Segregation of Research Activities Policy

Introduction

Quantace Research and Capital Private Limited (“Quantace”) is committed to maintaining the highest standards of integrity and objectivity in its research activities. To ensure that our research remains independent and free from any potential conflicts of interest, we adhere to the principles of Segregation of Research Activities as mandated by the Securities and Exchange Board of India (SEBI) (Research Analysts) Regulations, 2014.

Scope

This policy applies to all research activities carried out by Quantace. Given that Quantace does not currently provide any other services such as brokerage, investment banking, or merchant banking, this policy reinforces our sole focus on research and ensures that our analysis remains unbiased.

Purpose

The purpose of this policy is to:

• Ensure that research activities are conducted independently and free from external influences.
• Prevent conflicts of interest by maintaining a clear separation between research activities and any potential future business activities.
• Promote transparency and objectivity in the preparation and dissemination of research reports.

Segregation of Research Activities

1. Focus on Research

   • As Quantace exclusively offers research services, no other business divisions (such as brokerage or investment banking) exist within the company. Therefore, all activities related to research are inherently segregated from other financial services.
   • Quantace ensures that all research reports are created based on objective, data-driven analysis without any external influence.

2. Independence of Research

   • All research reports prepared by Quantace are conducted independently. There is no interaction with any other business services that may influence the objectivity of the research, as no such services are currently offered by Quantace.

3. Conflict of Interest Mitigation

   • Quantace does not engage in activities such as underwriting, brokerage, or corporate advisory services, which ensures that our research remains free from any potential conflicts arising from commercial interests.
   • We do not receive compensation from subject companies for services other than research, further eliminating potential bias.

4. Disclosure

   • In every research report, Quantace will disclose any material information regarding its business structure, ensuring full transparency about the absence of other business activities that may compromise the integrity of the research.
   • Any potential conflicts of interest, such as ownership in the securities being analyzed, will be disclosed to maintain transparency.

5. Personal Trading Restrictions

   • All research analysts and their associates are restricted from trading in securities they analyze or recommend for a period of 30 days before and five days after the publication of a research report. This ensures that personal interests do not interfere with the objectivity of the research.

6. Supervision and Compliance

   • Quantace appoints a Compliance Officer responsible for overseeing the adherence to this policy. The Compliance Officer will ensure that all research activities are conducted independently and that research reports are in full compliance with SEBI regulations.
   • Research reports will be subject to internal review to ensure that they are free from any influence or bias.

Future Considerations

Should Quantace expand into other services in the future, this policy will be updated to reflect the necessary segregation measures to ensure that research activities remain independent and uninfluenced by other business divisions.

Review and Amendments

This policy will be reviewed annually or as required to ensure compliance with SEBI regulations and to reflect any changes in the business activities of Quantace.