Code Of Conduct

1. Introduction

Securities Exchange Board of India vide its Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September 2014 has notified SEBI (Research Analysts) Regulations, 2014. These regulations have been introduced by SEBI with the objective of fostering transparency in security research and provide investors with more reliable and useful information to make investment decisions.
According to these Regulations, Research Analysts or Research Entity are required to adhere to the below code of conduct (as detailed in the THIRD SCHEDULE of the regulations)

2. Applicability

The policy shall be applicable to Equity Midas Capital (“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 on a Stock Exchange.

3. Code of Conduct

3.1 Honesty and Good Faith

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

3.2 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.

3.3 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.
Research Analysts must disclose any potential or actual potential conflict of interest and implement appropriate measures to manage and mitigate these conflicts effectively.
Research Analysts should refrain from trading securities while possessing material non-public information or engaging in activities that contribute to market manipulation.

3.4 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.
No staff member in possession of inside information may be involved in trading, making recommendations or publishing research with respect to the financial instruments to which the information relates.
Front-running is prohibited. There are two ways in which front-running can arise:

1. Through use of client or their information, i.e. utilizing the advantage of advance knowledge of pending orders of clients
2. Through information about the timing or contents of research prior to publication to clients

3.5 Confidentiality

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

3.6 Professional Standard

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

3.7 Compliance

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

3.8 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.

3.9 Suitability of Information

Research Analysts must not be incentivized to sell products that do not align with the general risk profile of their clients. We must prioritize the suitability of investment products for the client’s specific needs and circumstances.

3.10 Sharing of Information

Research Analysts are strictly prohibited from sharing client information obtained through their professional dealings for personal gains and any unauthorized purpose. This guideline emphasizes the importance of maintaining client confidentiality and data privacy.