019 Monday, 21 October 2019 October 2019 Thursday, 24 Tuesday, 22 558 557 559 555 556 Net Payable(11/06/2019) Tuesday, 29 October 2019 Tuesday, 29 October 2019 Net Payable(11/04/2019 Thursday, 31 October 2019 Net Payable(10/25/2019) Net Payable(10/29/2019) Tuesday, 29 October 2019 Tuesday, 29 October 2019 Tuesday, 29 October 2019 Thursday, 24 October 2019 Tuesday, 29 October 2019 Tuesday, 29 October 2019 Monday, 21 October 2019 Net Payable(10/24/2019) Monday. 21 October 2019 Monday, 21 October 2019 Monday, 21 October 2019 Tuesday, 22 October 2019 Monday, 21 0ctober 2019 Tuesday. 22 October 2019 Thursday. 24 0ctober 2019 Date Date Date Date Date 87257 87241 87242 87243 87190 87231 87232 87233 87173 87178 87189 87228 87165 87166 87167 87168 87170 Ref no. Ref o. Ref no. Ref Ref no. O BUY BUY BUY BUY BUY Transaction Transaction BUY BUY Transaction BUY BUY BUY BUY BUY BUY Transaction BUY BUY BUY Transaction BUY Particular shares 100000 NIKL shares 20000 ALI 5005000 Particular 20000 ALI shares BDO 20000 sh ares Particular SUN shares 2995000 SUN 10000 5000 BPI 25000 CHIB shares PXP shares 20000 SHLPH Particular 10000 1800 SECB 30000 SLI shares 5000 CHIB Particular 3000 BPI shares 20000 VLL shares shares shares GSMI PHEN shares shares shares 50000 shares shares S 6,343,104.35 4,069,908.17 1,531,757.24 5,021,739.9 986,640.74 10,413,012 1,190,204.5 449,369.11 275,575.50 417,386.25 986,640.74 680,892.75 Amount Amount 981,612.00 498,097.69 636,418.49 143,822.25 360,259.65 Amount 294,483.60 Amount Amount 479,239.87 125,718.75 154,885.51 81,164.02 52 2

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and Mr. Sulapas during the opening of accounts provide among others, thus: Further, the Terms and Conditions of the Agreements53 entered into between VSI

liability for any deficiency remaining after the sell-out. in the market price of the securities purchased for me/us shall be for me/our account and risk, until actually sold or disposed of furthermore, you are hereby necessary to cover the unpaid order or balance thereto, without prejudice to my/our me/us within four (4) trading days from the date of execution of my/our order. If not paid within three (3) trading days, any further upward or downward fluctuation authorized at your own discretion to sell all or part of my/our securities as maybe 3. All orders for the purchase of securities on cash basis shall be paid for by

Manual54 provides for the procedures for payment of its clients who purchased shares of stock, thus: Likewise, Item III (H) (1) (ji) of VSI written Supervisory Procedures and Compliance

client. If a client is too far from the messenger to collect from, to deposit the amount due to any of the Company's bank accounts situated near the client. A copy of the deposit slip is faxed to the Cashier to serve as support to the official receipt to be have the option to pay in cash or check. They have the option to pay in cash or check. A messenger is assigned to pick up the payments. The messenger issues a provisional receipt to the client and remits the collection to the cashier. The cashier issues an official receipt and gives it to the messenger for delivery to the Issued "Clients who purchased shares of stocks shall pay on or before T+3. They

selling the securities the amount is not enough to offset against his debit balance dues. If within ten trading days the client has not paid his account, he is given notice that the shares bought will be sold to cover his accountabilities. If after the difference will be for the account of the client. In case of non-payment of client within T+3, the client is reminded of his

into the securities market and redirect resources into more productive uses.55 arranging for the extension of credit to or for Mr. Sulapas in purchasing shares pursuant to the margin requirements under Section 48 of the SRC and Rule 48.2 of the SRC-IRR. The purpose of the margin requirements is to protect the economy from excess stock market speculations and to regulate the volume of credit flow, by way of speculative transactions, from the transaction date. Respondents had the clear obligation to liquidate the shares of stock on the next business day from the settlement date but not beyond ten (10) business days. The reason for the liquidation is that Respondents are forbidden from extending or liquidating the shares in transactions mentioned above pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares within three (3) business days Hence, the Respondents were not justified in applying the credit line and in not

non-payment within three (3) days or T+3 and the unlawful extending of credit to Mr. clear and Respondents cannot claim ignorance thereof. Hence, both VSI and Mr. Racadio Sulapas. Clearly, Respondents VSI and Mr. Racadio were well aware of the consequences of In fact, Sections 48.2 and 50 of the SRC and SRC Rules 48.2, 48.1 and 50 are very

54 Page 29 Annex 12 of the Respondents Position Paper 55 Abacus case. 53 Attachment to Annex 1 and Annex 1-A of Respondents Position Paper.

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violated the provision of the SRC and SRC Rules on Prohibition of Extension of Credit and Purchases and Sales in Cash Account.

law56 where intent is not an essential element. Mere violation of which is punishable being a mala prohibita. of Mr. Racadio and the rest of the Respondents to evade the requirements for margin accounts under the SRc and the SRC-IRR for the simple reason that the SRC is a special Further, Respondents cannot raise the defense that there is no intention on the part

E On the Charge for Violation of Rule 34.10 of the 2015 SRC Rules (Adora Aguilar)

Rule 34.10 on the following grounds: 57 In the Formal Charge, Complainant charged Respondent Aguilar for violation of

Million stock position evidenced by the Terms of Credit Line Agreement signed by Racadio and Sulapas. This Credit Line Agreement includes among others provisions for interests and collateral. 1. Julieto Sulapas has a credit line with VSI since 18 August 2015, with a Php40

2. Although the document was termed as a Credit Line Agreement, it was stil classified by VSI as a cash account rather than a margin account to seemingly IRR for margin accounts. remove the Julieto Sulapas transactions from the requirements of the SRC and its

margin account and comply with all the requirements of the SRC and its IRR. 3. The Associated Person has the duty to among others to check all executed trades and other transactions of the company, but Adora Aguilar was clearly remiss on this duty for her failure to properly identify the account of Julieto Sulapas as a

Rule 34.10 of the SRC IRR on the following reasons: 58 On the other hand, Respondent Aguilar argues that she cannot be held liable under

the account of Mr. Sulapas into a margin account; 1. Ms. Aguilar duly supervises all the trades executed by Venture Securities. Ms. Aguilar maintains that the Sulapas Account is a cash account because the existence of a credit line agreement or the charging of interest does not immediately convert

forth in Rules 48.1.1, 48.1.2, 48.1.3, 48.1.4, 48.1.5 and 48.2.2: the said account complies with all the requirements for a margin account as set 2. Even assuming without conceding that the Sulapas Account is a margin account,

3. Under the terms of the credit line agreement, Mr. Sulapas was allowed to borrow up to 40% of the current market value of his present stock holdings. The amount Mr. Sulapas was allowed to borrow was much lower compared to the limit set under Rule 48.1.1 of the SRC-IRR;

56 Baviera vs. Paglinawan, G.R. Nos. 168380 and 170602, February 8, 2007. 58 Pages 37-38 of the Answer 57 Page 21 of the Formal Charge

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minimum amount set in Rule 48.1.2 of the SRC IRR; market value of his present stock holdings. This is much higher compared to the 4. Mr. Sulapas was also required to maintain a margin of at least 60% of the current

5. Mr. Sulapas settled all "margin calls" made by Venture Securities without any Iss ues;

6. Mr. Sulapas always maintained sufficient collateral on securities in accordance problems with Mr. Sulapas; with Rule 48.2.2 of the SRC-IRR. Venture Securities also did not encounter any

7. Based on the foregoing, there is no intention on the part of Ms. Aguilar and the rest of the Respondents to evade the requirements for margin accounts under the SRC and the SRC-IRR;

In order to resolve this issue, the panel shall refer to SRC Rule 34, which states:

Rule 34 - Segregation and Limitation of Functions of Members, Brokers and Dealers

of the company. Sec. 34.10. The Associated Person of a Broker Dealer shall supervise the functions of the employees and check all executed trades and other transactions

Account is a Cash Account and not a Margin Account. the Sulapas account is a Margin account and not a cash account. To repeat, the Sulapas As already discussed, we are not in accord with the arguments of Complainant that

despite being a Cash Account and not a Margin Account she did not stop the creation and implementation of the credit line in favor of the Sulapas account. Rule for her failure to supervise the functions of the employees and check all executed trades and other transactions of the company for the reason that Mr. Sulapas account Nonetheless, we find that Ms. Aguilar is still in violation of the above-mentioned

F. On the Charge for violation of Rule 30.2.1.2.3.2.2 of the 2015 SRC Rules (VSI, Racadio, Aguilar and Balabis)

compliance with the provisions of the SRC and its IRR. 59 procedures in the "transfer in" transactions that ultimately led to the successful execution of the fraudulent schemes of Marlo Moron to the detriment of the clients of R&L; and, (iii) Mr. Racadio has failed to perform his duty to oversee the day to day operations of the company including its internal control procedures and financial operational capabilities in is necessary as part of internal control to ensure that it is the client himself who indeed requested the "transfer in"; (ii) the lack of action on the part of VSI, including its Associated Person Aguilar and Salesman Balabis, revealed the lack of satisfactory internal control "transfer in" requests in the account of Julieto Sulapas lack the signature of Sulapas which Complainant alleges that: (i) based on the documents received from VSI, certain

