Internal Policy

1. Research Analyst Independence Policy

N.S. Fidai maintains strict independence in research activities. Research opinions are based solely on analysis and are not influenced by any external parties, including issuers, promoters, or financial sponsors.

• Research Analyst does not accept payment or inducement from any company for publishing research.
• Research Analyst does not commit to a specific research opinion in exchange for compensation.
• Research reports are reviewed solely for factual accuracy, not for content or opinion.

2. Information Barriers (Chinese Walls)

To prevent misuse of material non-public information:

• Research activities are maintained separately from any investment activities.
• Non-public information received in a professional capacity is not used in research.
• All research is based on publicly available information.

3. Personal Account Dealing Policy

• The Research Analyst shall not deal in any security mentioned in a research report for a defined period before and after the report's publication.
• Personal investments are disclosed as required by SEBI regulations.
• Trading in securities contrary to recommendations made in research reports is prohibited.

4. Research Report Quality Control

• All research reports undergo review for accuracy before publication.
• Reports include publication date and are clearly marked with SEBI registration number.
• Analysts provide their name in research reports as required.
• Reports clearly state the basis and methodology of recommendations.

5. Record Maintenance

The following records are maintained for a minimum of 5 years:

• All published research reports
• Client agreements and KYC records
• Complaint records and resolution details
• Communications with clients regarding research
• SEBI correspondence and inspection records

6. Conflict of Interest Management

• Conflicts of interest are identified, disclosed, and managed proactively.
• Where conflicts cannot be managed adequately, the Research Analyst refrains from publishing research.
• All disclosures are clear, prominent, and not buried in footnotes.

7. Compliance Reviews

Internal compliance review is conducted annually to ensure adherence to SEBI regulations. Annual compliance certificate is filed with SEBI as required.

8. Whistleblower Policy

Any person who becomes aware of a violation of SEBI regulations or this policy may report it confidentially to: compliance@indiaequitynetwork.com with a cc to ram.iyer@indiaequitynetwork.com & nsfidai@indiaequitynetwork.com

Last Updated: 26th April 2026