Code of Conduct | Navkar Research

Last updated: June 2026

Code of Conduct & Securities Dealing Procedures, prepared in accordance with the Third Schedule read with Regulation 24(2) of the SEBI (Research Analysts) Regulations, 2014.

Introduction

SEBI, vide Notification No. LAD-NRO/GN/2014-15/07/1414 dated September 01, 2014, notified the SEBI (Research Analysts) Regulations, 2014, which became effective from November 29, 2014. The Regulations were introduced with the objective of fostering transparency in securities research and providing investors with reliable and useful information for making informed investment decisions.

This Code of Conduct and Securities Dealing Procedures Policy has been adopted in accordance with the aforesaid regulations and shall govern the conduct of Mr. Rachit Jain, SEBI Registered Research Analyst bearing Registration No. INH000022738, and all associated persons engaged in research activities.

Applicability

This policy applies to Mr. Rachit Jain (“Research Analyst” or “RA”), including all employees, associates, representatives, and persons engaged in research activities, in particular those involved in:

Preparation or publication of research reports;
Issuing buy / sell / hold recommendations;
Providing price targets or opinions on securities;
Research activities relating to securities listed or proposed to be listed on recognised stock exchanges.

Honesty and fairness

The Research Analyst shall act honestly, fairly, and in good faith while conducting research activities and shall not engage in any act, omission, manipulation, or deceptive practice that may mislead investors.

Diligence and competence

Act with competence, care, and diligence.
Maintain and continuously improve professional knowledge, skills, and competence.
Ensure that research reports are based on thorough analysis and research.
Not provide research reports based on rumours, hearsay, or unverified information.

Independence and objectivity

All research activities shall be conducted independently and objectively.
The Research Analyst shall not compromise independence for commercial considerations.
Research reports shall not be influenced by subject companies or third parties.
Conflicts of interest shall be disclosed promptly and appropriately.

Disclosure of conflicts of interest

Disclose financial interests in securities recommended in research reports.
Disclose compensation received from subject companies, if any.
Disclose positions held in securities of subject companies, wherever applicable.
Ensure disclosures are clear, prominent, adequate, and not misleading.

Client interests first

The interests of investors shall be placed above personal or business interests.
Research recommendations shall be fair, balanced, and unbiased.
Research services shall remain compliant with applicable SEBI regulations at all times.

Compliance with regulations

Comply with all applicable laws, regulations, SEBI circulars, and guidelines.
Maintain required records and registers as prescribed under SEBI regulations.
Submit timely reports, disclosures, and regulatory filings.
Co-operate fully with SEBI, stock exchanges, and regulatory inspections.

Prohibition on insider trading and front running

The Research Analyst shall not engage in or facilitate insider trading, front running, or misuse of unpublished price-sensitive information. All research activities shall be based only on publicly available information.

Insider dealing

No employee or associated person in possession of unpublished price-sensitive information shall: trade in securities relating to such information; publish research reports relating to such securities; communicate such information to unauthorised persons; or provide recommendations based on unpublished information.

Front running

Front running is strictly prohibited. It may arise through (a) misuse of advance knowledge of pending client orders; or (b) misuse of unpublished research recommendations or reports prior to publication or dissemination to clients.

Fair dealing

The Research Analyst shall deal fairly with all investors and shall not discriminate between investors in providing access to research reports, recommendations, or services.

Prohibition on churning

The Research Analyst shall not issue research reports or recommendations with the intention of inducing excessive trading activity that is not in the best interest of investors.

Record maintenance

The Research Analyst shall maintain proper records of research reports; client agreements and communications; complaints and grievance resolution; and compliance and disclosure documents. Records shall be maintained for the period prescribed under applicable SEBI regulations.

Prohibition on assured returns

The Research Analyst shall not make any promise, assurance, or guarantee of returns or profits from investments based on research reports. All research services are provided on a best-effort basis.

Confidentiality

The Research Analyst shall maintain confidentiality of research reports, client information, and internal communications until disclosure is legally required or such information becomes public.

Professional standards

The Research Analyst and associated persons engaged in research activities shall maintain high professional and ethical standards while preparing research reports and making investment recommendations.

Responsibility of senior management

Senior management shall bear primary responsibility for ensuring adherence to this Code of Conduct and the implementation of proper compliance systems and ethical business practices.

Review and updates

This policy may be reviewed and updated from time to time in accordance with amendments to SEBI regulations and other applicable laws.

Research Analyst: Mr. Rachit Jain
SEBI Registration No.: INH000022738
Brand Name: Navkar Research

Navkar Research — SEBI Registered Research Analyst (Reg. No. INH000022738, BSE Enlistment No. 6756). For any clarification regarding this document, please contact us.