Research Analyst Code of Conduct

Standards of conduct

The Firm, its partners, analysts and associated persons are expected to follow these principles:

1. Honesty and good faith — act honestly, fairly and in the interests of market integrity.
2. Diligence — exercise due skill, care and diligence and prepare research after appropriate analysis.
3. Conflict management — identify and effectively address conflicts and make appropriate disclosures.
4. No insider trading or front-running — do not misuse unpublished price-sensitive information or trade ahead of research.
5. Confidentiality — protect confidential research and client information until authorised disclosure or lawful production.
6. Professional standards — maintain competence, objectivity, adequate records and clear communication.
7. Regulatory compliance — comply with applicable SEBI requirements, RAASB standards and other laws.
8. Management responsibility — senior management remains responsible for adequate supervision, controls and corrective action.

Reporting concerns

Personnel must promptly report suspected misconduct, data misuse, conflicts, control failures or regulatory breaches to compliance or a designated partner. Retaliation for a good-faith report is not permitted.

Review

Breaches may result in restriction of duties, corrective training, disciplinary action, reporting to authorities or termination of association, depending on severity and legal requirements.