INTERNAL POLICIES

INTERNAL POLICIES AND PROCEDURES TO EFFECTIVELY ADDRESS CONFLICT OF INTEREST

This policy shall be applicable to Gaurav Sharma i.e.  a person primarily responsible for preparation or publication of the content of the research report; or providing a research report or making recommendation or giving price target or offering an opinion on any security that are listed or to be listed in a Stock Exchange.

1. LIMITATIONS ON TRADING BY RESEARCH ANALYSTS:

Research Analysts shall not

1. deal / trade in securities recommended / followed by the research analyst within 30 days before and five days after the publication of a research report;
2. deal / trade in securities that the research analyst reviews in a manner contrary to his given recommendation;
3. 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 the research analyst follows or recommends.

However, the above restrictions to trade/ deal in securities shall not be applicable in case of significant news or event concerning the subject company or based upon an unanticipated significant change in the personal financial circumstances of the research analyst.

• LIMITATION ON PUBLICATION OF RESEARCH REPORT, PUBLIC APPEARANCE, CONDUCT OF BUSINESS ETC.

• The Research Report issued by Research Analyst shall be based on adequate documentary research evidence.

• Research Analyst shall not provide any promise or assurance of favourable review in research report to the Company or Industry as a consideration to commence or influence a business relationship of for the receipt of compensation or other benefits.

• DISCLOSURES IN RESEARCH REPORT

Research Analyst shall disclose all material information about himself including the following in its research reports:

1. Business Activity
2. Disciplinary History
3. Terms and conditions on which it offers research report
4. Details with respect to Ownership and Material Conflict of Interest such as:
5. Whether Research Analyst or its/his associate or relatives has any Financial interest in the subject company, if yes, together with nature of such financial interest.

• Whether Research Analyst or its/his associate or relatives have actual / beneficial ownership of 1 % or more securities of subject company at the end of the month immediately preceding the date of publication of research report or date of public appearance, as the case may be.

• Details of actual / beneficial ownership of one percent or more securities of the subject company, at the end of month immediately preceding the date of publication the research report or date of public appearance.

• Details of any material conflict of interest at the time of publication of research report or at the time of public appearance.

• Details of any compensation received by Research Analyst or its/his/her/their associates from the subject company in past 12 months.

• Details of whether Research Analyst or its associates have managed or co-managed the public offering of subject company in past 12 months.

• Details of whether Research Analyst or its associates have received any compensation for investment banking or merchant banking of brokerage services from the subject company in past 12 months.

• Details of whether Research Analyst or its associates have received any compensation for products or services other than above from the subject company in past 12 months.

• Details of any compensation or other benefits received by Research Analyst or its/his/her/their associates from the subject company or 3rd party in connection with the research report.

• Research Analyst shall disclose in public appearance with regard to receipt of compensation
• Whether Research Analyst or its/his/her/their associates have received any compensation from the subject company in past 12 months

• Whether the subject company is / was client of Research Analyst during 12 months preceding the date of distribution of research report and the types of such services provided by Research Analyst

• Whether the Research Analyst has served as an officer, director or employee of the subject company.

• Whether Research Analyst has been engaged in market making activity of the subject company

• Such other disclosures in research reports / public appearance as specified by SEBI under any other regulations.

• Such Research Reports reflects the factual information about the subject company and are based on reliable information. Such reports also contain the definition of terms which are used in making recommendations and such terms have been used consistently.

1. If such Research Reports contain either a rating or price target for atleast 1 year, the same shall also provide for the graph of daily closing price of such securities for the period assigned or for a 3 year period, whichever is shorter.

1. Such Research Report Shall not be issued selectively to internal trading personnel or to a particular client or group of other clients in advance of other clients who are entitled to receive the research report.

1. In case, Research Analyst appears in public media and make any recommendation, the disclosure of his / its name, registration status and details of financial interest shall invariably made at the time of making such recommendation or offering any opinion in his personal capacity, responding to any queries of audience or journalists in personal capacity and communicating the research report or its substance through public media.

• OTHER CONDITIONS:

1. Research Analyst shall be NISM Certified or such other certification for research analysts as specified by SEBI.
2. Research Analyst shall maintain and preserve following records for a minimum period of 5 years:
3. Research recommendation provided
4. Rationale for arriving at research recommendation
5. Record of public appearance

• Research Analysts shall forth with inform the Board in writing about any information or particulars about him/her/them submitted to SEBI, which are found to be false or misleading in any material particular or are there is any change in information already submitted.

• Research Analyst shall conduct annual audit in respect of compliance with the captioned SEBI Regulations from member of ICAI or ICSI.