59 Paragraphs 26-29, page 18 of the Formal Charge

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In" Requests in accordance with the SRC-IRR. 60 Complainant further alleged that VSI is required to maintain copies of the "Transfer

be held liable under Rule 30.2.1.2.3.2.2 of the SRC-IRR based on the following reasons: Respondents countered that VSI, Mr. Racadio, Ms. Aguilar, and Mr. Balabis cannot

control of VSI or its capacity to safeguard securities; and the welfare of all its stakeholders. In accordance with the SRC-IRR, its trading, settlement, accounting, and back office functions are segregated in their respective facilities. CMIC found no material inadequacies in the internal 1.Proper internal control measures are present in VSI to safeguard its business

2. As regards the EQ Trade Transactions, VSI always requires the written signed request of its clients, like Mr. Sulapas, for "trade out" transactions;

completeness and movement of shares and stock positions; held by such counterpart brokerage firm. VSI presumed the regularity of transactions and existence of adequate internal control to comply with the firms also possess the same adequate internal controls. As regards EQ Trade Transactions, VSI presumed that other brokerage firms were only transferring shares from a specific account of a client and that CMIC verifies the 3. For "transfer in" transactions, VSI requires a request from the client, whether written or verbal. Additionally, VSI coordinates with its counterpart brokerage firm, such as R&L, to confirm whether the client indeed owns shares requirements of the SRC-IRR as regards EQ Trade Transactions. VSI relies on CMIC as a watchdog for other brokerage firms to ensure that other brokerage

4. VSI also presumed that the EQ trade protocols and authorization R& requirements under the PCD System, were all complied with on the side of

5. As the President of VSI, Mr. Racadio ensured that VSI and its employees he cannot be made liable under Rule 30.2.1.2.3.2.2 of the SRC-IRR; 61 employ resources and procedures to protect VSI operations and clients, and other registered persons from financial loss arising from theft, fraud and any other dishonest acts. In addition, since Mr. Racadio is not a registered person,

authority of the client pursuant to Section 52.1.1.1.1.2 of the SRC-IRR. 62 internal control. As long as there is confirmation for "transfer in", whether written or verbal, then the internal control procedures are complied with. In addition, it is "transfer out" requests which requires the signature and written 6. Contrary to the allegation in the Formal Charge, the relevant laws and rules do not require a client's signature for transfer in" requests for purposes of

Management Manual which is implemented and observed by all of its 7. VSI has its Supervisory Procedures and Compliance Manual and Risk employees. Furthermore, VSI ensured that the persons authorized to legally

60 Paragraph 6.50 Complainant Position Paper 61 Paragraphs 4.70-4.75 page 34.-35 of the Answer 62 Paragraph 4.36, page 28 of the Answer

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codes and passwords in compliance with the security requirements of the PCD and validly act on behalf of the participant do not know each other, access Rules. 63

8. Even assuming the cited violations against Mr. Balabis and Mr. Aguilar are these violations are the proximate cause of the losses incurred by the clients duly established, the complainant has failed to show in the Formal Charge how of R&L. 64 We agree with the Complainant.

SRC Rule Sec. 30.2.1.2.3, provides:

Sec. 30.2.1.2.3. Capabilities

procedures which are needed for the proper performance of his business A registered person shall have and employ effectively the activities. s ans

XX

30.2,1.2.3.2. A registered person shall ensure that at all times, pursuant to SRC Rule 30.2.6, he has:

30,2,1.2.3.2,1. Adequate resources to diligently supervise and does diligently supervise his employees and all persons appointed by him to conduct business for or with clients or any other registered persons; and

arising from the theft, fraud and other dishonest acts, or professional authorized representatives. 30.2.1.2.3,2.2, Satisfactory internal control procedures and financial and operational capabilities which can be reasonably expected to protect his operations, his clients and other registered persons from financial loss misconduct or omissions of all company officers, employees and

satisfactory internal control procedures and financial and operational capabilities. Under the Rule, registered persons have a legal and regulatory duty to maintain

a request from the client, whether written or verbal allegedly since the relevant laws and rules do not require a client's signature for "transfer in" requests for purposes of internal control. In this case, Respondents admitted that, in "transfer in" transactions, VSI requires

The SRC Rule pertaining to "transfer in" transactions provide:

office the following books and records relating to its business: 52.1.1.1. A Broker Dealer shall make, keep current and maintain in its principal

XXX

securities to and from other Broker Dealers and securities depository in case of 52.1.1.1:1.2. An In/Out Receipts Book setting forth the receipt and delivery of

64 Paragraph 2.100 page 26 Position Paper 63 Paragraph 2.95 pages 25-26 Position Paper

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delivery of the securities to or from Broker Dealers, the In/Out Receipt number. stock dividend distribution, including information on the date of receipt or

name of security, number of shares, and description of such receipt and delivery

request from the customer prior to executing the transfer and keep the document customer). If the receipt and delivery of shares refer to a transfer of shares by a customer from/to his account with the Broker Dealer to/from his other accoun with another Broker Dealer, the Broker Dealer should obtain a written transfer on file; (Emphasis ours) of securities (e.g. lodgment or upliftment of shares, transfer request by a

XXX

covers both the "transfer in" and "transfer out" transactions. Webster Dictionary). Also, the transfer of shares by a customer use the preposition or an action or condition suggestive of movement toward a place, person, or thing reached (Merriam-Webster Dictionary). In other words, the word "receipt" simply preposition "from" means "the origin" while "to" is "the destination". Thus, the rule requiring written transfer request from the customer prior to executing the transfer "from"/"to" and "to"/"from". "From" is used as a function word to indicate the starting connotes "to accept" and the word "deliver" means "to send". On the other hand, the used two words, namely, "receipt" and "delivery." The word "receipt" means generally accepted while "delivery" means the act or manner of delivering something (Merriam- or focal point of an activity while "to" is used as a function word to indicate movement In Rule 52.1.1.1.1.2, it is to be noted that the phrase "receipt and delivery of shares"

the above-mentioned rule when they did not get Mr. Sulapas written request for the "transfer in" transactions. Clearly, Respondents Aguilar and Balabis failed to comply with the requirements of

whether the Respondents have complied with three factors pertaining to VSI internal control procedure, specifically the VSI's Supervisory Procedures and Compliance Manual and Risk Management Manual (Annex 12-and 13 Respondents Position Paper), as follows: Besides, in determining the Respondent's liability, it is necessary to establish

2 3 1} Whether VSI established a "satisfactory" internal supervisory procedure Whether VSI adequately acted upon and investigated the "red flags" Whether VSI implemented and' maintained this ' procedure

procedure in place that may adequately enforce all the SEc Rules and applicable securities Iaws and regulations. Here, it was established by VSI that it had a reasonable supervisory control

policies in a reasonable manner renders them liable for the prohibited activities and in effect have allowed the suspicious activities to occur. VSI, Mr. Racadio. Ms. Aguilar, Mr. Balabis and its officers and employees concerned are required to adhere, implement and maintain the provisions of their procedure. In this case, we found that Respondents failed to maintain and implement the internal supervisory procedures when they did not require written authorization of Mr. Sulapas in the execution of the "transfer in" transactions. Respondents failure to implement these However, in addition to establishing an adequate supervisory control procedure,

unauthorized activities. Here, the question is not whether VSI or Racadio should have VSI and Racadio may also be held liable under the Rule for their failure to act on the

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known of the unauthorized activity, but rather if they attempted to intervene and investigate. Their repeated failures to thoroughly investigate their registered through the unauthorized transfers of securities. representatives unauthorized activities paved the way to cause to defraud investors

liable under the Rule for their failure to act and by not conducting an investigation on the were not detected and acted upon may be considered as sufficient ground for their liability. VSI and Racadio are required to monitor for all instances of unauthorized activities and Securities transactions and to act upon them accordingly. illegal activities and occurrences. Any activities in violation of the SRC and its IRR which the VSI and Racadio's failure to act upon the cumulative red flags, we found VSI and Racadio Accordingly, as a result of the unauthorized act of the registered persons and upon

person based on his failure to supervise VSI registered representatives. since he is not a registered person, he would likewise be liable under the Rule as a control Further, contrary to the claim of Mr. Racadio that he is not liable under the Rule

and the Respondents are strictly obliged to comply. watchdog for other brokerage firms to ensure that other brokerage firms also possess the same adequate internal controls and its presumption that the EQ trade protocols and authorization requirements under the PCD System were all complied with on the side of R&L is inconsequential for the simple reason that the requirement of the Rule is mandatory With respect to the contention of the Respondents that VSI relies on CMIC as a

Commission had to pass upon their compliance with VSI Supervisory Procedures and the Compliance with Supervisory Procedures necessarily means compliance with the laws. Thus, to determine whether the Respondents fulfil their obligation under the law, the Rules. To note, the SRC and its IRR are to be read into the Supervisory Procedures of VSI

duties in failing to observe their mandates under the SRC Rule with respect to the Capabilities, thereby negating the function imposed on them by SRC Rule 30.2.1.2.3. Clearly, Respondents VSI, Racadio, Aguilar.and Balabis, were gravely remiss on their

G. On the Charge for Violation of Rule 52.1.1.1.1.2 of the 2015 SRC Rules (VSI, Racadio and Mosenabre)

In this charge, the Complainant alleges that: 65

1 A review on the documents in relation to the Julieto Sulapas account in VSI revealed that certain "transfer out" in the account of Julieto Sulapas lacks written request.

2 A review of the Julieto Sulapas account ledgers with VSI also revealed that there are discrepancies on the number of shares between the Stock (In) CM, the Julieto Sulapas ledgers and the EQ Trade Form.

