The bank's clarification states that "employees, including retired employees, had the choice to exercise their ESOPs anytime up to a period of 10 years from the date of vesting", Khera said, adding that however, the only ESOP policy ICICI has publicly disclosed on its website is the one uploaded on the US Securities Exchange Commission (SEC) website, and it clearly states that former employees can exercise their ESOPs within a maximum of three months following their voluntary termination. Where is this "revised policy" under which Buch was able to exercise ESOPs eight years after the voluntary termination of her services, the Congress leader asked. "Why hasn't the revised policy been made publicly available by the ICICI? Why was Ms Madhabi Buch allowed to exercise ESOPs at a time when the share price of this company increased substantially, thereby benefitting her? And strangely, this benefit that accrued to her coincided with her tenure at the SEBI. Wasn't the market price beneficial to her?" he asked.