INTERNAL POLICIES AND PROCEDURES

The Securities & Exchange Board of India (SEBI) had formulated the SEBI (Research Analyst) Regulations, 2014 under the powers conferred on it under the SEBI Act, 1992. These regulations came into force with effect from 1st December 2014. Research analyst is required to follow the code formulated by us both in letter and spirit.

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 the Research Analyst i,e MOHANISH SANGHAVI (hereinafter referred as Research Analyst).

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 the RESEARCH ANALYSTS i.e MOHANISH SANGHAVI

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,

Significant news or event:

Significant news or event" means any news or event which is expected to have a material impact on or that reflects a material change to, the subject company's earnings, operations or financial condition, other than unpublished price sensitive information.

Subject Company:

“Subject Company" means the company whose securities are the subject of a research report or a public appearance or Buy Sell Recommendations.

OBLIGATIONS FOR ANALYST

Research Analysts (herein after referred to as “Analysts”) are required to observe high standards of integrity and ethical behaviour.

All research reports & Recommendations should be based on strict standards of truthfulness and fair dealing, and must be presented in a manner such that they are fair, clear and not misleading. There should be reasonable basis, based on adequate documentary evidence, for analysis and recommendations issued.

I shall not deal or trade on any securities on which any research reports is prepared, within 30 days before and 5 days after the publication of a research report. I shall not deal or trade directly or indirectly in any securities that i reviews in a manner contrary to my outstanding recommendation. 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 my personal financial circumstances.

INAPPROPRIATE INFLUENCES

As a Research Analyst, I shall:

·Not accept any remuneration or other benefit from the issuer or any other party in respect of the publication of research;

·Not offer or accept any inducement for the production of favorable research, including selective disclosure by an issuer of material information not generally available;

·Not, directly or indirectly offer favorable research, specific ratings or specific price targets as consideration or inducement for the receipt of business or compensation;

·Not, directly or indirectly offer or threaten to change research, a rating or price target as consideration or inducement for the receipt of business or compensation

DISCLOSURES IN RESEARCH REPORTS

All Required disclosures will be added to the Research Report or Recommendation Provided, as required by SEBI Regulation. These include:

·Whether there is any financial interest in the company referred in research reports and the nature of such interest.

·Whether there is 1% or more holding in securities of companies referred to in research reports;

·Whether there is any other material conflict of interest;

·Whether any acts pretending to a market making in the securities of companies referred to in reports; Information regarding any directorships or other material relationships with companies referred to in research reports;

·Any Past significant relationships with the Subject Company would be specified.

·All material information regarding the analyst including Disciplinary History, if any, will be specified.

Above Stated documents will be subject to changes, in line with updates & modifications to SEBI Research Analyst Regulations, from time to time.