Conflict of Interest Policy
1. Purpose
The purpose of this Conflict of Interest Policy is to define, identify, disclose, and manage conflicts of interest for employees engaged in research analysis at SRPL, in compliance with SEBI regulations. The goal is to maintain the highest standards of integrity, objectivity, and transparency in our research and advisory activities.
2. Scope
This policy applies to all employees of SRPL, including but not limited to research analysts, senior management, and other relevant staff involved in research and investment decision-making processes.
3. Definition of Conflict of Interest
A conflict of interest arises when an employee’s personal interests, relationships, or financial interests could interfere with their duty to act in the best interests of SRPL’s clients and the integrity of the research process. This includes, but is not limited to:
- Financial interests in securities or companies that are the subject of research.
- Personal relationships with individuals or entities that could influence or appear to influence research conclusions.
- Outside business interests that may affect impartiality or objectivity.
4. Disclosure Requirements
4.1 Initial Disclosure
- All employees must complete a Conflict of Interest Disclosure Form upon hiring.
- Disclosures must include information on personal investments, outside business activities, and significant personal relationships.
4.2 Ongoing Disclosure
- Employees are required to update their disclosures annually and whenever there are significant changes in their circumstances.
4.3 Review Process
- A Conflict of Interest Review Committee, comprising the Principal Officer and Compliance Officer of SRPL, will review all disclosures. The committee is responsible for assessing potential conflicts and determining appropriate actions.
5. Management of Conflicts
5.1 Avoidance
- Employees must avoid situations where their personal or financial interests could compromise their professional judgment.
- Research assignments will be structured to minimize potential conflicts. Analysts will not be assigned to research topics where a direct conflict of interest exists.
5.2 Mitigation
- Significant personal investments in companies under research must be placed in blind trusts, if applicable.
- Any identified conflicts will be disclosed to clients and stakeholders as per SEBI regulations.
6. Ethical Standards and Training
6.1 Code of Conduct
- Employees must adhere to SRPL’s Code of Conduct, which emphasizes ethical behaviour and compliance with conflict of interest policies.
6.2 Training Programs
- Regular training on conflict of interest policies and ethical standards will be provided to all employees.
7. Reporting Mechanism
7.1 Whistle-blower Policy
- Employees can report potential conflicts of interest anonymously through the whistle-blower hotline or email. All reports will be investigated promptly and confidentially.
7.2 Internal Reporting
- Employees must report any actual or potential conflicts of interest to their direct supervisor or the Conflict of Interest Review Committee.
8. Documentation and Record-Keeping
8.1 Record Maintenance
- Comprehensive records of all disclosures, reviews, and management actions will be maintained.
- Documentation will be kept for a minimum of five years or as required by SEBI regulations.
8.2 Audit Trail
- An audit trail will be maintained to track how conflicts of interest are identified, managed, and resolved.
9. Regulatory Compliance
9.1 SEBI Guidelines
- This policy will be regularly reviewed and updated to ensure compliance with SEBI regulations and any changes in the regulatory framework.
9.2 Policy Updates
- Any updates to the policy will be communicated to all employees. Employees are required to familiarize themselves with any changes.
10. Communication
10.1 Internal Communication
- This policy will be communicated to all employees, who are required to acknowledge receipt and understanding.
10.2 Client Communication
- SRPL will transparently communicate its conflict of interest management practices to clients and stakeholders.
11. Review and Amendments
This policy will be reviewed annually or as needed to ensure its effectiveness and compliance with regulatory requirements. Amendments will be made as necessary, and all changes will be communicated to employees.
12. Contact Information
For any questions or further clarification regarding this policy, employees may contact HR Department
Conflict of Interest Policy Version 1.0 approved by the Board of Directors on 06-02-26