As a SEBI-registered Research Analyst (part-time), Anand Rawani has implemented internal policies and procedures to identify, disclose, and effectively manage actual or potential conflicts of interest, in full compliance with the SEBI (Research Analysts) Regulations, 2014. Key principles include:

1. Independence of Research
Research activities are carried out independently and are not influenced by business, commercial, or client relationships. The Research Analyst does not engage in investment advisory, distribution, or execution services, ensuring clear separation of functions and avoiding inducement to issue favourable recommendations.

2. Disclosure of Conflicts
All research reports will prominently disclose any material conflicts of interest, including but not limited to:
– Financial interest in the subject company or financial instrument.
– Ownership of securities, current or proposed.
– Directorships or employment relationships in the subject entity.
– Compensation received from the subject company.
– Restrictions on Personal Trading

3. Restriction on Trading
Personal trading in securities under coverage is subject to the following safeguards:
– A blackout period of 30 days before and 5 days after publication of research reports; breaches will be disclosed with reasons.
– Pre-clearance requirements for trades.
– Maintenance of a personal trading register and periodic reporting.
– Prohibition of front running.

4. Recordkeeping and Audit Trail
Detailed records of research work, source data, recommendations, disclosures, and personal trades are maintained for five years as required by SEBI and will be made available for regulatory inspection.

5. No Promise of Returns
The Research Analyst does not make any implicit or explicit promises or guarantees of investment performance in research reports or communications.

6. Client Confidentiality
Any non-public information obtained during the research process is treated as confidential and is not misused or shared for personal or commercial gain.

7. Periodic Review and Compliance Monitoring
Policies and procedures are reviewed regularly to ensure alignment with regulatory changes and best practices. All potential violations are documented and addressed promptly.