How Should I Respond to a Show Cause Notice About My Spouse's Trading Account?

I am currently working in a broking firm. My spouse opened a trading account under a sub-broker. Now, the company has issued a show cause notice regarding trading business carried out under appointment clauses 4 to 13 under the heading "other conditions." As per the notice, I was supposed to disclose all the investments made by me and my family in the primary and secondary equity markets. Additionally, I am expected to abide by all the requirements and policy decisions of the company/SEBI/Exchange in this regard. The notice also states that employees and their family members are debarred from engaging in speculation and trading in the capital market directly or indirectly. I have never seen the company's code of ethics or signed it. While I was required to disclose investments in my appointment, at the time of joining in 2004, no account was opened. The trading account was opened in February 2016. Please guide me on how to prepare a reply.

Considering your situation, it's crucial to respond to the show cause notice with clarity and adherence to relevant policies and regulations. Here is a practical approach to preparing your reply:

Understanding the Situation
- Review the show cause notice thoroughly to grasp the specific allegations and requirements mentioned.
- Gather any relevant documents or evidence that support your case, such as the timing of the trading account opening and any communication regarding disclosure requirements.

Crafting Your Response
1. Acknowledge Receipt: Begin by acknowledging receipt of the show cause notice and express your intent to provide a detailed response.
2. Clarify Timeline: Clearly outline the timeline of events, emphasizing that the trading account was opened after your appointment in 2004 and provide any supporting documentation.
3. Address Code of Ethics: Mention that you never received or signed the company's code of ethics and request a copy to ensure you understand and comply with its provisions.
4. Policy Compliance: Emphasize your commitment to following company policies, SEBI regulations, and Exchange requirements, highlighting your adherence to ethical practices.
5. Declaration of Investments: If required, detail the investments made by you and your family in the primary and secondary equity markets as per the appointment clause.

Closing Statement
- Conclude your response by reiterating your dedication to compliance and cooperation with the company's directives.
- Request a fair assessment of the situation based on the facts presented and seek clarification on any ambiguous points.

It's essential to maintain a professional and respectful tone throughout your response, ensuring clarity and transparency in addressing the concerns raised in the show cause notice.