Code of Conduct
INTRODUCTION
SEBI vide its Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September, 2014 has notified SEBI (Research Analysts) Regulations, 2014, effective from 29th November, 2014. These regulations aim to bring transparency to securities research and provide investors with reliable information for investment decisions.
These Code of Conduct - Securities Dealing Procedures are implemented in accordance with these regulations.
APPLICABILITY
This policy applies to Gaurav Kumar Sharma (“RA”), a Research Analyst responsible for preparing or publishing research reports, providing recommendations (buy/sell/hold, overweight/underweight), price targets, or offering opinions on securities listed or to be listed on stock exchanges.
1. CODE OF CONDUCT FOR RESEARCH ANALYST
a. Honesty and Good Faith
The Research Analyst shall act honestly and in good faith.
b. Diligence
The Research Analyst shall act with due skill, care, and diligence and ensure all research
reports or recommendations are backed by thorough analysis.
c. Conflict of Interest
The Research Analyst shall appropriately identify, disclose, and address conflicts of
interest that may affect impartiality.
d. Insider Trading or Front Running
The Research Analyst shall not engage in insider trading or front running of research
reports or recommendations.
e. Confidentiality
The Research Analyst shall maintain confidentiality of research reports or recommendations
until they are released or provided to clients.
f. Professional Standard
The Research Analyst shall observe high professional standards during research or while
preparing reports.
g. Compliance
The Research Analyst shall comply with all regulatory requirements related to business
activities.
2. INSIDER DEALING
No staff member possessing inside information may trade, recommend, or publish research concerning financial instruments to which the information relates.
3. NO FRONT-RUNNING
Front-running is strictly prohibited. It may occur through:
- a. Use of client order information (advance knowledge of pending client orders)
- b. Premature knowledge of the timing or contents of research before publication
Mr. Gaurav Kumar Sharma
For LevelOne Research
SEBI Registered Research Analyst
Registration No. INH000022233