Code of Conduct

Securities Dealing Procedures in Terms of SEBI (Research Analysts) Regulations, 2014

INTRODUCTION

SEBI, vide its Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September 2014, has notified the SEBI (Research Analysts) Regulations, 2014, which are effective on or after the expiry of 29th November 2014 (i.e., the ninetieth day from the date of their publication in the official gazette). These regulations have been introduced by SEBI with the objective of fostering transparency in security research and providing investors with more reliable and useful information to make informed investment decisions.

These Code of Conduct - Securities Dealing Procedures are being implemented in line with these regulations.

APPLICABILITY

This policy shall be applicable to Elitefinserv (“RA”) Research Analysts, i.e., a person primarily responsible for the preparation or publication of the content of the research report, or providing a research report, making ‘buy, sell/hold’ or ‘overweight/underweight’ recommendations, giving price targets, or offering opinions on any security that is listed or to be listed on a Stock Exchange.

CODE OF CONDUCT FOR RESEARCH ANALYST

Honesty and Good Faith

Research Analysts shall act honestly and in good faith at all times.

Diligence

Research Analysts shall act with due skill, care, and diligence and ensure that research reports are prepared and stock recommendations are made after thorough analysis.

Conflict of Interest

Research Analysts shall effectively address any conflict of interest that may affect the impartiality of their research analysis or research report, or stock recommendation, and shall make appropriate disclosures to address the same.

Insider Trading or Front Running

Research Analysts shall not engage in insider trading, front running, or front running of their own research report or stock recommendations.

Confidentiality

Research Analysts shall maintain the confidentiality of research reports or stock recommendations until the report is made public, or the stock recommendations are provided to the respective clients.

Professional Standard

Research Analysts engaged in research analysis or providing research recommendations shall observe high professional standards while preparing research reports or analyzing subject companies for stock recommendations.

Compliance

Research Analysts shall comply with all regulatory requirements applicable to the conduct of their business activities.

INSIDER DEALING

No staff member in possession of inside information may be involved in trading, making recommendations, or publishing research concerning the financial instruments to which the information relates.

NO FRONT-RUNNING

Front-running is strictly prohibited. There are two ways in which front-running can arise:

• Through the use of client order information, i.e., utilizing the advantage of advance knowledge of pending client orders.
• Through information about the timing or contents of research prior to its publication to clients.

Mr. Divyansh Jain
For Elitefinserv
SEBI Registered Research Analyst
Registration No. INH000016409