Prevention of Insider Trading Policy

1. Objective

This Prevention of Insider Trading Policy (“Policy”) is adopted to:

1. prevent insider trading, whether actual or perceived;
2. prevent misuse or communication of unpublished price sensitive information (UPSI);
3. ensure fairness, transparency and integrity in securities transactions;
4. maintain independence, objectivity and credibility of research and advisory activities; and
5. ensure compliance with the SEBI (Prohibition of Insider Trading) Regulations, 2015, the SEBI (Research Analysts) Regulations, 2014, and related circulars, as amended from time to time.

2. Applicability

This Policy shall apply to:

• all Research Analysts employed by the Company;
• all employees (permanent, contractual, temporary);
• Directors and the Chief Executive Officer;
• Directors and the Chief Executive Officer;
• the Compliance Officer; and
• immediate relatives of all the above persons.

Trading by immediate relatives shall be deemed to be trading by the concerned employee.

3. Definitions

3.1 Insider

Any person connected with the Company, directly or indirectly, who is reasonably expected to have access to unpublished price sensitive information, including employees, directors, officers and immediate relatives.

3.2 Unpublished Price Sensitive Information (UPSI)

Information relating to a company or its securities that is not generally available and which, upon becoming generally available, is likely to materially affect the price of the securities, including but not limited to research recommendations, model portfolio changes or internal deliberations.

3.3 Immediate Relative

Spouse, dependent children, parents, siblings or any person financially dependent on the employee or whose trading decisions are influenced by the employee.

3.4 Restricted Securities

Securities which are:

• under active research coverage;
• included or proposed to be included in model portfolios; or
• identified, shortlisted or discussed for Margin Trading Facility (MTF) recommendations.

4. Prohibition on Insider Trading

No insider shall:

1. trade in securities while in possession of UPSI;
2. communicate, provide or allow access to UPSI to any person except in furtherance of legitimate purposes, performance of duties or discharge of legal obligations;
3. trade in restricted securities prior to publication or dissemination of research, model portfolio changes or MTF identification; or
4. engage in front-running, misuse of unpublished research or any activity prohibited under SEBI regulations.

Same-day trading (buy and sell or sell and buy on the same day) in restricted securities is strictly prohibited.

5. Trading Window Controls

5.1 Research Reports

The trading window shall remain closed:

• 7 calendar days prior to publication of a research report; and
• 7 calendar days after dissemination of the report.

5.2 Model Portfolios

The trading window shall remain closed from the date of internal finalisation of any model portfolio change and reopen 7 calendar days after communication to clients.

5.3 MTF Securities

The trading window shall remain closed from the date of internal discussion or identification and reopen 7 calendar days after client communication.

6. Extended Closure of Trading Window

The Compliance Officer may extend the trading window closure for up to 30 calendar days, considering sensitivity of information or material events. Such closure shall be binding on all insiders.

7. Pre-clearance of Trades

1. Pre-clearance is mandatory for all insiders for securities transactions.
2. Pre-clearance is compulsory where the value exceeds ₹50,000 per transaction or a series of related transactions.
3. Approval shall be valid for 7 trading days.
4. Fresh pre-clearance shall be obtained if the trade is not executed within the validity period.

8. Contra Trades

No insider shall execute a contra trade in the same security within 30 calendar days of the original transaction.
Any exception shall require prior written approval of the Compliance Officer with recorded reasons.

9. Chinese Walls and Arm’s Length Dealing

• Employees shall maintain strict information barriers (“Chinese Walls”) between research, advisory and any group/sister company activities.
• All dealings with brokers, intermediaries, portfolio managers or advisers shall be strictly at arm’s length.
• Preferential access, unpublished information or trading advantage is strictly prohibited.

10. Disclosures

All insiders shall make:

• initial disclosures at the time of joining/adoption of this Policy;
• quarterly disclosures of holdings and trades; and
• annual disclosures as prescribed.

Failure to make timely and accurate disclosures shall constitute a violation.

11. Monitoring and Record Maintenance

The Compliance Officer shall:

• monitor compliance with this Policy;
• maintain records of disclosures, pre-clearances and violations; and
• preserve such records for a minimum of five (5) years.

12. Obligations of Directors and CEO

Directors and the CEO shall:

• avoid trading in securities covered under research, model portfolios or MTF identification;
• ensure the highest ethical standards; and
• make enhanced disclosures as required under law.

13. Penalty and Disciplinary Action

Violation of this Policy may result in:

• internal disciplinary action including warning, suspension or termination; and
• reporting to SEBI or other regulatory authorities, wherever required.

14. Review, Approval and Amendment

Version 1.0 of the Policy and has been approved by the Board of Directors on February 06, 2026. It shall be reviewed annually or upon regulatory change; and shall be amended only with the approval of the Board of Directors.