Internal Policy

Internal Policies & Control Procedure in terms of SEBI (Research Analysts) Regulations, 2014

INDEX

  1. Preamble
    2. Applicability
    3. Definitions
    4. Management of Conflict of Interest and Disclosure Requirements
    a) Limitations on trading by research analysts
    b) Compensation of Research Analyst
    c) Limitation on Publication of Research Report, Public Appearance, Conduct of Business, etc.
    d) Disclosures in Research Report
    5. Other Conditions
    6. Review of the Policy
  2. Preamble

Securities Exchange Board of India vide its Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September, 2014 has notified SEBI (Research Analysts) Regulations, 2014.
This regulations have been introduced by SEBI with the objective of fostering transparency in security research and provide investors with more reliable and useful information
to make investment decisions.

According to these Regulations, Research Analysts or Research Entity are required to put in place a comprehensive policy framework as prescribed in Chapter III of SEBI
(Research Analysts) Regulations 2014.

  1. Applicability

The policy shall be applicable to all employees of BIGPROFITBUZZ engaged in Research Department as a Research Analyst i.e. person primarily responsible for
preparation or publication of the content of the research report; or providing a research report or Making ‘buy sell/ hold’ recommendation or giving price target or offering opinion
concerning public offer with respect to securities that are listed or to be listed in a Stock Exchange whether or not such person has the job title of ‘Research Analyst’.
It also includes an associated person who reports directly or indirectly to a research analyst(s).

  1. Definitions

Various terms shall have the following definitions and the other terms shall have the same meaning assigned to them in the captioned SEBI Regulations.

  1. a) “Price Target” means expectations of research analyst on the future performance of specific securities.
  2. b) “Public Appearance” means any participation in a conference call, seminar, forum (including interactive and non-interactive electronic forum), radio or television or internet
    or web or print media broadcast, authoring a print media article or other public speaking activity in public media in which a research analyst makes a recommendation or offers an opinion,
    concerning securities or public offer provided that it does not include a password protected webcast, conference call or such other events with the clients, if all of the event
    participants previously received the research report or other documentation that contains the required applicable disclosures and that the research analyst appearing at the event
    corrects and updates during the public appearance any disclosure in the research report that are inaccurate, misleading or no longer applicable’
  3. c) “Public Offer” includes initial public offer, further public offer, Offer for sale, disinvestment, takeover, buy-back or delisting of securities.
  4. d) “Relative” means a person as defined in sub section (77) of section 2 of the Companies Act, 2013 and who is financially dependent on independent research analyst or individual
    research analyst employed by research entity.
  5. e) “Research Analyst” means an Employee of ” BIGPROFITBUZZ.” who is primarily responsible for:
  6. Preparation or publication of the content of the research report or
  7. Providing research report or

iii. Making ‘buy/sell/hold’ recommendation or

  1. Giving Price target or
  2. Offering an opinion concerning public offer

– with respect to securities that are listed or to be listed in a stock exchange, whether or not any such person has the job title of ‘research analyst’ and includes any other entities
engaged in issuance of research report or research analysis. It also includes any associated person who reports directly or indirectly to such a research analyst in connection with
activities provided above.

  1. f) “Research Entity” means BIGPROFITBUZZ. or any other intermediary registered with SEBI who is / shall also engaged in Merchant Banking or Investment
    Banking or Brokerage Services or underwriting services and issue research report or research analysis in its own name through the individuals employed if any by it as research analyst and
    includes any other intermediary engaged in issuance of research report or research analysis.
  2. g) “Research Report” means any written or electronic communication that includes research analysis or research recommendation or an opinion concerning securities or public offer, providing a basis for investment decision and does not include the following communications :-
  3. Comments on general trends in the securities market
    ii. Discussions on the broad based indices
    iii. Commentaries on economic, political or market conditions
    iv. Periodic reports or other communications prepared for unit holders of mutual fund or alternative investment fund or clients of portfolio managers and investment advisers
    v. internal communications that are not given to current or prospective clients
    vi. Communications that constitute offer documents or prospectus that are circulated as per regulations made by the Board
    vii. Statistical summaries of financial data of the companies’
    viii. Technical analysis relating to the demand and supply in a sector or index
    ix. Any other communication which the Board may specify from time to time
  4. h) “Significant news or event” means any news or event which is expected to have a material impact on or that reflects a material change to, the subject company’s earnings, operations or financial condition, other than unpublished price sensitive information, as specified in the internal policies and procedure of the research analyst or research entity.

(i) “Subject Company” means the company whose securities are the subject of a research report or a public appearance.

(j) “Senior Management” shall mean and Proprietor of BIGPROFITBUZZ.

(k) “Third Party Research Report” means a research report produced by a person or entity other than Research Analysts of BIGPROFITBUZZ.

  1. Management of Conflict of Interest and Disclosure Requirements

BIGPROFITBUZZ. And its Research Analysts if any shall maintain arms-length relationship between its research activity and other activities.

  1. a) Limitations on trading by research analysts:
  • Personal trading activities of the individuals employed as research analysts are not entertained.
  • Research Analysts if employed by BIGPROFITBUZZ or their associates shall not
    (a) deal / trade in securities recommended /followed by the research analyst within 30 days before and five days after the publication of a research report;
    (b) deal / trade in securities that the research analyst reviews in a manner contrary to his given recommendation;
    (c) purchase or receive securities of the issuer before the issuer’s initial public offering, if the issuer is principally engaged in the same types of business as companies that
    the research analyst follows or recommends.
  • However, the above restrictions to trade/ deal in securities shall not be applicable in case of significant news or event concerning the subject company or based upon an
    unanticipated significant change in the personal financial circumstances of the research analyst, subject to prior written approval from
    proprietor of BIGPROFITBUZZ.
  • Further, all the research analysts If employed shall always adhered to the Conflict of interest Policy of the firm, developed and implemented by the company. This policy shall be
    read, understood and complied by all Research Analysts if any employed conjunction with the said Conflict of Interest Policy as may be prevalent from time to time.

[b] Compensation of Research Analysts:

  • The Research Analysts if any employed by BIGPROFITBUZZ. Shall not be entitled to any bonus, salary or other form of compensation that is based on
    specific brokerage services transactions.
  • Further, compensation of all research analysts shall be reviewed, documented and approved annually.
  • Such Research Analysts shall perform his/her/their duties independently.

[cl Limitation on Publication of Research Report, Public Appearance, Conduct of Business etc.

  • The Research Report issued by Research Analysts of BIGPROFITBUZZ. Shall be based on adequate documentary research evidence.
  • BIGPROFITBUZZ. and/or its Research Analysts if any shall not provide any promise or assurance of favourable review in research report to the Company or Industry as a consideration to
    commence or influence a business relationship of for the receipt of compensation or other benefits.
  • BIGPROFITBUZZ. Shall ensure that its Research Analysts if any are separate from other employees who are performing any other activity that may affect the independence of research report.
  • Research Analysts shall have adequate documentary basis, supported by research, for preparing a research report.

[d] Disclosures in Research Report

Research Analysts of BIGPROFITBUZZ. Who are engaged in research activity and preparing research report shall disclose all material information about himself or BIGPROFITBUZZ. including the following in its research reports:
• Business Activity
• Disciplinary History
• Terms and conditions on which it offers research report
• Details of Associates v. Details with respect to Ownership and Material Conflict of Interest such as :
(a) Whether BIGPROFITBUZZ. Or any Research Analysts or its/his associate or relatives has any financial interest in the subject company, if yes, together with nature of such financial interest
(b) whether BIGPROFITBUZZ. or any Research Analysts or its/his associate or relatives have actual / beneficial ownership of 1, % or more securities of subject company at the end of the month immediately preceding the date of publication of research report or date of public appearance, as the case may be.
(c) Details of actual / beneficial ownership of one percent or more securities of the subject company, at the end of month immediately preceding the date of publication the research report or date of public appearance
(d) Details of any material conflict of interest at the time of publication of research report or at the time of public appearance
(e) Details of any compensation received by BIGPROFITBUZZ. Or Research Analysts or its/his/her/their associates from the subject company in past 12 months.
(f) Details of whether BIGPROFITBUZZ. or its associates have managed or co-managed the public offering of subject company in past 12 months
(g) Details of whether BIGPROFITBUZZ. Or its associates have received any compensation for investment banking or merchant banking of brokerage services from the subject company in past 12 months