65 Pages 22 of the Formal Charge

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3 These observations reveal that VSI fails to maintain and keep current

Code and its Implementing Rules and Regulations. complete sets of its books and records in violation of the Securities Regulation

to day operations of the company. operations of the broker dealer, including the proper monitoring and maintenance of its books and records. The lack of accurate and complete books and records shows the failure of VSI to comply with the requirements under the SRC and ultimately the neglect of Wilfred Racadio of his duty to oversee the day The President of VSI Wilfred Racadio has the duty to oversee the day to day

In their Answer Respondents countered: 66

Book of its clients; Rule 52.1.1 relating to Rule 52.1.1.1.1.2. of the SRC-IRR mandating that the Broker Dealer make, keep current and maintain in its principal office the In/Out Receipts 1. VSI, Mr. Racadio, and Ms. Mosenabre likewise cannot be held liable for violating

were periodically and consistently submitted to the CMIC and to the external 2. Mr. Racadio and Ms. Mosenabre ensured that the records of transactions of the clients of Venture Securities are complete in the Company's files. These records auditor for annual audits. In addition, since Mr. Racadio and Ms. Mosenabre are not registered persons, they cannot be made liable under the above stated SRC-IRR Rules;

have a written request from him as shown by the previous submissions to this between the Stock (In) CM, the Julieto Sulapas ledgers and the EQ Trade Form, as can be seen on the previous submissions to this Honorable Office; 3. As regards the Sulapas Account, all of the "transfer out" requests of Mr. Sulapas Honorable Office. In addition, there are no discrepancies on the number of shares

4. Based on the foregoing, there is no basis to state that VSI, Mr. Racadio, and Ms. Mosenabre do not maintain the proper records in the principal office of Venture Securities;

the account of Julieto Sulapas lacks written request because certain signatures of Sulapas appearing in the EQ Trade Forms attached as Annex "I" appear to be exactly the same. In addition, Mr. Julieto Sulapas also personally denied such signatures in his Supplemental Affidavit to wit: In its Position Paper67, Complainant insists that certain "transfer out" request in

pinapirma sa akin ay mga EQ Trade Forms. Habang tinitingnan ko po ang mga kinontak ako ni Krystel at tinanong kung puede ba akong magpunta ng Venture dalawang beses kaming nagkita ni Krystel sa Jollibee malapit sa opisina ng Venture papel. Pinapirmahan po sa akin ang mga blankong dokumento para daw hindi ko na kailanganin na bumalik ulit. Natatandaan ko na ilan sa mga dokumentong "xxxiv. Na matapos lumabas sa publiko ang mga naganap sa R&L Investments. Securities upang magpirma ng nasa isandaang dokumento, at ilang mga blankong Securities upang magpirma ng mga dokumento dahil nasa audit sila. Umoo ako at

66 Page 39 of the Answer 67 Paragraphs 6.55 and 6.56 Complainant Position Paper

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magkaparehong magkapareho ang mga ito." dokumento, napapansin ko na parehong pareho yung mga pirma ko. Tingin ko ay kinopya lamang ang mga naturang pirma sapagkat imposible na maging

In thier Reply, 68 Respondents pointed out the following:

his "transfer out" requests as can be seen in Annex "8"-Series of Respondents Position Paper. 1. Mr. Sulapas affixed his signature in the written authorities that he executed for

"I" belong to Mr. Sulapas as can be seen in Annexes "2" and ;2-A" of Respondents" Position Paper. 2. Annex "I" of the Complainant's Position Paper does not refer solely to "transfer out" requests of Mr. Sulapas. Nevertheless, the signatures appearing in the in Annex

"I" are forged without providing any evidence to support such allegation. 3. Complainant appears to be implying that the signatures of Mr. Sulapas in Annex

of events cited portion of his Supplemental Affidavit in paragraph 6.56 of forgot the signature that he affixed on documents that he had just allegedly signed. Complainants position paper is incoherent because it appears that he immediately 4. The statements of Mr. Sulapas in his Supplemental Affidavit are of doubtful accuracy as they are filied with numerous inconsistencies. Moreover, the narration

inter alios acta as embodied under Section 31, Rule 130 of the Rules of Court. Complainant is trying to implicate the respondents in the conspiracy between Mr. Sulapas and Mr. Moron without showing any evidence that they are part of said conspiracy aside from the affidavit of Mr. Sulapas. 5. The statements of Mr. Sulapas in his Sinumpaang Salaysay and Supplemental Affidavit cannot be used against Respondents in this case under the doctrine of res

Office of the Ombudsman v. Mislang, said doctrine finds application even in 6. The Commission cannot use the affidavits of Mr. Sulapas as basis to penalize any of the Respondents. The doctrine of'res inter alios acta alteri nocere debet prevents such use of the admissions made by a co-conspirator, and as seen in the case of administrative cases.

Sulapas based on the Attached documents in Annex "J" thereof. discrepancies in the number of shares in the Stock (In) CM and EQ trade Forms of Julieto Likewise, Complainant in its Position Paper69 maintains that there are

indicative of bad faith. shares in the Stock (In) CM and EQ Trade Forms of Julieto Sulapas are minimal and not In their Reply, 70 Respondents admitted that the discrepancies in the number of

The said Rule provides that: This panel finds that Respondents violated of the above-mentioned Rule of SRC IRR

69 Paragraph 6.57. 70 Paragraph 2.80 page 24. 68 Paragraphs 2.77-279, pages 23-24 Respondents Reply.

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Sec. 52.1.1. Books and Records Rule

Sec. 52.1.1.1. A Broker Dealer shall make, keep current and maintain in its principal office the following books and records relating to its business:

XXX XXX XXX

securities to and from other Broker Dealers and securities depository in case of stock dividend distribution, including information on the date of receipt or delivery of the securities to or from Broker Dealers, the In/Out Receipt number, name of and delivery of shares refer to a transfer of shares by a customer from/to his account with the Broker Dealer to/from his other account with another Broker Dealer, the Broker Dealer should obtain a written transfer request from the customer prior to executing the transfer and keep the document on file;: Sec. 52.1.1.1.1.2. An In/Out Receipts Book setting forth the receipt and delivery of security, number of shares, and description of such receipt and delivery of securities (e.g. lodgment or upliftment of shares, transfer request by a customer). If the receipt

the business transaction of the company. require a Broker Dealer to make, keep current and maintain books and records relating to The afore-quoted provision, which is also known as the "Books and Records Rule"

without discounting the possibility of the claim of Mr. Sulapas that the signatures appearing in the EQ Trade Forms was not his, still finds the Respondents to have violated the above-mentioned Rule. After a careful review of the arguments and position of the parties, the panel while

requires authorization by the client coupled with the admission of Respondents that there are discrepancies in the number of shares in the Stock (In) CM and EQ Trade Forms are more than sufficient evidence to prove the violation. As already discussed above, the fact that the "Transfer In" request in EQ Trade

Stock (In) CM and EQ trade Forms of Julieto Sulapas are minimal and not indicative of bad faith is not an excuse since compliance of the Rule is mandatory. The claim of Respondents that the discrepancies in the number of shares in the

substantial figures pertaining to the number of shares as illustrated below. Besides, we noted that the discrepancies are not just minimal as they represent

10/01/2019 03/05/2019 06/09/2018 18/01/2019 06/08/2019 10/01/2019 Date 16/08/2018 18/01/2019 SDM 5607 SCM 11014 SCM 11014 SCM 11175 SCM 11010 SCM 10602 Reference SCM 11100 SCM 10893 SECB MER PIZZA BDO GSMI ABS Stock CHIB EAGLE No. of Stock per Stock Record 100,000 30,000 15,000 15,000 3,000 2,000 15,000 [ Per EQ Trade Form 150,000 27,600 30,000 50,000 10,000 3,000 2,000 3,000 Difference (135,000 (27,000) (2,000 (1,000) 50,000 12,000 2,400 5,000

Respondents in this issue in view of our discussion above pertaining on the matter. Finally, the panel will no longer discuss the issue on res inter alios acta raised by

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to verify the completeness of the EQ Trade transactions including the written 52.2 of the SRC which provides that "it shall be unlawful for any person, directly, or indirectly, to do any act or thing which it would be unlawful for such person to do under authorizations of Sulapas. As such, she is liable for violation of the Rule pursuant to Section the provisions of this Code or any rule or regulation thereunder." Verily, Ms. Mosenabre as the Settlement Officer of VSI has failed on her obligation

VSI compliance procedures for the proper monitoring and maintenance of its books and records. On the other hand, VSI and Mr. Racadio failed to perform their duty to implement

Section 26 in relation to Section 54 of H. On the charge for violation of the Securities Regulation Code (Aguilar, Balabis and Mosenabre)

In the Formal Charge, Complainant alleges, that: 71

Balabis knows, is an employee of R&L Investments, another broker dealer. personally meet Julieto Sulapas at the time the latter opened an account with VSI and (ii) Sulapas was referred to him by Marlo Moron, one who Loreto 1. During the investigation it was discovered that (i) Loreto Balabis did not

2. The documents received from VSI showed that Loreto Balabis, who income declared in the CAIF of less than PhP 1,000,000.00. processed most of the transactions of Julieto Sulapas in Venture, did not make any inquiry or verification as to the transactions of Julieto Sulapas, despite the large amounts involved (roughly PhP 10 billion in total from 2012 to 2019, per CMIC Report) in relation to the total net worth, liquid net worth and annual

3. Despite all of these circumstances that should have caught his attention on transactions pertaining to the account of Julieto Sulapas. This blatant disregard of his duties as a salesman under the law ultimately resulted to the loss of R&L clients' investments. guard, Loreto Balabis did not bother to check the disproportionate

income of Julieto Sulapas, the Associated Person Adora Aguilar likewise did not conduct any inquiry, verification and review of the Julieto Sulapas account disproportionate to the declared total net worth, liquid net worth and annual transactions. 4. Given the large amounts and volume of transactions which were grossly

