Code of Conduct (IA)
Code of Conduct (IA)
SEBI Registered Investment Adviser
SEBI Registration No.: INA000020758
BASL Enlistment No.: 2318
1. Introduction
SR Alpha Investment Advisers has adopted this Code of Conduct in accordance with Regulation 15(9), read with the Third Schedule of the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013.
This Code applies exclusively to the investment advisory services provided by SR Alpha Investment Advisers under its SEBI Investment Adviser registration.
SR Alpha Investment Advisers is committed to providing investment advisory services honestly, fairly, professionally and in the best interests of its clients.
2. Applicability
This Code shall apply to SR Alpha Investment Advisers and, to the extent applicable, its:
- Partners;
- Principal Officer;
- Compliance Officer;
- Persons associated with investment advice;
- Employees;
- Representatives; and
- Other persons involved in providing or supporting investment advisory services.
3. Honesty and Good Faith
SR Alpha Investment Advisers shall act honestly and in good faith while conducting its research activities and providing research services.
The firm shall not make any false, misleading, exaggerated or deceptive representation regarding:
- Its investment advisory services;
- Expected or potential investment returns;
- Past performance;
- Investment products or securities;
- Regulatory registration; or
- The risks associated with an investment.
SEBI registration shall not be represented as an assurance of performance, returns or approval of any investment recommendation.
4. Diligence
SR Alpha Investment Advisers shall act with due skill, care and diligence while providing investment advisory services.
Investment advice shall be provided only after conducting appropriate analysis and considering relevant factors, including:
- The client’s investment objectives;
- Financial position;
- Investment experience;
- Risk profile;
- Risk-bearing capa
- city;
- Investment horizon;
- Liquidity requirements; and
- Reasonably available investment alternatives.
The firm shall ensure that the basis and rationale for the investment advice are appropriately recorded.
5. Capabilities
SR Alpha Investment Advisers shall maintain and effectively utilise the professional resources, infrastructure, systems and procedures necessary for the proper performance of its investment advisory activities.
The firm shall ensure that persons providing investment advice possess the qualifications, experience and certifications prescribed under the applicable SEBI regulations.
Appropriate internal controls shall be maintained for:
- Client onboarding;
- Know Your Client compliance;
- Risk profiling;
- Suitability assessment;
- Advisory communication;
- Record maintenance;
- Fee collection;
- Grievance redressal; and
- Regulatory compliance
6. Information About Clients
SR Alpha Investment Advisers shall obtain relevant information from its clients before providing investment advice.Such information may include the client’s:
- Age;
- Income and financial position;
- Existing investments and assets;
- Liabilities and borrowings;
- Investment knowledge and experience;
- Investment objectives;
- Investment horizon;
- Risk appetite and risk tolerance;
- Liquidity requirements; and
- Capacity to absorb investment losses.
The information obtained shall be used for risk profiling, suitability assessment and the provision of appropriate investment advice.
Client information shall be kept confidential and shall not be disclosed to any unauthorised person, except:
- With the client’s consent;
- Where required under applicable law; or
Where required by a regulatory, judicial or governmental authority.
7. Information to Clients
SR Alpha Investment Advisers shall provide clients with adequate, accurate and relevant material information relating to its services and recommendations.
The firm shall appropriately disclose:
- The nature and scope of its investment advisory services;
- The applicable advisory fees and charges;
- Material risks associated with recommended securities or investment products;
- Material conflicts of interest;
- Key features and limitations of recommended products;
- The basis of the investment recommendation;
- Relevant warnings and disclaimers;
- The terms and conditions of the advisory engagement; and
- Any other material information required for an informed investment decision.
The firm shall not conceal or omit material facts that may affect the client’s investment decision.
8. Fair and Reasonable Charges
SR Alpha Investment Advisers shall charge investment advisory fees in accordance with the limits, modes and conditions prescribed by SEBI and the recognised supervisory body from time to time.
The firm shall ensure that:
- Advisory fees are fair and reasonable;
- The fee structure is clearly communicated to the client;
- The applicable fees are recorded in the Investment Advisory Agreement;
- No undisclosed fee or charge is collected;
- Proper invoices or receipts are issued; and
- No assured-return or profit-sharing representation is made while charging fees.
Fees shall be collected only through permitted banking channels and in the manner prescribed under applicable regulations.
9. Conflicts of Interest
SR Alpha Investment Advisers shall endeavour to avoid actual or potential conflicts of interest.
Where a conflict cannot be avoided, the firm shall:
- Identify the conflict;
- Disclose the conflict to the affected client;
- Ensure that the conflict does not compromise the objectivity of the advice;
- Treat the client fairly; and
- Continue to act in the client’s best interests.
The firm shall maintain appropriate segregation between its investment advisory activities and its other business activities, including research services, as required under applicable regulations.
10. Compliance
SR Alpha Investment Advisers, including its partners, Principal Officer and persons associated with investment advice, shall comply with all regulatory requirements applicable to its investment advisory activities.
This includes compliance with:
- The SEBI Act, 1992;
- The SEBI (Investment Advisers) Regulations, 2013;
- Applicable SEBI circulars, master circulars and guidelines;
- Requirements of the recognised supervisory body;
- Know Your Client and anti-money-laundering requirements;
- Risk-profiling and suitability requirements;
- Client-level segregation requirements;
- Fee-related requirements;
- Record-maintenance requirements;
- Advertisement and communication requirements; and
- Investor grievance-redressal requirements.
11. Responsibility of Partners and Management
The partners and management of SR Alpha Investment Advisers shall bear primary responsibility for:
- Maintaining appropriate standards of conduct;
- Establishing and following proper internal procedures;
- Ensuring regulatory compliance;
- Supervising employees and persons associated with investment advice;
- Protecting confidential client information;
- Ensuring proper risk profiling and suitability assessment;
- Ensuring fair treatment of clients;
- Maintaining proper books and records; and
- Ensuring timely resolution of client grievances
12. Reporting of Violations
Any actual or suspected violation of this Code shall be promptly reported to the Principal Officer or Compliance Officer of SR Alpha Investment Advisers.
Any violation shall be reviewed and dealt with in accordance with the firm’s internal procedures and applicable regulatory requirements.
13. Review of the Code
This Code shall be reviewed periodically and updated wherever necessary to reflect amendments to applicable laws, regulations, circulars, master circulars or supervisory requirements
Published by:
SR Alpha Investment Advisers
SEBI Registered Investment Adviser
SEBI Registration No.: INA000020758