Conflict of Interest & Disclosure Policy

Objective

The Firm seeks to preserve the independence and impartiality of its research. Actual, potential and perceived conflicts are identified, assessed, managed and disclosed so clients can make informed decisions.

Identification of conflicts

Relevant conflicts may include financial interests in a subject company, business relationships, compensation, market-making or advisory relationships, employment or directorship connections, material ownership by analysts or associates, and personal trading around research publication.

Controls

• Research conclusions must not be influenced by sales, issuer or commercial considerations.
• Analysts and associated persons must comply with applicable personal-trading restrictions and must not front-run research.
• Confidential research must remain confidential until authorised publication.
• Gifts, benefits or issuer consideration that could impair objectivity must not be accepted.
• Where independence cannot be adequately protected, coverage may be declined, delayed, restricted or withdrawn.

Report-level disclosures

Each research report will carry disclosures required by the SEBI (Research Analysts) Regulations, including material financial interests and relevant relationships, as applicable. A disclosure does not eliminate the conflict; it enables the reader to evaluate it.

Escalation and review

Partners and compliance personnel are responsible for escalation and resolution. Conflicts and controls are reviewed periodically and as part of the Firm's compliance audit.

This policy reflects the conflict-of-interest and code-of-conduct principles applicable to Research Analysts. It does not replace report-specific disclosures.