5. It was also admitted by Adora Aguilar during the investigative proceedings of Julieto Sulapas to transact relating to the latter's account with Venture. that she knew Marlo Moron was the trading floor assistant/settlement clerk of R&L. Yet, Adora Aguilar still allowed Marlo Moron to be the authorized person

6. Adora Aguilar, as the Associated Person, has the duty to ensure the compliance of the broker dealer under the provisions of the Securities

71 Pages 15-16 of the Formal Charge.

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blatantly disregarded to perform her duties under the SRC and her license. is also specifically indicated under the terms and conditions of her license. In Regulation Code and its Implementing Rules and Regulations. The same duty disproportionate transaction amounts from Sulapas declared total net worth. Venture, and the overarching authority granted by Sulapas to Marlo Moron, were flagrant violations of the basic principle of Risk Management. Clearly, she this case, the inaction of Adora Aguilar and her failure to review and verify the credentials and financial position of Julieto Sulapas such as the liquid net worth, annual income, the circumstances of his engagement with

not make any inquiry into the Julieto Sulapas transactions. Further, she of R&L, and is the authorized person of Julieto Sulapas at the same time. 7. Teresita Mosenabre, as the settlement officer of VSI should have also looked into the EQ trade transactions. Despite the large volume of EQ trades, she did admitted during the investigative proceedings that she confirmed the EQ trade transfers of Julieto Sulapas, knowing that Marlo Moron is the settlement officer

8. The above discussed circumstances reveal the gross inexcusable negligence of Venture Securities officers and employees to perform the duties entrusted] to them by law in connection with the Julieto Sulapas account amounting to bad faith. Hence, they may be held liable under Section 26 of the SRC and Rule 26.1 of its 2015 SRC-IRR.

accusation against them in the Formal Charge and alleged that: 72 In their defense, Respondents Aguilar, Balabis and Mosenabre denied the

Section 26 of the SRC and Rule 26.1 of the SRC-IRR because they did not engage in any fraudulert transactions as defined therein; 1. Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre cannot be held liable under

as a fraud or deceit upon any person; circumstances under which they were made, not misleading, (iii) engaged in any act, transaction, practice or course of business which operates or would operate 2. The circumstances described in the Formal Charge do not show that Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre directly or indirectly (i)employed any device, scheme, or artifice to defraud, (ii) obtained money or property by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in the light of the

3. It is clear that in order to be liable for a Fraudulent Transaction under Section 26 of the SRC and Rule 26.1 of the SRC-IRR, there must be an intentional act specific acts of Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre amounting to any of the Fraudulent Transactions described under Section 26 of the SRC and Rule committed by the alleged perpetrators: The Formal Charge failed to show the 26.1 of the SRC-IRR;

Balabis and/or Ms. Mosenabre are in conspiracy with the alleged fraudulent 4. Neither is there any allegation in the Formal Charge that Ms. Aguilar, Mr schemes of Mr. Moron and Mr. Sulapas;

72 Pages 29-31 of the Answer.

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been fair and regular. The(Supreme) Court has stressed time and again that allegations must be proven by sufficient evidence because mere allegation is definitely not evidence.": 2013 states that was to fraud, the rule is that he who alleges fraud or mistake a person takes ordinary care of his concerns and that private transactions have 5. The Supreme Court in Spouses Ramos v. Obispo, G.R. No. 193804, 27 February affecting a transaction must substantiate his allegation, since it is presumed that

6. In this case, there are no allegations and no evidence showing that Ms. Transactions under Section 26 of the SRC and Rule 26.1 of the SRC-IRR. The Formal Charge does not even identify that transactions that they consider as "fraudulent transactions" under said provisions; Aguilar, Mr. Balabis, and Ms. Mosenabre engaged in any of the Fraudulent

and inexcusable negligence in the performance of their duties; commit a fraudulent transaction under Section 26 of the SRC and Rule 26.1 of 7. Even assuming that the gross and inexcusable negligence can be the basis to the SRC-IRR, Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre did not commit gross

he personally visited the office of Venture Securities. The identitfy of Mr. Sulapas was properly verified by Venture Securities; 8. As already discussed above, Mr. Balabis only handed an account opening form to Mr. Moron, which the latter requested for Mr. Sulapas. Account opening forms part of Mr. Balabis because the account of Mr. Sulapas was created at the time of other broker dealers can be freely downloaded over the internet. The account of Mr. Sulapas was not created during this time. There was no omission on the

because these transactions fit the latter's trading profile; worth, and annual income. More importantly, Mr. Sulapas was also a knowledgeable trader, and he was to sustain his numerous buy and sell transactions almost entirely from his trading activities. There were no omissions on their part to find the transactions of Mr. Sulapas as suspicious trader, and he would execute numerous buy and sell transactions during the trading day, buying and selling the shares with the most trading action. The average value of his daily transactions fit his declared total net worth, liquid net Aguilar and Mr. Balabis because they are in line with his established trading profile with Venture Securities. From 2012-2019, Mr. Sulapas was an active 9. The transactions of Mr. Sulapas did not elicit any suspicions on the part of Ms.

Mr. Moron because of the foregoing reasons; any special or unusual authority other than the usual authority given by other clients to their authorized representatives. In addition, it was Mr. Sulapas who primarily gave instructions to Venture Securities for his account. There was no omission on the part of Ms. Aguilar to be suspicious on the authority granted to elicit any suspicions because there is no prohibition for Mr. Moron, as the trading floor assistant / settlement of R&L, to be authorized to transact Mr Sulapas account with Venture Securities. Moreover, Mr. Moron was not granted 10. The fact that Mr. Moron was an authorized person of Mr. Sulapas did not

11. Ms. Mosenabre monitored the EQ trade transactions of Mr. Sulapas from 2012 to 2019, and she found the volume of his EQ trades to be consistent with

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R&L followed the necessary protocols and internal control regarding "transfer his established trading profile. Furthermore, she relied on the presumption that Mosenabre called R&L to discuss and/or confirm EQ trade transactions, it was only Mr. Moron who was available to answer her inquiries; out" requests such as the one present in Venture Securities. Whenever Ms.

employees of Venture Securities are not participants in any of it; and responsibilities as mandated by law and in accordance with the Rules: Any fraudulent transaction originated and was consummated inside R&L, and the 12. As discussed, there is no basis to state that Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre committed gross and inexcusable negligence that would amount to bad faith. These employees of Venture Securities were performing their duties

13. Based on the foregoing, there is no basis to find Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre liable for any fraudulent transactions under Section 26 of the SRC and Rule 26.1 of the SRC-IRR and to be penalized under Section 54 of the SRC:

above, it is undisputable that: The panel finds the submissions of Respondents meritless. Based on the discussion

Signed the CAIF. (1) Mr. Balabis was not present during the Sulapas account opening but he still

but he was allowed to transact beyond his declared financial capacity. (2) The Financial Capacity of Mr. Sulapas indicated in his CAIF is only P1,000,000.00

he has existing account with another broker, R&L. any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that (3) Respondents allowed Mr. Sulapas to indicate in his CAIF that he does not have

(4) Respondents failed to require Mr. Sulapas-to update his CAIF.

authorization from Mr. Sulapas. (4) Respondents allowed the execution of EQ Trades without the written

that it is not a Margin Account. (5) Respondents unlawfully granted Credit Line to Sulapas account despite the fact

payment of the shares within three (3) business days from the transaction date. transactions pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the (6) As Cash Account, Respondents failed to liquidate the shares in numerous

Section 26 in relation to Section 54 of the SRC, provides:

directly or indirectly, in connection with the purchase or sale of any securities to: "SEC. 26. Fraudulent Transactions. - It shall be unlawful for any person,

26.1. Employ any device, scheme, or artifice to defraud;

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material fact of any omission to state a material fact necessary in order to 26.2. Obtain money or property by means of any untrue statement of a make the statements made, in the light of the circumstances under which they were made, not misleading; or

26.3. Engage in any act, transaction, practi operates or would operate as a fraud or deceit upon any person. (SRC) Sec. 54. Investigative Sanctions ice or course of business which

Commission finds that: (a) There is a violation of this Code, its rules, or its SEC. 54. Investigative Sanctions. - 54.1. If, after due notice and hearing, the orders;

XXX XXX XXX

it shall, in its discretion, and subject only to the limitations hereinafter prescribed, impose any or all of the following sanctions as may be appropriate in light of the facts and circumstances:

One million pesos (P1,000,000.00) plus not more than Two thousand pesos (P2,000.00) for each day of continuing violation; (i) Suspension, or revocation of any registration for the offering of securities; (ii) A fine of no less than Ten thousand pesos (P10,000.00) nor more than

under Section 17 of this Code or any other act, rule or regulation administered by the Commission; (iii) In the case of a violation of Sections 19.2, 20, 24, 26 and 27, person performing similar functions, of an issuer required to file reports disqualification from being an officer, member of the Board of Directors, or

times the profit gained or loss avoided as a result of the purchase, .sale or communication proscribed by such Section; and {iv) In the case of a violation of Section 34, a fine of no more than three (3)

