Code of Conduct

Sumit Pal (Individual) is a SEBI Registered Research Analyst vide Registration Number INH300008757 dated September 10, 2021. Sumit Pal is an Individual Registered Research Analyst.

In accordance to Regulation 24 (2) of the SEBI (Research Analyst) Regulations, 2014, I shall
maintain the following Code of Conduct:

1. Honesty and Good Faith
I shall act honestly and in good faith.
2. Diligence
I shall act with due skill, care and diligence and shall ensure that the research report is prepared
after thorough analysis.
3. Conflict of Interest
I shall effectively address conflict of interest which may affect the impartiality of research
analysis and research report and shall make appropriate disclosures to address the same.
4. Insider Trading or front running
I shall not engage in insider trading or front running of my own research report.
5. Confidentiality
I shall maintain confidentiality of report till the report is made public.
6. Professional Standard
I am engaged in research analysis and shall observe high professional standard while preparing
research report.
7. Compliance
I shall comply with all regulatory requirements applicable to the conduct of its business
activities.
8. Responsibility of senior management
I shall bear primary responsibility of senior management for ensuring the maintenance of
appropriate standards of conduct and adherence to proper procedures.