Internal Policy

Most Research Analysts maintain these controls and do not publish them. We publish ours, because a control you cannot see is a control you cannot rely on.

1. Segregation of activities — the Chinese Wall

Research activity is segregated from every other activity carried on by the Research Analyst. Information obtained in the course of research is not shared with, or used for the benefit of, any other activity, and no other activity is permitted to influence the substance or timing of a research recommendation.

The Research Analyst carries on no investment banking, merchant banking or brokerage business, and holds no distribution registration for any financial product. This removes the most common source of conflict entirely, rather than managing it.

2. Personal trading — the blackout

The Research Analyst maintains a personal portfolio of Indian listed equities. That portfolio is a real and continuing constraint on what may be published and when — publishing on a security freezes his own dealing in it for the whole blackout window — and the coverage universe is selected with that constraint applied, not around it. Any holding in a covered company is disclosed in the report itself. See Disclosure.

3. Compensation

No part of the Research Analyst's compensation is linked to any specific recommendation or view, to the volume of recommendations issued, or to any transaction executed by any client. Compensation comes solely from subscription fees. No compensation of any kind is accepted from a subject company.

4. Blackout windows around public offerings

Where the Research Analyst is in any way associated with a public offering, no research report on that subject company is published during the applicable restricted periods — 40 days for an initial public offering and 10 days for a further public offering where acting as manager, and 25 days where acting as underwriter. In practice the Research Analyst undertakes no such roles.

5. Recommendation integrity

• Every recommendation is timestamped at publication and carries the price on the recommendation date, the valuation basis, and an explicit review or exit trigger.
• A published recommendation is never silently amended. A change of view is issued as a new, dated document and the record retains both.
• The record of recommendations available to subscribers is the complete record, including recommendations that did not work. Nothing is removed from it.
• No performance figure, return figure, win rate or profit-and-loss statement is used as a marketing claim anywhere on this website or in any communication.

6. Research process and independence

Research is prepared from primary sources — exchange filings, annual reports and regulatory disclosures — cross-checked against independent data sources, with any disagreement between sources disclosed rather than resolved silently. The recommendation is the Research Analyst's own. The role of artificial intelligence tools in this process, and its limits, are disclosed on the AI Use Disclosure page.

7. Records

Research reports, the basis and rationale for each recommendation, client agreements, KYC records, fee records, and the complete record of complaints and their resolution are maintained for a minimum of five years and produced to SEBI or the BSE Limited (Research Analyst Administration and Supervisory Body) on request.

8. Qualification and certification

The Research Analyst holds the NISM-Series-XV: Research Analyst Certification Examination, certificate number NISM-202500192228, valid until 11 June 2029. It is verifiable at https://certifications.nism.ac.in/nismskills. The certification is renewed before expiry as required.

9. Compliance calendar