Code of Conduct

Last updated 21 September 2026 · Version 2026-09

Sugam Kashyap abides by the Code of Conduct for Research Analysts in Schedule III of the SEBI (Research Analysts) Regulations, 2014, summarised below.

1. Honesty and good faith. Act honestly and in good faith.
2. Diligence. Act with due skill, care and diligence and ensure research is prepared after thorough analysis.
3. Conflict of interest. Take effective steps to avoid conflicts; disclose those that cannot be avoided.
4. Insider trading and front running. Not indulge in insider trading or front running; not trade contrary to published recommendations within the restricted period; not accept inducements.
5. Confidentiality. Maintain confidentiality of research before publication and of client information.
6. Professional standards. Maintain the required certifications, comply with the regulations, circulars and guidelines, and disclose regulatory and disciplinary history.
7. Compliance with rules and regulations. Comply with applicable law and cooperate with SEBI and RAASB.
8. Responsibility. Take responsibility for all research published under the registration, including where AI tools assist.
9. Advertisements. Communicate only in a fair, true and unambiguous manner in line with the SEBI advertisement code; no superlatives, no promise of returns, no testimonials.

Personal trading policy

The Research Analyst and immediate family do not trade in a security contrary to a published recommendation for 30 days after publication, and do not trade ahead of publication. Holdings are disclosed on every report.