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Code of Conduct

Code of Conduct

Code of Conduct – Securities Dealing Procedures

In accordance with SEBI (Research Analysts) Regulations, 2014.

VISHAL BHINGARADIYA (Vista Nivesh)
SEBI Registration Number: INH000010706
Address: 26, Vandana Soc-2, Bhid Bhanjan Pachhad, Nana Varachha, Surat, Gujarat, 395006

Introduction

SEBI, through Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September 2014, introduced the SEBI (Research Analysts) Regulations, 2014, which became effective from 29th November 2014. These regulations aim to foster transparency in securities research and provide investors with reliable and useful information to make informed investment decisions.

This Code of Conduct outlines the securities dealing procedures to ensure compliance with the said regulations.

Applicability

This policy is applicable to Vista Nivesh, including its Research Analysts, who are primarily responsible for:

  • Preparing or publishing the content of research reports.

  • Providing research reports.

  • Making buy, sell, hold or ‘overweight, underweight’ recommendations.

  • Giving price targets or offering opinions on securities listed or to be listed on a stock exchange.

Code of Conduct for Research Analysts

  • Honesty and Good Faith
    Research Analysts shall act honestly and in good faith in their professional activities.

  • Diligence
    Research Analysts shall act with due skill, care, and diligence, ensuring that research reports and stock recommendations are based on thorough analysis.

  • Conflict of Interest
    Research Analysts shall address conflicts of interest that may affect the impartiality of their research and shall make appropriate disclosures to mitigate such conflicts.

  • Insider Trading or Front Running
    Research Analysts shall not engage in insider trading or front running, including trading ahead of their own research reports or stock recommendations

  • Confidentiality
    Research Analysts shall maintain the confidentiality of reports and research recommendations until they are made public or shared with respective clients

  • Professional Standards
    Research Analysts shall observe high professional standards while preparing research reports or analyzing companies for stock recommendations.

  • Compliance
    Research Analysts shall comply with all applicable regulatory requirements relevant to their business activities.

  • Insider Dealing
    No staff member in possession of inside information may trade, recommend, or publish research concerning financial instruments related to such information.

  • No Front-Running
    Front-running is strictly prohibited. This includes:
    • Using client order information in advance.
    • Acting on knowledge of the timing or content of research before it is shared with clients.