Internal Policy — Vishwesh Diware (SEBI Registered Research Analyst)

This Internal Policy outlines the ethical framework, compliance structure, and operational standards followed by Vishwesh Diware, SEBI Registered Research Analyst, for the conduct of research and dissemination of market-related information. It is aligned with the SEBI (Research Analysts) Regulations, 2014, the Master Circular for Research Analysts (June 25, 2025), and applicable provisions of the Securities and Exchange Board of India Act, 1992.

1. Code of Conduct & Ethical Standards

• Research is carried out with independence and objectivity.
• No insider trading, front-running, or unfair trade practices are permitted.
• Confidential market information is used solely for research purposes and not for personal gain.
• All research analysts and associates adhere to the SEBI-mandated Code of Conduct.

2. Research Process & Methodology

• Research recommendations are based on price action, technical analysis, market volume, and institutional activity.
• All trade ideas are supported by objective data and defined stop-loss and targets.
• Before publication, every research idea is reviewed for accuracy, clarity, and compliance.
• No guarantees or assured returns are ever communicated to clients or subscribers.

3. Conflict of Interest Policy

• Any material conflict of interest (financial holdings, relationships, or positions) is identified, reviewed, and disclosed in the relevant research communication.
• Vishwesh Diware or his associates will not exploit unpublished or confidential information for personal benefit.
• A strict separation is maintained between research activity and any promotional or affiliate engagement.

4. Record Keeping & Data Management

• All research reports, trade notes, communications, and client interaction records are maintained for a minimum of 5 years, as required by SEBI.
• Research records are securely stored with access controls and backup systems.
• Data integrity and traceability are ensured through timestamped digital logs.

5. Compliance Monitoring

• Regular internal reviews are conducted to ensure adherence to SEBI regulations and this policy.
• Any suspected violation is escalated to the compliance officer and documented for review.
• Updates to SEBI circulars or regulatory amendments are promptly incorporated into internal workflows.

6. Information Security & Confidentiality

• Sensitive data and client information are stored in encrypted systems accessible only to authorized personnel.
• No personal or financial data is shared externally without explicit consent.
• All communication channels (email, WhatsApp, Telegram) follow privacy and access protection protocols.

7. Training & Awareness

• SEBI regulations and code of conduct
• Market ethics and compliance best practices
• Data privacy and research documentation standards

8. Whistleblower & Escalation Mechanism

• Employees or associates may report unethical behavior, regulatory breaches, or conflicts of interest directly to the compliance officer.
• Whistleblower confidentiality is maintained, and no retaliatory action is permitted.

9. Technology & Operational Controls

• Systems used for market analysis and report generation are secured by multi-level access control.
• All updates, backups, and data transfers follow established IT governance practices.
• Unauthorized access, copying, or modification of internal systems is strictly prohibited.

Policy Review & Amendments

• This policy is reviewed annually or whenever SEBI issues a relevant update.
• Any changes are approved by the compliance head and reflected on this page with the new effective date.
• The latest version of this policy shall always be available on the official website.

Statement of Integrity

“At Vishwesh Research, we uphold the highest standards of ethical research and compliance.”

“Every recommendation is backed by data, integrity, and a commitment to investor protection.”