The Research Analyst commits to preserving all relevant records for a minimum of five years, including:
Signed and dated research reports,
Issued recommendations and rationale,
Records of public appearances and related disclosures.
E. Other Compliance Conditions
The Research Analyst will serve as the compliance officer, overseeing adherence to SEBI’s guidelines, and ensuring that all employees meet the certification and qualification standards mandated by SEBI under Regulation 7.
By: R. Haresh, SEBI-Registered Research Analyst SEBI Registration Number: INH200005656
C. Management of Conflict of Interest and Disclosure Requirements
To maintain objectivity, the Research Analyst upholds an arms-length relationship between research activities and other functions. Specific policies include:
a) Limitations on Trading by Research Analysts
To prevent conflicts:
The Research Analyst’s personal trading activities are monitored, recorded, and may require formal approval.
Neither the Research Analyst nor associates may:
Trade in securities recommended by the Analyst within 30 days before and 5 days after a report is published.
Trade in a manner contrary to recommendations made.
Purchase or receive securities before an IPO if the issuer operates in a similar business.
b) Limitations on Research Reports, Public Appearances, and Business Conduct
The Research Analyst is restricted from publishing or publicly commenting on a subject company under specific circumstances:
IPO or FPO Management:
No publication within 40 days following IPO pricing.
No publication within 10 days following FPO pricing.
Underwriting Restrictions: No publication or public appearance for 25 days following an IPO where the Analyst is the underwriter.
Lock-Up Agreements: No publication 15 days before or after the expiry of a lock-up agreement.
Solicitation Restrictions: The Analyst may not engage in activities, such as sales pitches, that solicit investment or merchant banking services.
Research Independence: Reports are based on verifiable research without any assurance of a favorable review for companies, sectors, or groups as a condition for compensation.
c) Disclosures in Research Reports and Public Appearances
Each report or appearance includes full disclosure on:
Financial Interests: If the Analyst, associates, or relatives hold any financial interest in the subject company.
Ownership: If there is 1% or greater ownership in the subject company.
Conflicts of Interest: Disclosure of any other conflicts, whether from ownership or compensation received.
Additional disclosures cover:
Compensation:
If the Analyst received compensation from the subject company in the last 12 months.
If the Analyst or associates managed or co-managed public offerings for the company.
If any compensation was received for non-investment banking services.
Market-Making Activity: Disclosures cover whether the Analyst or associates engaged in market-making for the company.
d) Research Report Content Requirements
Reports will be clear, reliable, and consistent, including:
Defined rating terminology and benchmarks.
Price target history or performance charts if applicable for over one year.
Consistency in view representation across reports and appearances.
Equal access to reports for all clients without preferential treatment for certain clients.
Review and disclosure of any third-party reports shared with clients.
D. Maintenance of Records
The Research Analyst commits to preserving all relevant records for a minimum of five years, including:
Signed and dated research reports,
Issued recommendations and rationale,
Records of public appearances and related disclosures.
E. Other Compliance Conditions
The Research Analyst will serve as the compliance officer, overseeing adherence to SEBI’s guidelines, and ensuring that all employees meet the certification and qualification standards mandated by SEBI under Regulation 7.
By: R. Haresh, SEBI-Registered Research Analyst SEBI Registration Number: INH200005656
B. Definitions
Terms used within these policies align with the SEBI Regulations and are defined as follows:
Associate: Refers to any individual or entity under direct or indirect control by, or controlling, the intermediary (Research Analyst), or under common control with the intermediary, as defined by SEBI (Intermediaries) Regulations, 2008. For natural persons, this includes relatives, and for corporate entities, it includes group companies and companies under the same management.
Price Target: The Research Analyst’s projected future performance of specific securities.
Public Appearance: 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 Offer: Encompasses initial public offers (IPO), further public offers (FPO), offers for sale, disinvestment, takeovers, buy-backs, or delistings.
Research Analyst: An individual responsible for:
Preparing or publishing research content,
Providing research reports,
Making buy/sell/hold recommendations or price targets,
Offering opinions concerning public offers on listed or proposed-to-be-listed securities. This term also covers associated individuals reporting directly or indirectly to a Research Analyst.
Relative: Defined as per subsection (77) of section 2 of the Companies Act, 2013, it includes financially dependent individuals on the independent research analyst or employees of a research entity.
Research Entity: An SEBI-registered intermediary engaged in merchant banking, investment banking, brokerage, underwriting, or similar services, which issues research reports through its employed research analysts.
