Individual Code of Conduct

SEBI, vide its Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September 2014, notified the SEBI (Research Analysts) Regulations, 2014, which came into effect on 29th November 2014. These regulations were introduced to foster transparency in securities research and provide investors with reliable and useful information to make informed investment decisions.

The policy shall be applicable to Truestock Universe Private Limited, (“RA”) Research analyst i.e. a person primarily responsible for preparation or publication of the content of the research report; or providing a research report or Making ‘buy, sell/hold’ or ‘overweight / underweight’ recommendation or giving price target or offering an opinion on any security that are listed or to be listed in a Stock Exchange.

Code of Conduct for Research Analyst

1. Honesty and Good Faith

Research analyst or research entity shall act honestly and in good faith.

2. Diligence

Research analyst or research entity shall act with due skill, care and diligence and shall ensure that the research report is prepared after thorough analysis.

3. Conflict of Interest

Research analyst or research entity shall effectively address conflict of interest which may affect the impartiality of its research analysis and research report and shall make appropriate disclosures to address the same.

4. Insider Trading or front running

Research analyst or research entity or its employees shall not engage in insider trading or front running or front running of its own research report.

5. Confidentiality

Research analyst or research entity or its employees shall maintain confidentiality of report till the report is made public.

6. Professional Standard

Research analyst or research entity or its employees engaged in research analysis shall observe high professional standard while preparing research report.

7. Compliance

Research analyst or research entity shall comply with all regulatory requirements applicable to the conduct of its business activities.

8. Responsibility of senior management

The senior management of research analyst or research entity shall bear primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures.