Rajesh Prabhudesai is also engaged in the activity of Investment Advisor. Both the activities i.e. Research Analyst and Investment Advisor are segregated. 

If we hold, at the time of recommendation, any holdings in the stocks on which we are expressing recommendation, we will disclose it. Our recommendation will not be influenced by our personal holdings. 

We charge fees to our customers that is our revenue model. We do not earn any income from the companies we cover. 

We do not earn any income from sell/distribution of third party products. 

Internal policy for conflict of interest 

Securities and Exchange Board of India (‘SEBI’) has notified General Guidelines for intermediaries, and their associated persons in securities market (hereinafter referred to as ‘Guidelines’) with the objective of avoiding or dealing with or managing conflict of interest by them. According to these Guidelines, all intermediaries including the Research Analyst(s) or Research Analyst are required to put in place a Conflict of Interest Policy (hereinafter referred to as ‘Policy’). 

To ensure compliance with the said Guidelines, Prabhudesai Rajesh S, being a SEBI registered Research Analyst having Registration No.  INH000023685 is required to adopt and adhere to such Guidelines. 

1. Research Analyst shall adhere to these guidelines for avoiding or dealing with   or managing conflict of interest. They shall be responsible for educating their associated persons for compliance of these guidelines. 
2. Research Analyst and their associated persons  shall, 

• lay down, with active involvement of senior management, policies and internal procedures to identify and avoid or to deal or manage actual or potential conflict of interest, develop an internal code of conduct governing operations and formulate standards of appropriate conduct in the performance of their activities, and ensure to communicate such policies, procedures and code to all  concerned; 
• at  all  times  maintain high standards  of  integrity in the conduct  of their business; 
• ensure fair treatment of their clients and not discriminate amongst  them; 
• ensure that their personal interest does not, at any time conflict with their duty to their clients and client’s interest always takes primacy in their advice, investment decisions and  transactions; 
• make appropriate disclosure to the clients of possible source or potential areas of conflict of interest which would impair their ability to render fair, objective and unbiased  services; 
• endeavor to reduce opportunities for conflict through prescriptive measures such as through information barriers to block or  hinder  the flow of information from one department/ unit to another,  etc.; 
• place appropriate restrictions on transactions in securities while handling a mandate of issuer or client in respect of such security so as to avoid any conflict; 
• not deal in securities while in possession of material non published information; 
• not to communicate the material non published information while dealing in securities on behalf of  others; 
• not in any way contribute to manipulate the demand for or supply of securities in the market or to influence prices of  securities; 
• not have an incentive structure that encourages sale of products not suiting the risk profile of their  clients; 
• not share information received from clients or pertaining to them, obtained as a result of their dealings, for their personal   interest; 

3. The management of Research Analyst shall put in place systems for implementation  of the aforementioned guidelines and provide necessary guidance enabling identification, elimination or management of conflict of interest situations.  The management shall review the compliance of the above guidelines  periodically. 

4. The said guidelines shall be in addition to the provisions, if any, contained in respective regulations/ circulars issued by the Board from time to time regarding dealing with conflict of interest, in respect of   Research Analyst.