Internal Policy for Research Activities

To maintain the highest ethical standards and comply with regulatory requirements, PKC TRADING (SEBI Reg. No. INH000021836 | BSE Enlistment No. 6634) adheres to the following internal policies regarding research activities:

1. Disclosure of Conflicts of Interest

• Transparency: Any actual or potential conflicts of interest that could influence research reports or recommendations must be fully disclosed to clients.
• Affiliations: All analysts must declare any financial interest, beneficial ownership, or material connection to the subject companies being researched.

2. Insider Trading Prohibition

• Zero Tolerance: Analysts and employees are strictly prohibited from trading in securities based on Unpublished Price Sensitive Information (UPSI).
• Trading Restrictions: Personal trading by analysts is monitored to prevent anticipated trading ahead of research report publications, in accordance with SEBI (Prohibition of Insider Trading) Regulations.

3. Independence and Objectivity of Research

• Unbiased Analysis: Research reports must be based on factual data, rigorous analysis, and independent judgment, free from external pressure or influence from subject companies.
• Separation of Functions: Research activities are segregated from other business functions (if any) to prevent the flow of sensitive information that could compromise objectivity.

4. Methodological Soundness

• Basis of Recommendations: All buy/sell/hold recommendations must be supported by adequate documentation, clear rationale, and reliable public data.
• Consistency: Analysts must apply consistent methodologies and clearly state the risks and assumptions underlying their recommendations.

5. Quality Assurance

• Review Process: Research reports undergo internal review for accuracy, clarity, and regulatory compliance before dissemination.
• Record Keeping: Records of research reports, recommendations, and the rationale behind them are maintained for a minimum period of 5 years as per SEBI norms.

6. Regulatory Compliance

• Adherence to Laws: All research activities must strictly comply with SEBI (Research Analysts) Regulations, 2014, and other applicable laws.
• NISM Certification: All individuals engaged in research activities must hold valid NISM Series XV: Research Analyst Certification.

7. Confidentiality and Data Protection

• Client Data: Strict protocols are in place to safeguard client information and prevent unauthorized access or sharing.
• Proprietary Information: Internal research data and draft reports are treated as confidential until officially published.

8. Transparent Client Disclosures

• Risk Warnings: Every research report must prominently display risk disclosures and disclaimers regarding market volatility and investment risks.
• Terms of Service: Clients are clearly informed about the scope of services, fees, and the non-guaranteed nature of market returns.

9. Ethics and Accountability

• Code of Conduct: All team members must adhere to a strict Code of Conduct promoting integrity, honesty, and professional behavior.
• Violations: Breaches of internal policy or regulatory norms are subject to disciplinary action, including termination and reporting to regulatory authorities where necessary.