Code of Conduct – Securities Dealing Procedures in terms of SEBI (Research Analysts) Regulations, 2014
Trading Sky
SEBI Registration Number: INH000016029
Address: B-149, Upper Ground Floor, Left Side F/P, Old No. 507, Shaheen Bagh, Abul Fazal Enclave Part-II, Delhi, National Capital Territory of Delhi, 110025
Introduction
SEBI, through Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September 2014, has introduced the SEBI (Research Analysts) Regulations, 2014, which became effective on 29th November 2014. These regulations aim to foster transparency in security 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 aforementioned regulations.
Applicability
This policy is applicable to Trading Sky, including 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 make appropriate disclosures to mitigate such conflicts.
- Insider Trading or Front Running
Research Analysts shall not engage in insider trading or front running, including the front running 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 provided to 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 regulatory requirements applicable to their business activities.
- Insider Dealing
No staff member in possession of inside information may be involved in trading, making recommendations, or publishing research concerning the financial instruments to which the information pertains.
- No Front-Running
Front-running is strictly prohibited. This can occur in two ways:
- Using client order information, i.e., utilizing the advantage of advance knowledge of pending client orders.
- Using information about the timing or contents of research prior to its publication to clients.