(v) Other penalties within the power of the Commission to impose

for the violation." 54.2. The imposition of the foregoing investigative sanctions shall be without prejudice to the filing of criminal charges against the individuals responsible

operates or would operate as a fraud or deceit upon any person." security "(1) to employ any device, scheme, or artifice to defraud, or (2) to obtain money or property by means of any untrue statement of a material fact or any omission to state a material fact . . ., or (3) to engage in any transaction, practice, or course of business which Section 26 of the SRC makes it unlawful for any person in the offer or sale of any

public, rather than upon the intent or culpability of the person responsible. In other words, the allegations involves a transaction, practice, or course of business which operates or practice, or course of business which operates or would operate as a fraud or deceit, that it plainly focuses upon the effect of particular conduct on members of the investing to Section 26(3) of the SRC as the provision violated by the Respondents, it appearing that would operate as a fraud or deceit upon any person. A perusal of the Formal Charge will readily reveal that the Complainant is pointing It is quite clear in Section 26 (3)'s language, "to engage in any transaction,

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for violation of this Section a showing of deliberate intent to defraud is not required as a condition precedent to protecting investors.

transactions for dishonest purpose or moral obliquity, which resulted to the prejudice acts are not just mere gross inexcusable negligence amounting to bad faith as stated by the and repeated wrongful and unlawful acts involving huge amounts of securities and damage of investors. repeatedly, consciously and intentionally, for several years (2012 to 2019), failed and ignored to comply with the pertinent regulations and provisions of the SRC and its IRR. The acts of the Respondents are conscious and intentional to do wrongful acts. These acts undoubtedly show evident bad faith on the part of the Respondents. These Complainant. The Respondents should not get away from the consequences of their several In the present case, we found that the Respondents

obliquity. Thus, in Securities and Exchange Commission v. Honorable Court of Appeals et al., 73 the Honorable Supreme Court held: conscious and intentional design to do a wrongful act for a dishonest purpose or moral Based on Section 26.3 of the SRC, "fraud" is akin to bad faith, which implies a

it is unlike that of the negative idea of negligence in that fraud or bad faith contemplates a state of mind affirmatively operating with furtive objectives. xxx" (Underscoring supplied) "To constitute, however, a violation of the Revised Securities Act that not mere negligence, on the part of the offender must be established. Fraud here is akin to bad faith which implies a copscious and intentional design to do a wrongful act for a dishonest purpose or moral obliquity: can warrant an imposition of a fine under Section 29(3) [now Section 26(3) of the SRC], in relation to Section 46 of the Act, fraud or deceit,

the Honorable SupremeCourtheld: public interest, and are thus subject to strict public regulation. In the same case of Abacus, It is worthy to mention that transactions involving securities are impressed with

t h us m an d at o ry ." (Underscoring supplied) public regulation. In particular, the laws and regulations requiring the economy from excessive stock market speculations, and are "Stock market transactions affect the general public and the national economy. The rise and fall of stock market indices _reflect to a considerable degree the state of the economy.Trendsin stock prices tend to herald.changes in business conditions._Consequently. securities transactions are impressed with public interest and are thus subject to payment of traded shares within specified periods are meant to protect

it is presumed that a person takes ordinary care of his concerns and that private transactions have been fair and regular. The(Supreme) Court has stressed time and again that allegations must be proven by sufficient evidence because mere allegation is definitely who alleges fraud or mistake affecting a transaction must substantiate his allegation, since same unavailing. In this case, the Supreme Court states that "as to fraud, the rule is that he As to Respondents allusion to the case of Spouses Ramos v. Obispo74 we find the

73 G.R. Nos. 106425 & 106431-32, (July 21, 1995) 74 G.R. No. 193804, 27 February 2013

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not evidence. Moreover, fraud is not presumed - it must be proved by clear and convincing evidence."

Supreme Court ruled that: In the case of Republic of the Philippines vs. Mega Pacific Esolutions, Inc., et.al. 75 the

evidence and can well be inferred from attendant circumstances. Fraud by its While fraud cannot be presumed, it need not be proved by direct

physically; it must of necessity be proved in many cases by inferences from circumstances shown to have been involved in the transaction in question. nature is not a thing susceptible of ocular observation or readily demonstrable

demonstrating the commission of a conscious and intentional design to do a wrongful act amounting to bad faith by the Respondents pertaining to the Sulapas account transactions. is tantamount to fraud for purposes of Section 26(3) of the SRC, to the prejudice of the investors. Here, Respondents Aguilar and Balabis are liable for fraud due to their evident bad faith in doing the above-mentioned wrongful acts for dishonest purpose or moral obliquity which In the case at bar, Complainant has sufficiently discharged the burden of

fact in their course of action. Julieto Sulapas to transact relating to the latter's account with VSI, while it may be true Moron, being the trading floor assistant settlement officer of R&L, to be authorized to transact Mr. Sulapas account with VSI, yet the glaring fact is that whenever Ms. Mosenabre called R&L to discuss and/or confirm EQ trade transactions, it was only Mr. Moron who was available to answer her inquiries. Certainly, Ms. Aguilar do not dispute that she knew Mr. Moron was the trading floor assistant/settlement clerk of R&L. That fact is suspicious in itself, and should alert all VSI officers and employees genuinely minded in pursuing good and best practices in securities transactions not to ignore such that Respondents did not elicit any suspicions because there is no prohibition for Mr. Anent the matter on authorizing Marlo Moron to be the authorized person of

situation, the more natural thing for them to do after knowing that Mr. Moron is the would be to verify the legitimacy of the transactions with other employees or officers of transact on Mr. Sulapas Account with VSI and the person who will discuss and/or confirm the EQ trade transactions from R&L with them at the same time without eliciting any suspicions, were unnatural to be believable and contrary to human experience. In this authorized person and the person who will also confirm the transaction at the same time, R&L. Indeed, the Respondents' act of allowing Mr. Moron as the authorized person to

document without reading the contents thereof. Given the circumstances, we have sufficient basis to believe that there is thus a doubt as to the execution of the Supplemental Affidavit alleges that he does not remember authorizing Mr. Moron to execute trade transactions in his name although he acknowledges that he signed a authorization. Besides, it may be worth noting that Mr. Sulapas in paragraph 3(xxi) of his

SRC pursuant to Section 51.2 of the SRC which provides that "it shall be unlawful for any As regards Ms. Mosenabre, she would likewise be liable under Section 26 of the

75 G.R. No. 184666, June 27, 2016

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Sulapas. Her failure to perform her obligation resulted to the prejudice of the investors. the completeness of the EQ Trade transactions including the written authorizations of Mr. person, directly, or indirectly, to do any act or thing which it would be unlawful'for such person to do under the provisions of this Code or any rule or regulation thereunder." As mentioned above, as the Settlement Officer of VSI, she has failed on her obligation to verify

Balabis and Monsenabre are found to have violated Sections 26.3 in relation to Section 54 of the SRC. From the foregoing and based on our previous discussions, Respondents Aguilar.

I. On the Charge for violation of Section 51 in relation to Section 26 of the Securities Regulation Code (Wilfred Racadio)

26 of the SRC on the following reasons: 76 In the Formal Charge, Complainant is accusing Mr. Racadio for violation of Section

1. The officers and employees of VSI glaringly failed to perform their duties in connection with the transactions of the Julieto Sulapas accounts, amounting to bad faith, and

liable with Venture Securities officers and employees. 2. As president, he has the duty to oversee the day-to-day operations of the company. Apparently, he failed to perform his duties in this case. Applying Section 51 of the Securities Regulation Code makes Wilfred Racadio jointly and severally

In the Answer, Mr. Racadio disputed the accusations and alleged, that: 77

to Section 26 of the SRC; 1. There is also no basis to find Mr. Racadio liable under Section 51.1 in relation

2. Based on the allegations in the Formal Charge, Mr. Racadio has not controlled or otherwise, or in connection with any agreement or any understanding in 26 of the SRC; any person liable under the SRC or the SRC-IRR through stock ownership, agency. connection with the commission of any of the fraudulent transactions in Section

3. It appears from the Formal Charge that the commission of the fraudulent Venture Securities, and Mr. Racadio does not personally know Mr. Moron. Mr. Racadio also does not control the actions of Mr. Sulapas in any way. Mr. Sulapas is knowledge, judgment, and funds. There are not even any allegations of conspiracy among Mr. Racadio, Mr. Moron, and Mr. Sulapas; transactions originated and was consummated inside R&L. Mr. Racadio does not control the actions of Mr. Moron in any way. Mr. Moron is not an employee of a client of Venture Securities, and he executed all his trades based on his own

76 Page 17 of the Formal Charge 77 Pages 31-32 of the Answer

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transactions described under the SRC; 4. There are no specific acts of Mr. Racadio in the Formal Charge showing that he controlled Mr. Moron and/or Mr. Sulapas to commit any of the fraudulent

Section 51 of the SRC, Mr. Racadio has exercised due diligence in the performance he had no knowledge of facts by reason of which the other Respondents would be guilty of bad faith much less of fraud. As discussed in the previous section, there is no basis to state that Ms. Aguilar, Mr. Balabis, and Ms. Mosenabre committed gross and inexcusable negligence that would amount to bad faith; does not control Ms. Aguilar, Mr. Balabis, and/or Ms. Mosenabre "by or through stock ownership, agency, or otherwise or in connection with an agreement or understating." Moreover, assuming without admitting that he is covered by of his duties, including but not limited to making sure that the proper and sufficient internal control systems and procedures were in place, and despite this 5. In addition, Mr. Racadio is not covered by Section 51.1 of the SRC because he

6. Based on the foregoing, there is no basis to find Mr. Racadio for any fraudulent Section 51.1 of the SRC; transactions under Section 26 of the SRC and Rule 26.1 of the SRC-IRR under

We are not persuaded by Mr. Racadio's arguments. The liability of Mr. Racadio is more straightforward.

