While acknowledging that prohibitions against insider trading played an essential role in maintaining the fairness, health and integrity of the capital markets, CII emphasised that the procedures should be suggestive in nature, giving a broad framework of what was expected.

"It should be upto the individual company to assess its needs and to come up with detailed policies and procedures tailored to its business, company structure and unique circumstances," a CII release said.

Noting that Codes of Conduct and Compliance memos were specifically crafted to provide comprehensible guidance to employees, the Chamber said a general acknowledgement from an employee that he or she had read the code and understood it should be sufficient undertaking to avoid undue administrative burden.

On the issue of pre-clearance of trades, CII said not all employees in every firm would need to pre-clear trades and hence this should also be left to each firm to be decided.

While only those employees who may be privy to inside information should be required to pre-clear their trades, other conflicts could be caught in the monitoring of trades post trade date, it said.