Code of Conduct – Securities Dealing Procedures in accordance with SEBI (Research Analysts) Regulations, 2014

Introduction

The Securities and Exchange Board of India (SEBI), through Notification No. LAD-NRO/GN/2014-15/07/1414 dated September 1, 2014, introduced the SEBI (Research Analysts) Regulations, 2014. These regulations came into effect on November 29, 2014, aiming to enhance transparency in securities research and provide investors with reliable, actionable information for making informed investment decisions. This Code of Conduct – Securities Dealing Procedures is aligned with these regulations.

Applicability

This policy applies to QUANTACE RESEARCH AND CAPITAL PRIVATE LIMITED (the “RA”) and its Research Analysts, defined as individuals responsible for preparing or publishing research reports, offering ‘buy, sell, hold,’ ‘overweight/underweight’ recommendations, setting price targets, or providing opinions on securities listed or to be listed on a stock exchange.

1. Code of Conduct for Research Analysts

• Honesty and Good Faith: Research Analysts must conduct themselves with honesty and good faith in all activities.
• Diligence: Research Analysts should exercise due skill, care, and diligence, ensuring all research reports or stock recommendations are thoroughly analyzed before publication.
• Conflict of Interest: Research Analysts must identify and address any conflicts of interest that may affect the objectivity of their analysis, making appropriate disclosures when necessary.
• Insider Trading and Front-Running: Research Analysts must not engage in insider trading, front-running, or the advance trading of securities based on their own research reports or stock recommendations.
• Confidentiality: Research Analysts are responsible for maintaining the confidentiality of research reports or recommendations until they are made public or provided to clients.
• Professional Standards: Research Analysts must adhere to high professional standards in preparing research reports and analyzing companies for stock recommendations.
• Compliance: Research Analysts are required to comply with all relevant regulatory requirements governing their business activities.

2. Insider Dealing

No employee with access to inside information may trade, make recommendations, or publish research related to the financial instruments concerned.

3. No Front-Running

Front-running, the practice of trading based on non-public information, is strictly prohibited. This can occur through:

1. Using client order information to trade on advance knowledge of pending orders; or
2. Using information about the timing or content of research prior to its publication or distribution to clients.