Conflict of Interest

This page summarises AlgoGreek Research’s internal policies and procedures to address conflict of interest, as submitted with Annexure 20A to SEBI. Material conflicts, if any, will also be disclosed in individual research reports. This page does not state that no conflict exists.

Arms-length and independence

The Research Analyst shall maintain an arms-length relationship between its research activity and other activities. A ‘Chinese Wall’ policy separates research activities from other business activities. Employees working as research analysts shall not communicate unpublished research information to anyone in another department. Research activities remain independent of any commercial technology-platform operations, marketing partnerships, or third-party client solicitation activities.

As a sole proprietorship, the proprietor, Chander Navani, structurally fulfils the regulatory role of the Compliance Officer until a separate officer is appointed.

Objective of the policy

• Establish internal control procedures governing dealing and trading by any research analyst.
• Address actual or potential conflict of interest arising from dealings or trading in securities of a subject company, and promote objective research that reflects an unbiased view.
• Prevent the use of a research report or research analysis to manipulate the securities market.
• Implement mechanisms to keep research independent of other business activities of the Research Analyst.
• Ensure compliance with SEBI rules and regulations.

Limitations on personal trading

• Personal trading of individuals employed as research analysts, if any, shall be monitored, recorded and, where necessary, subject to a formal approval process.
• The Research Analyst shall not deal or trade in any securities that the analyst recommends or follows within 30 days before and 5 days after publication of a research report on the subject company, and shall not deal or trade in a manner contrary to an outstanding recommendation.
• The Research Analyst shall not purchase or receive securities of an issuer before that issuer’s IPO if the issuer is principally engaged in the same types of business as companies that the analyst follows or recommends.
• The above restrictions shall not apply in case of significant news or event concerning the subject company, or based upon an unanticipated significant change in the personal financial circumstances of the research analyst, subject to complete internal written documentation and compliance logging.

Compensation

Research analysts in the employment of AlgoGreek Research shall not be entitled to any bonus, salary or other form of compensation that is based on specific brokerage-services transactions. Compensation of research analysts shall be reviewed, documented and approved annually. Research analysts shall perform their duties independently.

Publication, public appearance and conduct of business

Research reports issued by Chander Navani, proprietor of AlgoGreek Research, or any employed research analyst, shall be based on adequate documentary research evidence. The Research Analyst shall not provide any promise or assurance of favourable review in a research report to a company or industry as consideration to commence or influence a business relationship or for the receipt of compensation or other benefits.

Research analysts shall not engage in sales or marketing related to brokerage-service divisions, shall not participate in business activities designed to solicit investment banking, merchant banking or brokerage-services business (such as sales pitches and deal road shows), and shall not communicate with a current or prospective client in the presence of brokerage personnel about such transactions.

Quiet-period restrictions around IPO / FPO manager, co-manager and underwriter roles apply as specified in the Annexure 20A policy (including the 40-day / 10-day / 25-day / 15-day windows described there), unless prior written approval is obtained from the Compliance Officer. AlgoGreek Research is applying as an independent individual Research Analyst and not as a corporate Research Entity engaged in merchant banking or underwriting; those quiet-period rules would apply if that structural setup changes with prior SEBI approval.

Ownership, financial interest and relationships with subject companies

In research reports and public appearances, AlgoGreek Research shall disclose, as applicable:

• whether the Research Analyst, an associate or a relative has any financial interest in the subject company, and the nature of such financial interest;
• whether the Research Analyst, associates or relatives have actual / beneficial ownership of 1% or more securities of the subject company at the end of the month immediately preceding the date of publication or public appearance;
• any other material conflict of interest at the time of publication or public appearance;
• whether compensation has been received from the subject company in the past 12 months;
• whether the Research Analyst or associates have managed or co-managed a public offering of the subject company in the past 12 months;
• whether compensation has been received for investment banking, merchant banking or brokerage services from the subject company in the past 12 months;
• whether compensation has been received for products or services other than the above from the subject company in the past 12 months;
• whether compensation or other benefits have been received from the subject company or a third party in connection with the research report;
• whether the Research Analyst has served as an officer, director or employee of the subject company;
• whether the Research Analyst has been engaged in market-making activity of the subject company.

Applicable material conflicts will be disclosed in individual research reports. Absence of a disclosure on this page is not a representation that no conflict exists in respect of any particular subject company.

Code of conduct (extract)

• Honesty and good faith.
• Diligence: research reports shall be prepared after thorough analysis.
• Conflicts of interest shall be addressed and disclosed so as not to affect impartiality.
• No insider trading, front running, or front running of own research reports.
• Confidentiality of a report until it is made public.
• High professional standard while preparing research reports.
• Compliance with all applicable regulatory requirements.