INTERNAL POLICIES
DETAILS ABOUT INTERNAL POLICIES AND CONTROL PROCEDURES TO EFFECTIVELY ADDRESS CONFLICT OF INTEREST
The internal policies and control procedures help to promote unbiased research and effectively address conflict of interest which may affect the impartiality of the research analysis and research report/research recommendations. The details about the internal policies and control procedures are as follows:
1. I will not deal or trade in the securities that I have recommended to the clients or followed within 30 days before and 5 days after the publication of research recommendations or research reports.
2. I will not deal or trade directly or indirectly in securities in a manner contrary to the recommendations given to the client.
3. Records will be kept for my personal trading or transactions in securities done by me as the Research Analyst.
4. I will not purchase or receive securities of the issuer before the issuer’s initial public offering if the issuer is principally engaged in the same types of business as companies that I follow or recommend.
5.There will be a clear and defined process for research or selecting securities for recommendations. The process will be followed at all times to avoid any conflict of interest.
6. There will always be an adequate documentary basis, supported by research, for giving recommendations/calls.
7. The aim will always be to promote reliable research that reflects unbiased views. The views and recommendations given by the research analyst will not be affected by any market news.
8. The recommendations will not be used to manipulate the market. The source used for doing research will always be authentic. The information used for research will not be from any source which is not authentic. It will always be ensured that the software used for research and analysis is reliable.
9. If there is any material conflict of interest at the time of giving recommendations adequate disclosures will be given to the clients about the same.
10. The research activities will be clearly segregated from other activities and there will be an arms-length relationship between the activities.
11. The code of conduct will be strictly adhered to, at all times.
OBJECTIVE:
It is mandatory in terms of the Regulations for every Research Analyst to formulate a Code of Conduct. In order to comply with the mandatory requirements of the Regulations, it was necessary to formulate a specific Code of Conduct for me/us. Our policy is only to publish investment research/Recommendations that is impartial, independent, clear, fair and not misleading.
CODE OF CONDUCT:
This Code of Conduct shall be called CODE OF CONDUCT FOR RESEARCH ANALYST (hereinafter referred to as ‘the Code of Conduct’). The Code of Conduct shall come into force with immediate effect.
APPLICABILITY:
This Code of Conduct is applicable to all RESEARCH ANALYSTS and ASSOCIATES, if any of the RESEARCH ANALYST.
IMPORTANT DEFINITIONS:
“Research report” means any written or electronic communication that includes research analysis or research recommendation or an opinion concerning securities or public offer, providing a basis for investment decision except:-
comments on general trends in the securities market;
commentaries on economic, political or market conditions;
Periodic reports prepared for unit holders of mutual fund or alternative investment fund or clients of portfolio managers and investment advisers etc.
“Research analyst” means a person who is primarily responsible for:-
preparation or publication of the content of the research report or providing research report; or
making ‘buy/ sell/ hold’ recommendation or giving price target; or
offering an opinion concerning public offer,
Explanation.- The term also includes any associated person who reports directly or indirectly to such a research analyst in connection with activities provided above.
Any personnel appearing in public media and giving stock specific recommendation will be treated as research analyst and he/she has to follow all the applicable rules and regulations for the same.