Formal Procedure for Trading by Research Analysts
1. Objective
This procedure lays down the framework to regulate personal trading by the Research Analyst (RA) and ensure compliance with the SEBI (Research Analysts) Regulations, 2014, so that research activities remain unbiased, transparent, and in the best interest of investors.
2. Applicability
This procedure applies to:
- The Research Analyst (RA).
- Immediate relatives of the RA.
- Any trading accounts where the RA has direct or indirect control.
3. General Principles
- The RA shall maintain the highest standards of integrity, independence, and objectivity while preparing research reports and recommendations.
- The RA shall not indulge in front running, misuse of unpublished price sensitive information (UPSI), or create any conflict of interest while dealing in securities.
4. Trading Restrictions
- No trading is permitted in securities covered in research reports for 30 calendar days before and 5 calendar days after the publication of such reports.
- The RA must not trade contrary to their own recommendations for at least 30 calendar days after making such recommendation.
- Contra trades — buying and selling the same security within 30 calendar days — are strictly prohibited.
5. Record Maintenance
- All requests for approval, granted approvals, and executed trades shall be recorded and preserved for at least 5 years.
- A trading register shall be maintained to monitor compliance with this procedure.
6. Reporting of Violations
- Any violation of this procedure must be immediately reported to the Compliance Officer, Pardeep Kumar, at help.tradenova@gmail.com.
- Disciplinary action, including restriction on further trading, monetary penalty, or reporting to SEBI, may be taken in case of violations.
7. Review
This procedure will be reviewed periodically to ensure alignment with applicable laws and SEBI regulations.
8. Approval & Acknowledgement
This procedure has been reviewed and approved by the undersigned and is effective from the date mentioned below.
Regards,
Trade Nova Technologies Private Limited
SEBI Registered Research Analyst
SEBI Registration No.: INH000026789
Need help with this?
Our Principal Officer, Harinder Singh, and Compliance Officer, Pardeep Kumar, are available Mon–Fri · 9:00 AM to 5:00 PM.