Can an Apprentice/ trainee be considered as an Insider ??

satish (Compliance & Legal) (38 Points)

17 January 2008  
As per Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 1992,

“connected person” means any person who—


(i) is a director, as defined in clause (13) of section 2 of the
Companies Act, 1956 , of a company, or is deemed to be a director of
that company by virtue of sub-clause (10) of section 307 of that Act; or

(ii) occupies the position as an officer or an employee of the company or holds a position involving a professional or business relationship between himself and the company [whether temporary or permanent] and who may reasonably be expected to have an access to unpublished price sensitive information in relation to that company.

And
“insider”
means any person who, is or was connected with the company or is deemed
to have been connected with the company, and who is reasonably expected
to have access to unpublished price sensitive information in respect of
securities of a company, or who has received or has had access to such
unpublished price sensitive information.

Now the query is :

Whether
an apprentice or a trainee can be considered as an insider ? (According to me, he will normally have access to unpublished price sensitive information.)