circumspect in approving the prohibited credit line facility. circumstances would have cautioned him from approving the credit line. As the President and member of the board of directors, it is incumbent upon him to have been more to 40% the value of his alleged stock position equivalent to Php44,639,825.00 despite the notwithstanding the obvious warning sign that Sulapas' Financial capacity per his CAIF is only Php 1,000,000.00. Thus, he intentionally failed to observe his fiduciary duty when he approved the credit line facility to Mr. Sulapas. Had he fulfilled his fiduciary duty, the above fact that the Sulapas account is not a Margin Account but a Cash Account and First, he unlawfully approved the Credit Line for Sulapas' account amounting to up

shares pursuant to the margin requirements under Section 48 of the SRC and Rule 48 of the IRR. Respondents, including Racadio had the clear obligation to liquidate the shares of stock on the next business day from the settlement date but not beyond ten (10) business days. The reason for the liquidation is that VSI and Racadio are forbidden from extending or arranging for the extension of credit to or for Mr. Sulapas cash account in purchasing pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares transactions within three (3) business days from the transaction date. Second, Respondent Racadio did not liquidate the shares on numerous transactions

Laundering Council. Hundred Thousand Pesos (Php 500,000.00) and prepared for the same day do not discount his participation to remove the Sulapas transactions from the purview of the Anti-Money Third, the fact that Respondent Racadio signed the multiple checks lower than Five

following facts as discussed above: Respondent Racadio's liability under Section 26(3) of the SRC is also laid bare by the

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financial capacity on numerous occasions. 1: Allowing Mr. Sulapas to transact in his securities transactions beyond his

2. Failure to maintain and implement the corporation's internal supervisory control procedures.

3. Failure to discharge his supervisory and control responsibility to stop the illegal activities of his subordinates

bad faith in consciously doing the above-mentioned wrongful acts for dishonest SRC, to the prejudice of the investors. moral obliquity which is tantamount to fraud within the contemplation of Section 26(3) of the To our mind, this only goes to show that Mr. Racadio would be liable for fraud in his purnose

interest of the corporation and investors. stockholders and other stakeholders. On this, he should exercise not only care and diligence but utmost good faith and fair dealings in the management of the corporate affairs in the As a director and president of VSI, he holds a fiduciary relation to the corporation

to the prejudice and damage of the investors. Thus, Respondent Racadio should be held liable for his wrongful acts, which resulted.

Rules 30.2.6.1 and 30.2.6.3 of the 2015 SRC Rules (Racadio and Aguilar) On the Charge for violation of

In the Formal Charge, Complainant alleged that: 78 1. As an Associated Person, Adora Aguilar's primary duty includes overseeing the operations of the company and the supervision of its employees. 2. However, the following circumstances show lapses in employing effective Aguilar: compliance functions in Venture Securities by the Associated Person Adora

a. Inaccuracies in the CAIF of Julieto Sulapas, including the failure to indicate his other accounts with another brokerage firm; b. Improper classification of Julieto Sulapas account as cash account instead of margin account, despite the existence of a credit line agreement; c. Lack of further inquiry as to the large amount of stock transactions of Julieto Sulapas way beyond his declared annual income in the CAIF; and, d. There were transfers of shares that were not supported with written instructions signed by Sulapas.

78 Page 20 of the Formal Charge

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3. Likewise, the President Wilfred Racadio has the duty to oversee the day-to-day to transfer show the neglect and failure Wilfred Racadio to perform his duties as CAIF, the improper classification of the Julieto Sulapas account, the lack of inquiry as to the large transactions involved and the lack of written instructions president to implement proper internal control procedures. operations of VSI, including its internal controls. However, the inaccuracies in the

In their answer, Respondents countered: 79

Securities; 1. Mr. Racadio and Ms. Aguilar likewise cannot be held liable for violating Rule 30.2.6.1 and Rule 30.2.6.3 regarding the compliance functions inside Venture

of Mr. Sulapas are in accordance with his trading profile. Moreover, Mr. Racadio 2. As already discussed above, the numerous amount of buy and sell transactions and Ms. Aguilar has determined that Mr. Sulapas is able to sustain funding for his

financial capacity enter to into this amount of transactions: transactions almost entirely from his trading activities. Thus, it was well within his

his CAIF did not render the transactions he entered into as fraudulent; 3. As discussed above, Ms. Aguilar repeatedly required Mr. Sulapas to correct and Venture Securities just duly noted that Mr. Sulapas has another account with another broker dealer. Furthermore, the failure on the part of Mr. Sulapas to update update his information in his CAIF. Ms. Aguilar, however, cannot commit a felony or offense just to make sure that the CAIF reflects the correct information. Instead,

by the client for "transfer in" requests; 4. Mr. Racadio and Ms. Aguilar ensured all of the "transfer out" requests of Mr Sulapas are in writing and signed by him. As regards transfer in" requests, there is no requirement under the relevant laws and rules for a written request duly signed

5. Lastly, Mr. Racadio and Ms. Aguilar properly classified the account of Mr. Sulapas as a cash account;

We agree with the Complainant.

independent of all operational and business functions. The relevant portion of the quoted maintain an appropriate and effective compliance function within the firm which is provision, provides: SRC Rule Section 30.2.6 requires the management of Broker Dealer to establish and

30.2.6. Supervision

Sec. 30.2.6.1. The management of every Broker Dealer shall establish and maintain an appropriate and effective compliance function within the firm which is independent of all operational and business functions. The compliance function shall be performed by an Associated Person who shall be registered with the Commission and required to report directly to the board of directors and the company President. The management shall ensure that the Associated Person/s performing the compliance function possesses sufficient training and experience in]

79 Pages 36-37 of the Answer

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firm enabling them to effectively execute their duties. securities regulation matters and an understanding of the securities activities of the

XXXXXXXXX

Associated Person/s in the conduct of their compliance function. Broker Dealer company, diligence of a good father of the family is required from the Sec. 30.2.6.3. Although final responsibility for proper supervision shall r . with the

Associated Persons new/renewal license taken by management on the said occurrences. Such logbook must be duly 30.2.6.4. Associated Persons shall promptly report to management all occurrences of material non-compliance by the company or its staff with legal and regulatory organization of which such Broker Dealer is a trading participant of such findings and action taken. For this purpose, the Associated Person must maintain a logbook of all material non-compliance reports with the appropriate notation of the action registered with the Commission within fifteen (IS) days from issuance of the Management shall then promptly notify the Commission and any self-regulatory requirements, as well as with the company's own policies and procedures.

by its employees and agents. function by the management of a Trading Participant is mandatory to properly address and effectively rectify the violations, irregularities, infractions From the above, the establishment of an effective and appropriate compliance or unusual activities committed

shown that an appropriate and effective compliance functions have not been implemented. established and maintained. They failed to show that VSI supervisory and compliance system is reasonably designed to achieve compliance with the applicable laws and regulations. In the case at bar, VSI, Ms. Aguilar and Mr. Racadio's actions have substantially.

and effective compliance function within the company. Racadio and Aguilar willfully failed to implement, establish and maintain an appropriate As discussed above, the following surrounding circumstances have shown that VSI.

(1) Mr. Balabis is not present during the Sulapas account opening.

but he was allowed to transact beyond his declared financial capacity. (2) The Financial Capacity of Mr. Sulapas indicated in his CAIF is only P1,000,000.00

he has existing account with another broker, R&L. any other account with other broker dealers notwithstanding Ms. Aguilar knowledge that (3) Respondents allowed Mr. Sulapas to indicate in his CAIF that he does not have

(4) Respondents failure to require Mr. Sulapas to update his CAIF.

from Mr. Sulapas. (4) Respondents allowed the execution of EQ Trade without written authorization

Account. (5) The unlawful granting of Credit Line to Sulapas account which is not a Margin

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transactions pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares within three (3) business days from the transaction date. (6) As Cash Account, Respondents failed to liquidate the shares in some

Thousand Pesos (Php 500,000.00) prepared for the same day to remove the Sulapas transactions from the purview of the Anti-Money Laundering Council. (7) Respondents VSI and Racadio issued multiple checks lower than Five Hundred

responsibility for proper supervision rest with the Broker Dealer company. violated the pertinent provision of the Supervision Rule, but also VSI since the final From the foregoing, the panel concludes that not only Ms. Aguilar and Mr. Racadic

Racadio, Adora Aguilar and Loreto Balabis) Section 30.2.1.1 of the 2015 SRC Rules (Ventures Securities, Wilfred K. On the Charge for violation of

In this charge, the Complainant stated that: 80

Information Form (CAIF) himself but simply gave Marlo Moron a blank CAIF (without verification of the contents of the Julieto Sulapas CAIF). 1. Loreto Balabis did not see Julieto Sulapas fill out the Customer Account

2.There are EQ Trades involving the Julieto Sulapas account without written request and/or with unsigned requests.

3. Adora Aguilar did not require Julieto Sulapas to correct his answers in the CAIF Sulapas has an account with R&L. as to the existence of an account with other brokers even if she knew that Julieto.

instructed on behalf of Julieto Sulapas. 4. Marlo Moron was allowed as authorized .person of Julieto Sulapas despite knowledge that he is a trading floor assistant/settlement clerk in R&L where the subject EQ trades originated. It has also been revealed during the investigative proceedings that Venture officers relied on the confirmation of Marlo Moron as the alleged settlement officer of R&L for transactions that Marlo Moron himself

5. The above mentioned circumstances clearly show that Venture and its officers maintained commercial honor and principles below the required high standards of the SRC.

standard honor and trade principles of the officers and employees of Venture Securities with the high standards of commercial honor and just and equitable Implementing Rules and Regulations. The acts committed which are below the 6. Wilfred Racadio, the President of Venture Securities, has the duty to oversee the day to day operations of the broker dealer, including the observance of Venture principles of trade as required under the Securities Regulation Code and its

80 Page 17-18 of the Formal Charge

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Securities as discussed above clearly shows the failure of Wilfred Racadio to perform his duties as the President of the company.

