Compliance · 10

Code of Conduct

// LAST UPDATED: [DATE] · APPLIES TO rasaumya.com

The following Code of Conduct is observed by Dr. Saumya Agarwal, SEBI Registered Research Analyst (Reg. No. INH000027496), in accordance with the SEBI (Research Analysts) Regulations, 2014, as amended.

Honesty and Good Faith

The Research Analyst shall act honestly and in good faith.

Diligence

The Research Analyst shall act with due skill, care and diligence and shall ensure that the research report is prepared after thorough analysis.

Conflict of Interest

The Research Analyst shall effectively address conflict of interest which may affect the impartiality of its research analysis and research report and shall make appropriate disclosures to address the same.

Insider Trading or Front Running

The Research Analyst or its employees shall not engage in insider trading or front running or front running of its own research report.

Confidentiality

The Research Analyst or its employees shall maintain confidentiality of the report till the report is made public.

Professional Standard

The Research Analyst or its employees engaged in research analysis shall observe high professional standards while preparing the research report.

Compliance

The Research Analyst shall comply with all regulatory requirements applicable to the conduct of its business activities.

Responsibility of Senior Management

The senior management of the Research Analyst shall bear primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures.

This Code of Conduct is prescribed under the SEBI (Research Analysts) Regulations, 2014. It is reproduced here as a binding standard governing all research activity conducted by Dr. Saumya Agarwal.