Code of Conduct

Honesty and Good Faith: Research analysts must act with honesty and good faith at all times.

1. Responsibility of Management: Senior management is primarily responsible for upholding high standards of conduct and ensuring adherence to proper procedures within the research analyst’s operations.

2.Conflict of Interest: Research analysts must effectively manage any conflicts of interest that could impact the impartiality of their analysis and reports. They must also provide appropriate disclosures to address these conflicts.

3.Insider Trading and Front Running: Research analysts and their employees are prohibited from engaging in insider trading or front running, including the exploitation of their own research reports.

4.Compliance: Research analysts must comply with all applicable regulatory requirements related to their business activities.

5.Confidentiality: Research analysts and their employees must maintain the confidentiality of reports until they are publicly released.

6.Professional Standards: Research analysts and their employees should adhere to high professional standards in the preparation of research reports.Diligence: Research analysts must act with due skill, care, and diligence, ensuring that research reports are prepared following thorough analysis.