Code Of Conduct (RA)
Code Of Conduct (RA)
SR ALPHA INVESTMENT ADVISERS
SEBI Registration No.: INH000025975
BSE Enlistment No.: 7036
1. Introduction
SR Alpha Investment Advisers has adopted this Code of Conduct in accordance with Regulation 24(2), read with the Third Schedule of the Securities and Exchange Board of India (Research Analysts) Regulations, 2014.
This Code applies exclusively to the research services, research reports and research recommendations issued by SR Alpha Investment Advisers under its SEBI Research Analyst registration.
The firm is committed to maintaining the independence, integrity, objectivity and professional quality of its research activities.
2. Applicability
This Code shall apply to SR Alpha Investment Advisers and, to the extent applicable, its:
- Partners;
- Principal Officer;
- Compliance Officer;
- Employees;
- Persons associated with research services;
- Persons preparing or reviewing research reports;
- Persons communicating research recommendations; and
- Other persons involved in providing or supporting research services.
This Code applies to activities involving:
- Preparation or publication of research reports;
- Provision of research reports;
- Buy, sell or hold recommendations;
- Overweight or underweight recommendations;
- Price targets;
- Opinions regarding securities or public offers;
- Oral or written research recommendations; and
- Public appearances relating to securities.
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:
- Provide false or misleading research information;
- Make exaggerated or deceptive claims;
- Promise or assure investment returns;
- Misrepresent past performance;
- Conceal material risks; or
Represent SEBI registration as an assurance of the accuracy or profitability of a recommendation.
All research views shall represent genuinely held and independently formed opinions.
4. Diligence
SR Alpha Investment Advisers shall act with due skill, care and diligence while preparing research reports and issuing research recommendations.
The firm shall ensure that every research report or recommendation is supported by a reasonable and adequate analysis of relevant information, which may include:
- Annual reports;
- Quarterly results;
- Investor presentations;
- Management commentary;
- Industry and sector information;
- Economic and market conditions;
- Valuation data;
- Technical data, where applicable;
- Publicly available disclosures; and
- Material risks affecting the recommendation.
Research reports shall have an adequate documentary basis and the rationale for the recommendation shall be appropriately maintained.
5. Conflict of Interest
SR Alpha Investment Advisers shall identify and effectively address any actual or potential conflict of interest that may affect the impartiality or objectivity of its research analysis or research reports.
Where relevant, the firm shall make appropriate disclosures regarding:
- Financial interests in the subject company;
- Ownership of securities of the subject company;
- Material business relationships;
- Compensation received from the subject company;
- Association with the subject company;
- Services provided to the subject company;
- Personal or professional relationships affecting objectivity; and
- Any other material conflict of interest.
The firm shall ensure that its research conclusions are not influenced by sales, marketing, investment advisory, commercial or other business considerations.
6. Insider Trading and Front-Running
SR Alpha Investment Advisers, its partners, employees and persons associated with research services shall not engage in:
- Insider trading;
- Front-running of research reports;
- Front-running of research recommendations;
- Trading based on unpublished research information;
- Misuse of unpublished price-sensitive information; or
- Communicating confidential information to an unauthorised person.
No person covered by this Code shall trade, directly or indirectly, on the basis of advance knowledge of:
- A pending research report;
- A proposed buy, sell or hold recommendation;
- A change in an existing recommendation;
- A proposed price target;
- A proposed entry or exit level; or
- Any other unpublished research view.
All concerned persons shall comply with the applicable provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
7. Confidentiality
SR Alpha Investment Advisers and its employees shall maintain the confidentiality of research reports and research recommendations until they are released or communicated to the intended clients or subscribers.
- Unpublished research information shall not be:
- Disclosed to an unauthorised person;
- Used for personal trading;
- Used for the benefit of another person;
- Selectively disclosed to preferred clients;
- Shared with sales or marketing personnel for misuse; or
- Used to manipulate or influence the securities market.
- Access to unpublished research information shall be provided only on a need-to-know basis.
8. Professional Standards
SR Alpha Investment Advisers and persons engaged in research analysis shall maintain high professional standards while:
- Conducting securities research;
- Analysing companies, sectors and industries;
- Preparing research reports;
- Determining recommendations;
- Establishing price targets;
- Communicating research views;
- Making public appearances; and
- Responding to client or subscriber queries.
- Research reports and recommendations shall:
- Be clear and not misleading;
- Distinguish facts from opinions;
- Be based on reliable information;
- Contain appropriate risk disclosures;
- Define the meaning and time horizon of recommendations;
- Use recommendation terminology consistently; and
- Avoid claims of assured or guaranteed returns.
9. Compliance
SR Alpha Investment Advisers shall comply with all regulatory requirements applicable to its research activities and business operations.
This includes compliance with:
- The SEBI Act, 1992;
- The SEBI (Research Analysts) Regulations, 2014;
- Applicable SEBI circulars, master circulars and guidelines;
- Requirements of the Research Analyst Administration and Supervisory Body;
- Disclosure requirements applicable to research reports;
- Personal trading and securities-dealing restrictions;
- Advertisement and communication requirements;
- Record-maintenance requirements;
- Client consent and fee-related requirements;
- Research-report distribution requirements;
- Public-appearance requirements; and
- Investor grievance-redressal requirements.
10. Responsibility of Partners and Management
The partners and management of SR Alpha Investment Advisers shall bear primary responsibility for:
- Maintaining appropriate standards of research conduct;
- Preserving the independence and objectivity of research;
- Establishing proper internal procedures;
- Identifying and managing conflicts of interest;
- Supervising employees and persons associated with research services;
- Preventing insider trading and front-running;
- Protecting unpublished research information;
- Ensuring appropriate regulatory disclosures;
- Maintaining research records and supporting documents; and
- Ensuring compliance with applicable regulations.
11. Research Independence
Research reports and recommendations shall reflect the independent and unbiased view of the persons responsible for preparing the research.
No partner, employee, client, subject company, commercial department or other person shall improperly influence:
- The conclusion of a research report;
- The recommendation assigned to a security;
- The price target;
- The timing of publication; or
- The risks and disclosures contained in the report.
12. Reporting of Violations
Any actual or suspected violation of this Code, including any suspected conflict of interest, insider dealing, front-running or unauthorised disclosure of research information, shall be promptly reported to the Principal Officer or Compliance Officer.
Violations 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 Research Analyst
SEBI Registration No.: INH000025975