In terms of SEBI (Research Analysts) Regulations, 2014
Bhakti Wealth
SEBI Registration Number: INH000018054
Research Analyst: Ms. Nandita Rai
Address: [Insert Registered Office Address of Bhakti Wealth]
Introduction
The Securities and Exchange Board of India (SEBI), through Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September 2014, introduced the SEBI (Research Analysts) Regulations, 2014, effective from 29th November 2014. These regulations are intended to promote transparency, enhance investor protection, and ensure that investment research is credible, objective, and in the best interest of investors.
This Code of Conduct establishes the securities dealing procedures for Bhakti Wealth and its Research Analyst, ensuring full compliance with the above regulations.
Applicability
This policy applies to Bhakti Wealth and specifically to its SEBI-registered Research Analyst, Ms. Nandita Rai, in respect of the following activities:
- Preparation and publication of research reports.
- Distribution of research reports to clients.
- Making investment recommendations such as ‘buy, sell, hold’ or ‘overweight/underweight.’
- Providing price targets or offering views on securities listed or proposed to be listed on recognized stock exchanges.
Code of Conduct for Research Analysts
1. Honesty and Good Faith
The Research Analyst shall act honestly, fairly, and in good faith while discharging her professional responsibilities.
2. Diligence
All research and recommendations shall be based on thorough analysis, backed by due skill, care, and diligence.
3. Conflict of Interest
Any conflict of interest that could compromise the objectivity of research shall be identified and disclosed appropriately to clients.
4. Insider Trading or Front Running
The Research Analyst shall not engage in insider trading or front running of research reports, recommendations, or client trades.
5. Confidentiality
All unpublished research, recommendations, or proprietary information shall be kept strictly confidential until officially released to clients or the public.
6. Professional Standards
The Research Analyst shall uphold the highest standards of professionalism, integrity, and ethical conduct while preparing and disseminating research.
7. Compliance
All applicable SEBI regulations, circulars, and guidelines shall be strictly adhered to in the conduct of research and advisory services.
Insider Dealing
No person associated with Bhakti Wealth, who is in possession of unpublished price-sensitive information (UPSI), shall engage in:
- Trading in the concerned securities,
- Making recommendations, or
- Publishing research reports relating to such securities.
No Front Running
Front-running in any form is strictly prohibited. This includes:
- Using Client Order Information: Exploiting prior knowledge of client trades for personal benefit.
- Using Research Publication Information: Misusing advance knowledge of the timing or content of unpublished research reports for personal or third-party gain.
✅ This Code of Conduct ensures that Bhakti Wealth and Ms. Nandita Rai operate with transparency, fairness, and compliance, safeguarding investor confidence and upholding the regulatory framework set forth by SEBI.