(h) Details of whether BIGPROFITBUZZ or its associates have received any compensation for products or services other than above from the subject company in past 12 months
(i) Details of any compensation or other benefits received BIGPROFITBUZZ or Research Analysts or its/his/her/their associates from the Subject Company or 3rd party in connection with the research report

  • BIGPROFITBUZZ. and / or its Research Analysts shall disclose in public appearance with regard to receipt of compensation (a) whether BIGPROFITBUZZ or Research Analysts or its/his/her/their associates have received any compensation from the subject company in past 12 months (b) whether the subject company is / was client of BIGPROFITBUZZ. During 12 months preceding the date of distribution of research report and the types of such services provided by BIGPROFITBUZZ
    • Whether the Research Analysts has served as an officer, director or employee of the subject company.
    • Whether BIGPROFITBUZZ. Or its Research Analysts has been engaged in market making activity of the subject company
    • such other disclosures in research reports / public appearance as specified by SEBI under any other regulations
    • Such Research Reports reflects the factual information about the subject company and are based on reliable information. Such reports also contain the definition of terms which are used in making recommendations and such terms have been used consistently.
    • lf such Research Reports contain either a rating or price target for at least 1 year, the same shall also provide for the graph of daily closing price of such securities for the period assigned or for a 3 year period, whichever is shorter.
    • Such Research Report Shall not be issued selectively to internal trading personnel or to a particular client or group of other clients in advance of other clients who are entitled to receive the research report.
    • In case of distribution of any 3’d party research report, Research Analysts of BIGPROFITBUZZ. Shall review such 3’d party report for any untrue statement of material fact or any false or misleading information, provided that BIGPROFITBUZZ. or its Research Analysts do not have any direct / indirect business or contractual relationship with such 3’d party research provider.
    • In case, any Research Analysts or proprietor or employee of BIGPROFITBUZZ. appears in public media and make any recommendation, the disclosure of his / its name, registration status and details of financial interest shall invariably made at the time of making such recommendation or offering any opinion in his personal capacity, responding to any queries of audience or journalists in personal capacity and communicating the research report or its substance through public media.
  1. Other conditions

    • Research Analysts if any of BIGPROFITBUZZ. Shall obtain NISM certification or such other certification for research analysts as specified by SEBI.
    • BIGPROFITBUZZ. And its Research Analysts If any shall maintain and preserve following records for a minimum period of 5 years:
    • Research Report duly signed and dated
    • Research recommendation provided
    • Rationale for arriving at research recommendation
    • Record of public appearance
    • Clients wishing to avail the research services from BIGPROFITBUZZ. Should mandatorily be required to visit online at www.bigprofitbuzz.com & must read disclaimer on the website accordingly.
    • The Compliance Officer of BIGPROFITBUZZ. Shall monitor and comply in this regard.
    • BIGPROFITBUZZ. Shall conduct annual audit in respect of compliance with the captioned SEBI Regulations from member of ICAI or ICSI.

    6. Review of the Policy

    The policy will be reviewed as and when considered necessary by the BIGPROFITBUZZ as per SEBI Guidelines.

CORRESPONDENCE AND CLARIFICATION
All correspondence and queries concerning this Policy be sent to the Compliance Officer,

Mr. JITENDER
Place: Faridabad

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