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CONFLICT OF INTEREST POLICY
In compliance of SEBI Circular CIR/MIRSD/5/2013 dated August 27,
2013
1.The Proprietor shall take measures to identify and avoid or to
deal or manage actual or potential conflict of interest, develop
an internal code of conduct governing operations and formulate
standards of appropriate conduct in the performance of their
activities, and ensure to communicate such policies, procedures
and code to all concerned;
2.The company and its employees shall
a)At all times maintain high standards of integrity in the
conduct of their business
b)Ensure fair treatment of their clients and not discriminate
amongst them
c)Ensure that their personal interest does not, at any time
conflict with their duty to their clients and client’s interest
always takes primacy in their advice, investment decisions and
transactions
d)Make appropriate disclosure to the clients of possible source
or potential areas of conflict of interest which would impair
their ability to render fair, objective and unbiased services
e)Endeavour to reduce opportunities for conflict through
prescriptive measures such as through information barriers to
block or hinder the flow of information from one department/
unit to another, etc.
f)Place appropriate restrictions on transactions in securities
while handling a mandate of issuer or client in respect of such
security so as to avoid any conflict;
g)Not deal in securities while in possession of material non
published information
h)Not to communicate the material non published information
while dealing in securities on behalf of others;
i)Not in any way contribute to manipulate the demand for or
supply of securities in the market or to influence prices of
securities;
j)Not have an incentive structure that encourages sale of
products not suiting the risk profile of their clients
k)Not share information received from clients or pertaining to
them, obtained as a result of their dealings, for their personal
interest.
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