PKC Trading

Internal Policy

At PKC TRADING, we are committed to upholding the highest standards of professional conduct, transparency, and ethical research practices. This Internal Policy serves as a guiding framework for all research analysts and associated personnel operating under our organization, in alignment with SEBI (Research Analyst) Regulations and globally recognized best practices.

1. Disclosure of Conflicts of Interest

We are committed to full transparency. Any potential or actual conflicts of interest—whether direct or indirect—will be disclosed in all relevant communications, including research reports. This includes:

  • Financial interests in the securities or companies we cover
  • Any business relationships with subject companies
  • Compensation structures that may influence research outcomes

2. Insider Trading Prohibition

We strictly prohibit the use of any unpublished price-sensitive information (UPSI) obtained during the course of our professional activities. All analysts and staff must comply with SEBI’s Prohibition of Insider Trading Regulations and internal compliance protocols. Any breach will be dealt with as a serious disciplinary matter.

3. Independence and Objectivity of Research

Our research analysts operate with full autonomy in developing, reviewing, and publishing their work. No individual, internal or external, is permitted to exert undue influence on research opinions or recommendations. Our analysts are shielded from business or client pressures that could compromise research objectivity.

4. Methodological Soundness

All research reports are developed using a transparent, repeatable, and empirically grounded methodology. We avoid speculation and clearly define the assumptions, data sources, and limitations behind our analysis to ensure the credibility of insights provided.

5. Quality Assurance

Each research output undergoes a multi-level review process to ensure factual accuracy, relevance, and timely delivery. Our commitment is to maintain:

  • Accuracy in data interpretation
  • Timeliness of updates
  • Professional tone and clarity in communication

6. Regulatory Compliance

We maintain full compliance with all applicable laws and regulations, including:

  • SEBI (Research Analyst) Regulations, 2014
  • SEBI’s Code of Conduct and Circulars
  • Any relevant provisions under the Companies Act, 2013 or Securities Contracts (Regulation) Act

Ongoing training is provided to ensure all team members are aware of evolving compliance responsibilities.

7. Confidentiality and Data Protection

All non-public data, whether pertaining to clients, partners, or securities, is handled with strict confidentiality. Access to sensitive information is role-based and monitored. Analysts and team members are prohibited from sharing or using such information outside legitimate business interests.

8. Transparent Client Disclosures

We will disclose:

  • The nature and scope of any financial interest in the subject companies
  • Methodologies, assumptions, and disclaimers associated with the research
  • Any risks involved in acting on the research recommendations

Disclosures will accompany each research communication or service engagement.

9. Ethics and Accountability

All employees, analysts, and support staff at PKC TRADING are expected to act with:

  • Integrity and professional responsibility
  • Zero tolerance for misinformation or manipulation
  • Accountability for the accuracy and impact of their work

Conclusion

By enforcing this internal policy, PKC TRADING seeks to maintain trust, transparency, and regulatory excellence across all research operations. This policy shall be reviewed periodically and updated as necessary to reflect evolving legal and operational requirements.

Let me know if you’d like to also generate a compliance attestation form or acknowledgment section for new analyst onboarding.