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INTERNAL POLICY ON CONFLICT OF INTEREST

Issued by: Krishna Kumar Pathak

SEBI Registered Research Analyst - INH300009914

BSE Enlistment No: 5590

1. Objective

This Internal Policy on Conflict of Interest ("Policy") is formulated in compliance with Regulation 15(1) of the SEBI (Research Analyst) Regulations, 2014 and sets out principles and mechanisms adopted by Krishna Kumar Pathak ("Research Analyst" or "Analyst") to identify, avoid, disclose, and manage any conflict of interest arising during the course of research activity.

2. Definitions

Conflict of Interest: Any circumstance that may give rise to a personal or professional interest conflicting with the interest of Clients or impacting the Analyst's objectivity.
Client: A person or entity who receives research services from the Analyst.
Immediate Relative: As defined under SEBI (Prohibition of Insider Trading) Regulations, 2015.

3. Guiding Principles

Ensure honesty, integrity, and independence in research and recommendation activities
Maintain a clear separation between research and commercial interests
Always act in the best interest of clients, subject to regulatory frameworks
Disclose material interests or conflicts before or at the time of recommendation
Uphold the fiduciary duties imposed under SEBI RA Regulations

4. Identification of Conflict Scenarios

Scenario	Policy Action
Analyst holds shares in recommended stock	Mandatory disclosure in report
Immediate relative holds financial interest	Disclosure as per SEBI RA norms
Analyst has received any consideration from issuer company	Prohibited unless fully disclosed and compliant
Analyst performs services for company under coverage	Only permitted if legally disclosed and separated
Dual role in advisory or distribution business	Not applicable; segregation maintained as per SEBI

5. Policy Measures to Manage Conflict

1. Disclosure in Reports

Every research report shall include disclosures required under Regulation 19(1)(e), stating:

Analyst's or relatives' ownership in the stock
Whether the Analyst has served or received any benefit from the issuer
Whether the subject company has been a client in the past 12 months

2. Firewalls and Role Separation

The research function is fully independent from any commercial or distribution activity
No incentive, compensation, or consideration is accepted from companies for coverage

3. No Influence from Market Participants

Analysts shall not be influenced by promoters, brokers, or third parties in any research assignment
No participation in IPO allocation decisions or fund raising by covered companies

4. Restricted List Maintenance

A restricted list is maintained and updated regularly for companies where conflict may exist
No reports or commentary shall be issued on such companies

5. Regular Monitoring

Internal audits and compliance checks are conducted to ensure conflict management
Every research call, note, or post is verified for compliance and disclosure

6. Training & Awareness

The Analyst and team undergo periodic training on:

SEBI RA Regulations
Conflict identification and avoidance
Research ethics and compliance standards

7. Disclosure to Clients

Clients are informed of:

Analyst registration details (INH300009914)
Potential conflicts, if any, in every communication
Their right to seek clarification or lodge complaints regarding conflict

8. Non-Compliance & Disciplinary Action

Any breach of this Policy shall be treated as a serious violation. Disciplinary action may include:

Reporting to SEBI/BSE if required

9. Record keeping

All disclosures, research notes, logs of recommendations, and conflict declarations are preserved for a minimum of 5 years as mandated by Regulation 25 of SEBI RA Regulations.

10. Review & Updates

This policy shall be reviewed annually or as required by changes in law or business practice, and updated accordingly.

Disclaimer:

"Investment in securities market are subject to market risks. Read all the related documents carefully before investing." We are not responsible for your Profit and Loss. Past performance is no guarantee of future results.

Registration granted by SEBI, membership of BASL (in case of IAs) and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors. The investor is requested to take into consideration all the risk factors before actually trading in derivative contracts.