Research Report: Any communication (written or electronic) containing research analysis, recommendations, or opinions on securities or public offers that provide a basis for investment decisions. Exclusions include:
Market trend comments,
Index-based discussions,
Economic or political market commentaries,
Routine communications for mutual fund or AIF unit holders, or for portfolio management clients,
Internal communications not shared with current/prospective clients,
Official offer documents or prospectuses,
Statistical company data summaries, technical sector analyses, or other SEBI-specified communications.
Significant News or Event: Any material information expected to impact a company’s earnings, operations, or financial condition, excluding unpublished price-sensitive information.
Subject Company: The company whose securities are under analysis or subject to a public appearance.
C. Management of Conflict of Interest and Disclosure Requirements
To maintain objectivity, the Research Analyst upholds an arms-length relationship between research activities and other functions. Specific policies include:
a) Limitations on Trading by Research Analysts
To prevent conflicts:
The Research Analyst’s personal trading activities are monitored, recorded, and may require formal approval.
Neither the Research Analyst nor associates may:
Trade in securities recommended by the Analyst within 30 days before and 5 days after a report is published.
Trade in a manner contrary to recommendations made.
Purchase or receive securities before an IPO if the issuer operates in a similar business.
b) Limitations on Research Reports, Public Appearances, and Business Conduct
The Research Analyst is restricted from publishing or publicly commenting on a subject company under specific circumstances:
IPO or FPO Management:
No publication within 40 days following IPO pricing.
No publication within 10 days following FPO pricing.
Underwriting Restrictions: No publication or public appearance for 25 days following an IPO where the Analyst is the underwriter.
Lock-Up Agreements: No publication 15 days before or after the expiry of a lock-up agreement.
Solicitation Restrictions: The Analyst may not engage in activities, such as sales pitches, that solicit investment or merchant banking services.
Research Independence: Reports are based on verifiable research without any assurance of a favorable review for companies, sectors, or groups as a condition for compensation.
c) Disclosures in Research Reports and Public Appearances
Each report or appearance includes full disclosure on:
Financial Interests: If the Analyst, associates, or relatives hold any financial interest in the subject company.
Ownership: If there is 1% or greater ownership in the subject company.
Conflicts of Interest: Disclosure of any other conflicts, whether from ownership or compensation received.
Additional disclosures cover:
Compensation:
If the Analyst received compensation from the subject company in the last 12 months.
If the Analyst or associates managed or co-managed public offerings for the company.
If any compensation was received for non-investment banking services.
Market-Making Activity: Disclosures cover whether the Analyst or associates engaged in market-making for the company.
d) Research Report Content Requirements
Reports will be clear, reliable, and consistent, including:
Defined rating terminology and benchmarks.
Price target history or performance charts if applicable for over one year.
Consistency in view representation across reports and appearances.
Equal access to reports for all clients without preferential treatment for certain clients.
Review and disclosure of any third-party reports shared with clients.
D. Maintenance of Records
The Research Analyst commits to preserving all relevant records for a minimum of five years, including:
Signed and dated research reports,
Issued recommendations and rationale,
Records of public appearances and related disclosures.
E. Other Compliance Conditions
The Research Analyst will serve as the compliance officer, overseeing adherence to SEBI’s guidelines, and ensuring that all employees meet the certification and qualification standards mandated by SEBI under Regulation 7.
By: R. Haresh, SEBI-Registered Research Analyst SEBI Registration Number: INH200005656
A. Applicability
This policy applies to the Research Analyst and all employees engaged in research activities, including individuals primarily responsible for:
Preparing or publishing research reports;
Making recommendations or giving price targets on securities listed or proposed to be listed on stock exchanges;
Offering opinions on public offers; or
Any associated persons reporting directly or indirectly to the Research Analyst.
These policies cover any individual involved in creating research content, issuing investment recommendations, and conducting research-based public appearances, regardless of their job title.
B. Definitions
Terms used within these policies align with the SEBI Regulations and are defined as follows:
Associate: Refers to any individual or entity under direct or indirect control by, or controlling, the intermediary (Research Analyst), or under common control with the intermediary, as defined by SEBI (Intermediaries) Regulations, 2008. For natural persons, this includes relatives, and for corporate entities, it includes group companies and companies under the same management.
Price Target: The Research Analyst’s projected future performance of specific securities.
Public Appearance: 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 Offer: Encompasses initial public offers (IPO), further public offers (FPO), offers for sale, disinvestment, takeovers, buy-backs, or delistings.
Research Analyst: An individual responsible for:
Preparing or publishing research content,
Providing research reports,
Making buy/sell/hold recommendations or price targets,
Offering opinions concerning public offers on listed or proposed-to-be-listed securities. This term also covers associated individuals reporting directly or indirectly to a Research Analyst.