In their defense, the Respondents answered: 81

equitable principles of trade in relation to the account of Mr. Sulapas; Balabis under Section 30.2.1.1 of the SRC-IRR. Venture Securities, Mr. Racadio, Ms. Aguilar, and Mr. Balabis observed high standards of comimercial honor and just 1. There is also no basis to find Venture Securities, Mr. Racadio, Ms. Aguilar, and Mr.

internet. It bears stressing that the account of Mr. Sulapas was created at the time of his visit to the office of VSI, after verifying the information he provided, and after 32 determining his financial situation, investment objective, and investment 2. As already discussed above, Mr. Sulapas filled out his CAIF at the time he visited the office of Venture Securities on 29 May 2012. There is nothing unethical on the part of Mr. Balabis in giving a blank CAIF to Mr. Moron for Mr. Sulapas to fill up. The account opening forms of other broker dealers can be downloaded freely from the experience;

account of Mr. Sulapas from 2012-2019; relied on the presumption of regularity and the watchful eyes of CMIC that R&L complies with the requirements for the SRC-IRR as regards the transfer out" requests of Mr. Sulapas and that R&L was only transferring shares coming from the 3. All of the transfer out" requests of Mr. Sulapas contained a written authority regarding the expected stock transfer and position of the client. Moreover, VSI coming from him in accordance with the SRC-IRR. As regards "transfer in" requests, VSI found the client's advice regarding "transfer in" requests is sufficient for purposes of internal control because it gives sufficient and timely information

fraudulent; another account with another broker dealer. Furthermore, the failure on the part of Mr. Sulapas to update his CAIF did not render the transactions he entered into as 4. Ms. Aguilar required Mr. Sulapas to correct and update his information in his CAIF. Ms. Aguilar, however; cannot commit a felony or offense just to make sure that the CAIF reflects the correct information. This would be inconsistent with the high standards of commercial honor and just equitable principles of trade observed by VSI and its employees. Instead, VSI had duly noted that Mr. Sulapas maintained

representatives. It was also Mr. Sulapas who primarily transacted for his account; 5. There is no prohibition under the SRC or the SRC-IRR for Mr. Moron, as the authority other than the usual authority given by other clients to their authorized trading floor assistant / settlement of R&L, to be authorized to transact Mr. Sulapas account with Venture. Moreover, Mr. Moron was not granted any special or unusual

81 Page 32-33 of the Answer acted below the said high standards of commercial honor and just equitable 6. As the President of VSI, Mr. Racadio always makes sure that VSI and its employees observe high standards of commercial honor and just equitable show exactly how the Company and its employees observe the same. The allegations in the Formal Charge show no basis to find that VSI and its employees principles of trade in relation to the account of Mr. Sulapas. The above examples

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addition, since Mr. Racadio is not a registered person, he cannot be held liable under Section 30.2.1.1 of the SRC-IRR: VSI did not commit any felony or offense just for the purposes of compliance. In principles of trade. There were no laws and rules violated, and the employees of

principles of trade. As such, adherence to Rule 30.2.1 must be strictly observed, to wit: that every Broker Dealer, Associated Persons and Salesman, in the conduct of his business; shall observe high standards of commercial honor and just and equitable In dealing in securities, the Ethical Standards Rule, which, in substance, requires

Rule. 30.2.1. Ethical Standards Rules

shall observe high standards of commercial honor and just and equitable principles 30.2.1.1. Every Broker Dealer, Associated Person and salesman of a Broker Dealer (hereinafter referred to as a "registered person"), in the conduct of his business, of trade.

standards and may constitute grounds for the imposition of administrative sanctions, to Wit: acts and practices willfully committed by Respondents are considered contrary to such Under the broad-spectrum concept of the Ethical Standards Rule, the foregoing

(1) Mr. Balabis was not present during the Sulapas account opening.

P1,000,000.00 but he was allowed by Respondents to transact beyond his declared financial capacity. (2) The Financial Capacity of Mr. Sulapas indicated in his CAIF is only

knowledge that he has existing account with another broker, R&L. have any other account with other broker dealers notwithstanding Ms. Aguilar (3) Respondents allowed Mr. Sulapas to indicate in his CAIF that he does not

(4) Respondents failure to require Mr. Sulapas to update his CAIF.

authorization to do so. (5) Respondents allowed the execution of EQ Trade without written

Margin Account. (6) The unlawful granting of Credit Line to Sulapas account which is not a

transactions pursuant to SRC Rule 50.2 since Mr. Sulapas failed to tender in full the payment of the shares within three (3) business days from the transaction date. (7) As Cash Account, Respondents failed to liquidate the shares in some

Hundred Thousand Pesos (Php 500,000.00) prepared for the same day to remove the Sulapas transactions from the purview of the Anti-Money Laundering Council; and. (8) Respondents VSI and Racadio issued multiple checks lower than Five

(9) For violating all of the above-mentioned SRC and SRC-IRR provisions.

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the wrongful acts mentioned above and as a control person based on his failure to supervise VSI registered representatives. not a registered person, he would likewise be liable under the Rule for his participation in Contrary to the claim of Mr. Racadio that he is not liable under the Rule since he is

of the capital market. and just and equitable principles oftrade and to act honestly and fairly for the integrity their business and profession, failed to observe high standards of commercial honor Evidently, the Respondents VSI, Racadio, Aguilar and Balabis in the conduct of

to allege the ultimate facts showing any Regulation Code and it Implementing Rules and Regulations IV. Whether or not the Formal Charge failed culpability of the Respondents for the alleged violations ofthe Securities

V. Whether or not Respondent sufficiently denied the allegations of facts in the Formal Charged.

respective Formal Charge and Verified Answer. facts, respectively, need not be discussed further since this was already cured when both submitted their evidence, documents and affidavit of witnesses in their respective Position Papers and Comments/Reply that would support their factual allegations in their specifically deny the allegation of facts in the Formal Charged and failure to allege ultimate These remaining issues raised by Complainant and Respondents namely failure to

bound by the strict application of the Rules of Procedures. Further, as already discussed above, the Commission as administrative body is not

FINAL NOTE

contributed, if not they had been the proximate cause of the losses incurred by the clients of R&L. The foregoing acts and violations committed by the Respondents indispensably

tend to diminish the faith of the investors on the integrity of the capital market. the capital market which would violate the norm set by the securities law especially on the transactions and responsibilities of Broker Dealers and that would diminish or even just We cannot tolerate and ignore any act or omission on the part of those involved in

performance of their duties as officers, registered persons or employees. by holding accountable those who consciously and willfully commit wrongful acts in the capital market cannot be tolerated, let alone allowed to perpetuate. This must be curbed Likewise, the practice of installing undiscerning persons in entities involved in the

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the general public and the national economy. We stress that Republic Act No. 8799 otherwise known as the "The Securities Regulation Code," enunciates, inter alia, the State policy of promoting the development of the capital market and the protection of investors.82 The Respondents must be reminded that transactions involving securities affect

Respondents' act and imprimatur on these issues that seriously endanger the integrity of entire securities market. For this Commission to cop-out and to close its eyes to these acts and deeds, while convenient, would be to abandon its duty of safeguarding public interest and the integrity of the capital market. For this reason, it is totally unacceptable and unconscionable to place the

PENALTIES TO BE IMPOSED

other alternative penalties as provided for under Sec. 54.1 of the SRC. (MC 6, s. 2005 or Circular), the Commission, in its discretion, has the power to impose Notwithstanding the provisions of SEC Memorandum Circular No. 6, series of 2005

The pertinent portion of Sec. 54.1 of the SRC is herein reproduced:

Sec. 54.1 - If after due notice and hearing, the Commission finds that: (a) there is a violation of this Code, its rules, or its orders (b) xxx xx xxxxxx, it shall in its discretion, and subject only to the limitations hereinafter xxxxxx (c) xxx XXXxxx (d] prescribed, impose any or all of the following sanctions as may be appropriate in light of the facts and circumstances: (i) Suspension, or revocation of any registration for the offering of securities;

day of continuing violation; (ii) A fine of no less than Ten Thousand pesos (P10,000.00) nor more than One Million Pesos (P1,000,000.00) plus not more than Two Thousand Pesos (P2,000.00) for each

functions, of an issuer required to file reports under Section 17 of this Code or any other act, rule or regulation administered by the Commission; being an officer, member of the Board of Directors, or persons performing similar (iii) In the case of a violation of Sections 19.2, 20, 24, 26 and 27, disqualification from

(iv) In the case of a violation of Section 34, a fine of no more than three (3) times the profit gained or loss avoided as a result of the purchase, sale or communication proscribed by such Section; and (v) Other penalties within the power of the Commission to impose. (emphasis supplied)

devices and practices which create distortions in the free market.To achieve these ends, this Securities itself, encourage the widest participation of ownership in enterprises, enhance the democratization of wealth, promote the development of the capital market, protect investors, ensure full and fair disclosure about securities, minimize if not totally eliminate insider trading and other fraudulent or manipulative Regulation Code is hereby enacted. 82 SEC. 2. Declaration ofState Policy. - The State shall establish a socially conscious, free market that regulates

