Internal Policy

Internal Policy

SEBI vide its Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September, 2014 has notified SEBI (Research Analysts) Regulations, 2014. These regulations have been introduced by SEBI with the objective of fostering transparency in security research and provide the investors with more reliable and useful information to make investment decisions. Suhani Adilabadkar, a SEBI-registered Research Analyst (Registration Number (INH200003240) has adopted the followinginternal policies and control procedures to fulfill compliance with SEBI Regulations.

APPLICABILITY

The policy is applicable to Suhani Adilabadkar, SEBI Registered Research Analyst (INH200003240) for preparation and publication of research report and making ‘buy, sell/hold’ recommendation and giving price target or offering an opinion on any security that are listed or to be listed in a Stock Exchange.

DEFINITIONS

Research Analyst” means an RA who is primarily responsible preparation or publication of the content of the research report or providing research report or making ‘buy/sell/hold’ or ‘Overweight / Underweight’ recommendation or giving price target or offering an opinion concerning public offer.

Relative means a person as defined in sub section (77) of section 2 of the Companies Act, 2013 and who is financially dependent on independent research analyst or individual research analyst employed by research entity.

Price Target refers to Research Analyst’s projected future performance of specific securities.

PublicAppearance means participation in any conference call, seminar, forum, or media (electronic, radio, television, print, or internet) where a Research Analyst offers an opinion on securities or a public offer. This does not include private, password-protected events, provided that participants have received required disclosures in advance.

Public Offerrefers toinitial public offers (IPO), further public offers (FPO), offers for sale, disinvestment, takeovers, buy-backs, or delistings.

Research Reportrefers to any communication (written or electronic) containing research analysis, recommendations, or opinions on securities or public offers that provide a basis for investment decisions.

MANAGEMENT OF CONFLICT OF INTERESTS AND DISCLOSURE REQUIREMENTS

As per SEBI Guidelines, the Research Analyst shall maintain arms-length relationship between its research activity and other activities. Suhani Adilabadkar, SEBI Registered Research Analyst (INH200003240) operates only in research activity and has no other business activity.

LIMITATIONS ON TRADING BY RESEARCH ANALYSTS

The Research Analyst Shall not:

  1. Deal or trade any securities that the research analyst recommends or follows within 30 days before and 5 days after the publication of a research report on the subject company.
  2.  Deal or trade directly or indirectly any securities that he reviews in a manner contrary to his outstanding recommendation, etc
  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, subject to prior written approval from Compliance Officer.

PUBLICATION OF RESEARCH REPORT, PUBLIC APPEARANCE, CONDUCT OF BUSINESS

  • The Research Report issued by Research Analyst shall be based on adequate documentary supported by research
  • Research analyst shall ensure that the recommendations in the research report are corroborated by relevant data and analysis forming the basis for such research service.
  • 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 for the receipt of compensation or other benefits.
  • Research analyst shall disclose any public appearance with regard to receipt of compensation from the subject company in the past twelve months.

DISCLOSURES IN RESEARCH REPORTS

  • 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 any material conflict of interest at the time of publication of research report or at the time of public appearance.
  • Whether Research Analyst or its/his associate or relatives has any Financial interest in the subject company.
  • Details of any compensation received by Research Analyst or its/his/her/their associates from the subject company in past 12 months.
  • Details of any compensation or other benefits received by Research Analyst from the Subject Company or 3rd party in connection with the research report.

Other Conditions

  • The Research Analyst shall provide signed and dated research reports.
  • Provide recommendations with rationale.
  • The Research Analyst operates twitter (X) handle @SuhaniEqAnalyst but does give any recommendation on this social media platforms.

Suhani Adialbadkar

INH200003240

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