KYC

INTERNAL POLICY & CONTROL PROCEDURE

Internal Policy & Control Procedure

Home / Internal policy & Control Procedure

Internal Policy & Control Procedure

FRAMED UNDER REGULATION 15 OF THE SEBI (RESEARCH ANALYSTS)

REGULATIONS, 2014 (AS AMENDED)

READ WITH THE SEBI MASTER CIRCULAR FOR RESEARCH ANALYSTS

DATED FEBRUARY 6, 2026

Name of Research Analyst Ravi Chouhan
Category Individual Research Analyst (Independent Research Analyst)
SEBI Registration Number INH000019451
BSE Enlistment Number (RAASB) 6482
Registered Office / Address 27 Rajendra Nagar, Agar Road, Ujjain, Madhya Pradesh, 456001
Mobile Number 9977888734
Email ID [email protected]

1. PREAMBLE

SEBI vide Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September, 2014 notified the SEBI (Research Analysts) Regulations, 2014 (“RA Regulations”), which came into force on 1st December, 2014 and have since been amended from time to time (consolidated up to November 2025). SEBI has also issued a Master Circular for Research Analysts dated 6th February, 2026 (“Master Circular”), consolidating all subsisting circulars applicable to research analysts into a single operative document.

In terms of Regulation 15 of the RA Regulations, every research analyst is required to have written internal policies and control procedures governing dealing and trading by the research analyst. Accordingly, Ravi Chouhan, Individual Research Analyst holding SEBI Registration No. INH000019451 and BSE (RAASB) Enlistment No.             6482 (“RA”), has framed this Internal Policy & Control Procedure with direct reference to, and in compliance with, the RA Regulations and the Master Circular referred to above.

This document shall be treated as a live compliance document and shall be reviewed and updated whenever SEBI amends the RA Regulations or revises/reissues the Master Circular.

2. OBJECTIVE:

  1. To establish proper internal control and procedures and to govern the dealing and trading by any research analyst.
  2. To address actual or potential conflict of interest arising from such dealings or trading of securities of Subject RA and promoting objective and reliable research that reflects the unbiased view of research analyst.
  3. Preventing the use of research report or research analysis to manipulate the securities market.
  4. To implement appropriate mechanisms to ensure independence of its research activities from its other business activities.
  5. To ensure compliance with SEBI rules and regulations, we being the Research Analyst registered under SEBI, is required to adopt and adhere such Research Analyst Regulation, subject to the following policies and procedures.

It is mandatory in terms of the Regulations for every Research Analyst to formulate a Code of Conduct. In order to comply with the mandatory requirements of the Regulations, it was necessary to formulate a specific Code of Conduct. Our policy is only to publish research report which is impartial, independent, clear, fair and not misleading. Such research may be produced and published only by the analysts working with the Ravi Chouhan and as per the regulations.

3. APPLICABILITY

This policy is applicable to all research analysts and associates, if any of the Ravi Chouhan– Research Analyst i.e. a 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 an 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’.

2. DEFINITIONS

  1. Act: the Securities and Exchange Board of India Act, 1992.
  2. Associate: an associate as defined in the SEBI (Intermediaries) Regulations, 2008.
  3. Independent Research Analyst: a person whose only business activity is research analysis or preparation/publication of research reports — the category under which the RA is registered.
  4. Master Circular: the SEBI Master Circular for Research Analysts dated 6th February, 2026, as amended from time to time.
  5. NISM: the National Institute of Securities Market.
  6. RAASB: the Research Analyst Administration and Supervisory Body, presently BSE Limited.
  7. Research analyst: a person primarily responsible for preparing/publishing research reports, providing research reports, making buy/sell/hold recommendations, giving price targets, or offering opinions on public offers concerning listed or to-be-listed securities, irrespective of job title (Regulation 2(1)(u)).
  8. Research report: any written or electronic communication containing research analysis, recommendation or opinion on securities/public offers that provides a basis for investment decisions, subject to the specific exclusions in Regulation 2(1)(w).
  9. SCORES: the SEBI Complaints Redress System (https://scores.sebi.gov.in).
  10. ODR / SmartODR: the Online Dispute Resolution platform for the securities market (https://smartodr.in).
  11. Subject company: the company whose securities are the subject of a research report or public appearance.
  12. Independent research analyst means a person whose only business activity is research analysis or preparation and/or publication of research report.
  13. 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 disclosures in the research report that are inaccurate, misleading or no longer applicable.
  14. Securities means securities as defined in clause (h) of section 2 of the Securities Contracts (Regulation) Act, 1956.
  15. 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: -
    1. comments on general trends in the securities market;
    2. discussions on the broad-based indices;
    3. commentaries on economic, political or market conditions;
    4. periodic reports or other communications prepared for unit holders of mutual fund or alternative investment fund or clients of portfolio managers and investment advisers;
    5. internal communications that are not given to current or prospective clients;
    6. communications that constitute offer documents or prospectus that are circulated as per regulations made by the Board;
    7. statistical summaries of financial data of the companies;
    8. technical analysis relating to the demand and supply in a sector or the index;
    9. any other communication which the Board may specify from time to time.