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the SRC, the Commission adopted SRC Rule 54.1 which mirrors the above-mentioned provision of law, thus: In the implementation of the foregoing and in order to give effect to the intent of

xxxxxx, it shall, in its discretion, and subject only to the limitations hereinafter prescribed, impose any or all of the following sanctions as may be appropriate in light of the facts and circumstances: violation of this Code, its rules, or its orders (b) xxx 54.1 -- If after due notice and hearing, the Commission finds that: (a) there is a XXXXXx(c) xxx xxxxxx (d) xxX

securities; 54.1.1 Suspension, or revocatior of any registration for the offering of

communication proscribed by such Section; and times the profit gained or loss avoided as a result of the purchase, sale or supplied} functions, of an issuer required to file reports under Section 17 of this Code or any other act, rule or regulation administered by the Commission; One Million Pesos (P1,000,000.00) plus not more than Two Thousand Pesos (P2,000.00) for each day of continuing violation; from being an officer, member of the Board of Directors, or persons performing similar 54.1.4. In the case of a violation of Section 34, a fine of no more than three (3) 54.1.5. Other penalties within the power of the Commission to impose. 54.2.2.A fine of no less than Ten Thousand pesos (P10,000.00) nor more than 54.1.3. In the case of a violation ofSections 19.2, 20, 24, 26 and 27, disqualification (er mphasis

flexibility based on its discretion to impose various kinds of sanctions since not all to the facts and circumstances of each situation. sanctions apply in every case and the SEC is empowered to select the sanction appropriate On the basis of the above-quoted provisions, it is clear that the Code gives the SEC

be Php1,000,000.00. penalties against a Company and any person found administratively liable for violating any provision of the SRC and its IRR. If fine alone is the penalty imposed, the maximum shall The Commission may thus impose any of the above-mentioned alternative

based on its discretion. hereinafter prescribed, impose any or all of the following sanctions as may be appropriate in light of the facts and circumstances " operates to confer discretion to SEC to select the sanction appropriate to the facts and circumstances of each case. Applying Section 54.1, therefore, it does not prohibit the Commission to impose sanction To emphasize, the phrase "in its discretion, and subject only to the limitations

be applied as an alternative penalty on the penalties imposed under MC 6, s.2005, which was issued purposely to rationalize the penalties to be imposed by the Commission to insure strict compliance with the Code and its IRR. Thus, it could be said that the appropriate penalty under Sec. 54.1 of the SRC may

sanctions or to the filing of criminal charges against the person/s responsible for the the foregoing penalties shall be without prejudice to the imposition of other administrative violation. Likewise, under the same provision of the Circular it states that the imposition of

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in the application of the penalties provided for in the SRC. application of SRC Section 54 as an alternative penalty, but to lay down a rule of preference The clear tenor and intention of Memorandum Circular is not to remove the

legislative intent behind the law. Section 54 for violators of any of the provision of the SRC. Neither does it defeat the The pursuit of this purpose clearly does not foreclose the possibility of applying

Memorandum Circular No. 6 Series of 2005 ought not be deemed a hindrance. of the provision under Section 54 of the SRC is the more appropriate penalty, circumstances of both the offense and the offender clearly indicate good faith or a clear mistake of fact without taint of bad faith or negligence, otherwise, the imposition of a fine under the SRC should be considered as the more appropriate penalty. Needless to say, the determination of whether the circumstances warrant the imposition of a fine under the SRC provision rests solely upon the Commission. Should the Commission decide that any of the administrative monetary penalty provision of SRC such that where the Hence, the Memorandum Circular establishes a rule of preference in the application

SRC as an alternative penalty for violations of any of the provision of the SRC and its IRR. does not remove the imposition of any of the penalty provided for under Section 54 of the It is, therefore, understood that SEC Memorandum Circular No. 6 Series of 2005

Further, Section 29 of the SRC provides:

Code may be refused, or any registration granted thereunder may be revoked, suspended, or limitations placed thereon, by the Commission if, after due notice and hearing the Commission determines the application or registrant. Section 29. Revocation, Refusal or Suspension of Registration of Brokers, Dealers. Salesmen and Associated Persons. - 29.1. Registration under Section 28 of this

with a view to preventing such violation, another person who commits such violation; case of a registered broker, dealer or associated persons has failed to supervise. made hereunder, or any other law administered by the Commission, or in the (a) Has willfully violated any provision of this Code, any rule, regulation or order

the following administrative sanctions: the above-mentioned pertinent provisions of the SRC and the SRC IRR and hereby imposed WHEREFORE, premises considered, the panel finds that the Respondents violated

A. Yenture Securities. Inc.

1. A fine of One Million Pesos (P1,000,000.00) for violation of Rule. 30.2.1. (Ethical Standards Rules)

2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.3. (Capabilities)

3. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.4. (Information About Clients)

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4. A fine of One Million Pesos (P1,000,000.00) for violation of Sections 48.2 and SRC Rule 48.2 - (Prohibitions on Extension of Credit)

5. A fine of 0ne Million Pesos (P1,000,000.00) for violation of Section 50 of the SRC and SRC Rule 50 (Purchases and Sales in Cash Account)

6. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.1. [Books and Records Rule)

7. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.6. (Customer Account Information Rule)

8. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.6. (Supervision)

9. Revocation of its license/registration as broker/dealer pursuant to Section 29 of the SRC for willfully violating all of the above-mentioned provisions of the SRC and the SRC IRR

B. Mr. Wilfred Racadio

1. A fine of One Million Pesos (P1,000,000.00) for violation of Sec. 51 in relation to Sec. 26 of the SRC and disqualification from being an officer, member of the Board of Of the SRC. Directors or person performing similar functions pursuant to Sections 54.1, 28 and 29

2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule. 30.2.1. (Ethical Standards Rules)

4. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.3. (Capabilities)

5. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.4. (Information About Clients)

6. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.6.

(Supervision).

7. A fine of One Million Pesos (P1,000,000.00) for violation of Sections 48.2 of the SRC and SRC Rule 48.2 - (Prohibitions on Extension of Credit)

8. A fine of One Million Pesos (P1,000,000.00) for violation of Section 50 of the SRC and Rule 50 (Purchases and Sales in Cash Account)

9. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.1. (Books and Records Rule)

10. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.6. (Customer Account Information Rule)

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11. Disqualification from being a registered person pursuant to Sections 28 and 29 of the SRC

C.Ms. Adora Aguilar

1. A fine of One Million Pesos (P1,000,000.00) for violation of Sec. 26 in relation to 54 of the SRC and revocation of her license as Associated Person pursuant to Section 54.1 of the SRC.

2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule. 30.2.1. (Ethical Standards Rules)

3. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.3. (Capabilities}

4. A fine of One Million Pesos (P1,000,000.00).for violation of Rule 30.2.1.2.4. (Information About Clients)

5. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.6. (Supervision).

6. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 34 (Segregation and Limitation of Functions of Members, Brokers and Dealers)

I. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.1. (Books and Records Rule}

8. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.6. (Customer Account Information Rule)

9. Disqualification from being a registered person pursuant to Sections 28 and 29 of the SRC

10. Disqualification from being an officer, member of the Board of Directors or person performing similar functions pursuant to Section 54.1 of the SRC

D. Mr. Loreto Balabis

1. A fine of One Million Pesos (P1,000,000.00) for violation of Sec. 26 in relation to 54 of the SRC and revocation of his license as salesman of securities pursuant to Section 54.1 of the SRC.

2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule. 30.2.1. (Ethical Standards Rules)

3. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.3. (Capabilities)

4. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 30.2.1.2.4. (Information About Clients)

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5. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.6. (Customer Account Information Rule)

6. Disqualification from being a registered person pursuant to Sections 28 and 29 of the SRC

7. Disqualification from being an officer, member of the Board of Directors or person performing similar functions pursuant to Section 54.1 of the SRC E. Ms. Teresita Mosenabre

1. A fine of One Million Pesos (P1,000,000.00) for violation of Sec. 26 in relation to 54 of the SRC.

2. A fine of One Million Pesos (P1,000,000.00) for violation of Rule 52.1.1. (Books and Records Rule)

3. Disqualification from being a registered person pursuant to Sections 28 and 29 of the SRC

performing similar functions pursuant to Section 54.1 of the SRC 4. Disqualification from being an officer, member of the Board of Directors or person

severally liable for the monetary penalty imposed on its officers and employees. In sum. the total monetary penalties imposed upon all Respondents amount to Thirty-Two Million Pesos (Php 32,000,000.00). and to the same extent as the controlled persons, VSI and Mr. Racadio are held jointly and for proper supervision shall rest with the Broker Dealer Company and Section 51 of the SRC, which states that the controlling person shall also be liable jointly and severally with In conformity with SRC Rule 30.2.6.3, which provides that the final responsibility

charge responsible persons on the actual count or occurrences of violations committed. Investigation and Review Committee of MSRD may institute on the basis of evidence that it may, now or hereafter secure, including among others, to institute further action to Finally, this Decision is without prejudice to any further action that the

SO ORDERED."

11 June 2021.

ARL Chairman LONG.FACUM

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EMMA A. VALENCIA Member WIN EDWARD P. MENDINUETO Member 1

Copy furnished:

Secretariat Building, PICC Complex, Markets and Securities Regulation Department Securities and Exchange Commission Roxas Boulevard, Pasay City. ASSISTANT DIRECTOR ADAN EVAN O. PASCUA

8th Floor STI Holdings Center, VENTURE SECURITIES, INC. 6764 Ayala Avenue, Makati City.

WILFRED RACADIO 8th Floor STI Holdings Center, 6764 Ayala Avenue, Makati City.

8th Floor STI Holdings Center, 6764 Ayala Avenue, Makati City. ADORA AGUILAR

LORETO BALABIS 8th Floor STI Holdings Center, 6764 Ayala Avenue, Makati City

TERESITA MOSENABRE 8th Floor STI Holdings Center, 6764 Ayala Avenue, Makati City.

HERRERA TEEHANKEE & CABRERA Counsel for Respondents 5th Floor, SGV II Building, 6758 Ayala Avenue, 1200 Makati City

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