Relative: Defined as per subsection (77) of section 2 of the Companies Act, 2013, it includes financially dependent individuals on the independent research analyst or employees of a research entity.
Research Entity: An SEBI-registered intermediary engaged in merchant banking, investment banking, brokerage, underwriting, or similar services, which issues research reports through its employed research analysts.
Research Report: Any communication (written or electronic) containing research analysis, recommendations, or opinions on securities or public offers that provide a basis for investment decisions. Exclusions include:
Market trend comments,
Index-based discussions,
Economic or political market commentaries,
Routine communications for mutual fund or AIF unit holders, or for portfolio management clients,
Internal communications not shared with current/prospective clients,
Official offer documents or prospectuses,
Statistical company data summaries, technical sector analyses, or other SEBI-specified communications.
Significant News or Event: Any material information expected to impact a company’s earnings, operations, or financial condition, excluding unpublished price-sensitive information.
Subject Company: The company whose securities are under analysis or subject to a public appearance.
C. Management of Conflict of Interest and Disclosure Requirements
To maintain objectivity, the Research Analyst upholds an arms-length relationship between research activities and other functions. Specific policies include:
a) Limitations on Trading by Research Analysts
To prevent conflicts:
The Research Analyst’s personal trading activities are monitored, recorded, and may require formal approval.
Neither the Research Analyst nor associates may:
Trade in securities recommended by the Analyst within 30 days before and 5 days after a report is published.
Trade in a manner contrary to recommendations made.
Purchase or receive securities before an IPO if the issuer operates in a similar business.
b) Limitations on Research Reports, Public Appearances, and Business Conduct
The Research Analyst is restricted from publishing or publicly commenting on a subject company under specific circumstances:
IPO or FPO Management:
No publication within 40 days following IPO pricing.
No publication within 10 days following FPO pricing.
Underwriting Restrictions: No publication or public appearance for 25 days following an IPO where the Analyst is the underwriter.
Lock-Up Agreements: No publication 15 days before or after the expiry of a lock-up agreement.
Solicitation Restrictions: The Analyst may not engage in activities, such as sales pitches, that solicit investment or merchant banking services.
Research Independence: Reports are based on verifiable research without any assurance of a favorable review for companies, sectors, or groups as a condition for compensation.
c) Disclosures in Research Reports and Public Appearances
Each report or appearance includes full disclosure on:
Financial Interests: If the Analyst, associates, or relatives hold any financial interest in the subject company.
Ownership: If there is 1% or greater ownership in the subject company.
Conflicts of Interest: Disclosure of any other conflicts, whether from ownership or compensation received.
Additional disclosures cover:
Compensation:
If the Analyst received compensation from the subject company in the last 12 months.
If the Analyst or associates managed or co-managed public offerings for the company.
If any compensation was received for non-investment banking services.
Market-Making Activity: Disclosures cover whether the Analyst or associates engaged in market-making for the company.
d) Research Report Content Requirements
Reports will be clear, reliable, and consistent, including:
Defined rating terminology and benchmarks.
Price target history or performance charts if applicable for over one year.
Consistency in view representation across reports and appearances.
Equal access to reports for all clients without preferential treatment for certain clients.
Review and disclosure of any third-party reports shared with clients.
D. Maintenance of Records
The Research Analyst commits to preserving all relevant records for a minimum of five years, including:
Signed and dated research reports,
Issued recommendations and rationale,
Records of public appearances and related disclosures.
E. Other Compliance Conditions
The Research Analyst will serve as the compliance officer, overseeing adherence to SEBI’s guidelines, and ensuring that all employees meet the certification and qualification standards mandated by SEBI under Regulation 7.
By: R. Haresh, SEBI-Registered Research Analyst SEBI Registration Number: INH200005656
Introduction
As per SEBI Notification No. LAD-NRO/GN/2014-15/07/1414 dated September 1, 2014, SEBI introduced the SEBI (Research Analysts) Regulations, 2014 (“SEBI Regulations”). The goal of these regulations is to promote transparency in securities research and to provide investors with accurate, reliable information for their investment decisions. To ensure full compliance with these regulations, R. Haresh, a SEBI-registered Research Analyst (Registration Number INH200005656), adopts the following internal policies and control procedures.
A. Applicability
This policy applies to the Research Analyst and all employees engaged in research activities, including individuals primarily responsible for:
Preparing or publishing research reports;
Making recommendations or giving price targets on securities listed or proposed to be listed on stock exchanges;
Offering opinions on public offers; or
Any associated persons reporting directly or indirectly to the Research Analyst.
These policies cover any individual involved in creating research content, issuing investment recommendations, and conducting research-based public appearances, regardless of their job title.
