TEJAS NAIK
SEBI Registered Research Analyst
Registration No.: INH000016551
BSE Enlistment No.: 6193

Registered Address:
401, Reelicon Claramount,
Pune-Satara Road,
Near Walvekar Lawns,
Pune, Maharashtra – 411037

Contact: 88888 63863
Email: tejasnaik26@gmail.com

Code of Conduct – Securities Dealing Procedures

(In accordance with SEBI (Research Analysts) Regulations, 2014)

INTRODUCTION

SEBI, via Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September 2014, introduced the SEBI (Research Analysts) Regulations, 2014, which came into effect from 29th November 2014 (the ninetieth day from their publication in the official gazette).

These regulations aim to foster transparency in securities research and empower investors with reliable, unbiased information to support informed investment decisions.

This Code of Conduct and Securities Dealing Policy is implemented in compliance with the above regulations.

APPLICABILITY

This policy is applicable to Tejas Naik (“RA”), as a SEBI Registered Research Analyst. It covers all individuals responsible for:

• Preparation or publication of research reports

• Providing stock recommendations (Buy/Sell/Hold)

• Giving price targets or opinions on listed or to-be-listed securities

• Any related research analysis activity conducted under SEBI oversight

1. Code of Conduct for Research Analysts

a. Honesty & Good Faith
The Research Analyst shall act honestly and in good faith at all times.

b. Diligence
All research reports and stock recommendations must be based on thorough analysis, backed by skill, care, and diligence.

c. Conflict of Interest
Any potential conflict of interest must be transparently disclosed and effectively managed to preserve the impartiality of the research and recommendations.

d. Insider Trading / Front Running
Engagement in insider trading or front running of research reports or recommendations is strictly prohibited.

e. Confidentiality
All research and reports shall be kept confidential until publicly released or officially shared with clients.

f. Professional Standards
The Research Analyst must maintain high professional standards and integrity while preparing reports or making recommendations.

g. Regulatory Compliance
Strict adherence to all applicable SEBI and legal regulations governing business activities is mandatory.

2. Insider Dealing

Any staff member in possession of non-public, price-sensitive information is strictly prohibited from trading, recommending, or publishing any related research.

3. No Front-Running

Front-running is strictly banned. It includes:

a. Using advance knowledge of pending client orders for personal gain.
b. Trading based on prior knowledge of unpublished research content or timing.