SEBI Regulations

Code of Conduct

As required under Schedule III of SEBI (Research Analysts) Regulations, 2014

Indra Kamal Tiwari |  SEBI Reg. No.: INH000027414

Indra Kamal Tiwari, SEBI Registered Research Analyst (Registration No. INH000027414), is committed to upholding the highest standards of professional conduct. The following Code of Conduct is observed strictly in accordance with Schedule III of the SEBI (Research Analysts) Regulations, 2014, and governs all research activities and client interactions.

1. Honesty and Fairness

  • Act with integrity and in an honest and forthright manner with all clients.
  • Not manipulate the market or engage in any misleading activity.
  • Provide research that is fair, objective, and not influenced by any conflict of interest.
  • Never make false or misleading statements about any issuer or security.

2. Diligence

  • Exercise due care, skill, and diligence while preparing research reports.
  • Have a reasonable and adequate basis for recommendations based on thorough analysis.
  • Distinguish clearly between facts and opinions in all research reports.
  • Ensure that research recommendations are regularly reviewed and updated.

3. Capabilities

  • Maintain and enhance professional knowledge, skills, and competencies.
  • Provide research services only within areas of expertise and competency.
  • Stay updated with changes in SEBI regulations, market dynamics, and analysis techniques.
  • Ensure that all associates involved in research maintain required qualifications and certifications.

4. Information About Clients

  • Keep all client information strictly confidential and not disclose it to any third party without consent.
  • Use client information only for the purpose for which it was provided.
  • Not misuse access to client information for personal gain.

5. Information to Clients

  • Provide adequate and timely disclosures to clients regarding conflicts of interest.
  • Disclose SEBI registration number, type of registration, and validity in all research reports.
  • Disclose any personal interest in the securities recommended in research reports.
  • Inform clients promptly of any material changes that may affect the research.
  • Provide clear disclosures on fees and charges before commencing services.

6. Fair and Reasonable Charges

  • Not charge excessive or non-transparent fees from clients.
  • Clearly disclose all fees and charges before commencement of services.
  • Not accept fees or compensation in any form other than as disclosed.
  • Refund fees if services are not rendered as agreed.

7. Compliance with Regulatory Requirements

  • Comply with all applicable laws, rules, and regulations of SEBI and other relevant authorities.
  • Maintain all records and documents as required under SEBI (Research Analysts) Regulations, 2014.
  • Cooperate fully with SEBI inspections, inquiries, and investigations.
  • Not engage in any activity that is prohibited under SEBI regulations.
  • File all required reports and disclosures with SEBI in a timely manner.

8. Responsibility to the Market

  • Not engage in any activity that could distort or manipulate the securities market.
  • Not engage in front-running or any form of insider trading.
  • Ensure that research recommendations do not constitute market manipulation.
  • Promote fair, transparent, and efficient capital markets through honest research.

This Code of Conduct is binding on Indra Kamal Tiwari and all associates engaged in research activities. Any violation of this code may be reported to SEBI through the SCORES portal at scores.sebi.gov.in or through the ODR mechanism at smartodr.in.