B. Definitions
Terms used within these policies align with the SEBI Regulations and are defined as follows:
Associate: Refers to any individual or entity under direct or indirect control by, or controlling, the intermediary (Research Analyst), or under common control with the intermediary, as defined by SEBI (Intermediaries) Regulations, 2008. For natural persons, this includes relatives, and for corporate entities, it includes group companies and companies under the same management.
Price Target: The Research Analyst’s projected future performance of specific securities.
Public Appearance: 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 Offer: Encompasses initial public offers (IPO), further public offers (FPO), offers for sale, disinvestment, takeovers, buy-backs, or delistings.
Research Analyst: An individual responsible for:
Preparing or publishing research content,
Providing research reports,
Making buy/sell/hold recommendations or price targets,
Offering opinions concerning public offers on listed or proposed-to-be-listed securities. This term also covers associated individuals reporting directly or indirectly to a Research Analyst.
Relative: Defined as per subsection (77) of section 2 of the Companies Act, 2013, it includes financially dependent individuals on the independent research analyst or employees of a research entity.
Research Entity: An SEBI-registered intermediary engaged in merchant banking, investment banking, brokerage, underwriting, or similar services, which issues research reports through its employed research analysts.
Research Report: Any communication (written or electronic) containing research analysis, recommendations, or opinions on securities or public offers that provide a basis for investment decisions. Exclusions include:
Market trend comments,
Index-based discussions,
Economic or political market commentaries,
Routine communications for mutual fund or AIF unit holders, or for portfolio management clients,
Internal communications not shared with current/prospective clients,
Official offer documents or prospectuses,
Statistical company data summaries, technical sector analyses, or other SEBI-specified communications.
Significant News or Event: Any material information expected to impact a company’s earnings, operations, or financial condition, excluding unpublished price-sensitive information.
Subject Company: The company whose securities are under analysis or subject to a public appearance.
C. Management of Conflict of Interest and Disclosure Requirements
To maintain objectivity, the Research Analyst upholds an arms-length relationship between research activities and other functions. Specific policies include:
a) Limitations on Trading by Research Analysts
To prevent conflicts:
The Research Analyst’s personal trading activities are monitored, recorded, and may require formal approval.
Neither the Research Analyst nor associates may:
Trade in securities recommended by the Analyst within 30 days before and 5 days after a report is published.
Trade in a manner contrary to recommendations made.
Purchase or receive securities before an IPO if the issuer operates in a similar business.
b) Limitations on Research Reports, Public Appearances, and Business Conduct
The Research Analyst is restricted from publishing or publicly commenting on a subject company under specific circumstances:
IPO or FPO Management:
No publication within 40 days following IPO pricing.
No publication within 10 days following FPO pricing.
Underwriting Restrictions: No publication or public appearance for 25 days following an IPO where the Analyst is the underwriter.
Lock-Up Agreements: No publication 15 days before or after the expiry of a lock-up agreement.
Solicitation Restrictions: The Analyst may not engage in activities, such as sales pitches, that solicit investment or merchant banking services.
Research Independence: Reports are based on verifiable research without any assurance of a favorable review for companies, sectors, or groups as a condition for compensation.
c) Disclosures in Research Reports and Public Appearances
Each report or appearance includes full disclosure on:
Financial Interests: If the Analyst, associates, or relatives hold any financial interest in the subject company.
Ownership: If there is 1% or greater ownership in the subject company.
Conflicts of Interest: Disclosure of any other conflicts, whether from ownership or compensation received.
Additional disclosures cover:
Compensation:
If the Analyst received compensation from the subject company in the last 12 months.
If the Analyst or associates managed or co-managed public offerings for the company.
If any compensation was received for non-investment banking services.
Market-Making Activity: Disclosures cover whether the Analyst or associates engaged in market-making for the company.
d) Research Report Content Requirements
Reports will be clear, reliable, and consistent, including:
Defined rating terminology and benchmarks.
Price target history or performance charts if applicable for over one year.
Consistency in view representation across reports and appearances.
Equal access to reports for all clients without preferential treatment for certain clients.
Review and disclosure of any third-party reports shared with clients.
D. Maintenance of Records
The Research Analyst commits to preserving all relevant records for a minimum of five years, including:
Signed and dated research reports,
Issued recommendations and rationale,
Records of public appearances and related disclosures.
E. Other Compliance Conditions
The Research Analyst will serve as the compliance officer, overseeing adherence to SEBI’s guidelines, and ensuring that all employees meet the certification and qualification standards mandated by SEBI under Regulation 7.
By: R. Haresh, SEBI-Registered Research Analyst SEBI Registration Number: INH200005656