3. APPLICABILITY

This policy applies to Ravi Chouhan in his capacity as an Individual Research Analyst, and to any associate or person associated with his research services. The RA is registered and functions as an Independent Research Analyst and is not registered as a Part-Time Research Analyst.

4. DEPOSIT REQUIREMENT

The RA shall maintain a deposit, in the form of units of a liquid/overnight mutual fund or a deposit with a scheduled bank, based on the maximum number of clients serviced on any day of the preceding financial year:

No. of Clients (maximum on any day of the preceding financial year) Deposit to be maintained
Up to 150 clients ₹1,00,000 (₹1 lakh)
151 to 300 clients ₹2,00,000 (₹2 lakh)
301 to 1,000 clients ₹5,00,000 (₹5 lakh)
1,001 clients and above ₹10,00,000 (₹10 lakh)
  1. The deposit shall be marked as a lien in favour of RAASB in the manner specified by RAASB.
  2. The slab shall be reviewed annually and any top-up completed by 30th April of the subsequent financial year.
  3. The deposit secures amounts payable by the RA pursuant to ODR/arbitration proceedings in case of default.

5. QUALIFICATION AND CERTIFICATION


The minimum qualification for an individual RA is a graduate degree with the relevant NISM certification, or the NISM Post Graduate Program in Securities Market (Research Analysis). As an existing individual RA, the revised qualification criteria introduced by later amendments do not apply retrospectively; however, the RA shall continue to hold a valid, current NISM certification.

  1. The RA shall renew the applicable NISM certification within three years of the date of the registration certificate, or before expiry of the existing certificate, whichever is applicable, and shall retain evidence of each renewal.
  2. Any associate or person associated with the RA's research services shall obtain and maintain the relevant NISM certification within the timeline prescribed by SEBI/NISM.

6. CONFLICT OF INTEREST AND ARM'S-LENGTH SEPARATION


The RA shall maintain an arm's-length relationship between his research activity and any other business or professional activity. As the RA's only business activity is research analysis, this arm's-length distance position (the "Chinese Wall") is maintained by ensuring the RA does not undertake any other whole-time or executive professional/business activity that could interfere with, or create a conflict with, the independence and objectivity of his research.

In line with the general guidelines for dealing with conflicts of interest in the Master Circular, the RA shall:

  1. Identify, avoid and manage conflicts of interest and give primacy to client interest at all times;
  2. Disclose possible sources of conflict of interest, including any financial interest in a subject company, to clients and in every research report;
  3. Maintain information barriers to prevent improper flow of price-sensitive or confidential information;
  4. Not deal in securities of a company while handling any assignment or mandate involving that company;
  5. Not deal in securities while in possession of unpublished price sensitive information (UPSI), and not communicate UPSI to or on behalf of others;
  6. Not contribute, directly or indirectly, to manipulation of the demand, supply or price of securities;
  7. Not adopt any incentive structure that could encourage recommending products unsuited to a client's risk profile;
  8. Not misuse client information obtained through dealings for personal benefit;
  9. Periodically review, and document such review of, compliance with this conflict-of-interest framework.

7. RESTRICTIONS ON PERSONAL DEALING


  1. The RA's personal trading activity shall be monitored, recorded and, where necessary, subject to a documented self-approval process before dealing in any security covered by his research.[cite: 10]
  2. The RA shall not deal or trade in any security he recommends or follows within 30 days before, and within 5 days after, publication of a research report on the subject company.[cite: 10]
  3. The RA shall not deal or trade, directly or indirectly, in any security he reviews in a manner contrary to his outstanding recommendation.[cite: 10]
  4. The RA shall not purchase or receive securities of an issuer before that issuer's initial public offering where the issuer is principally engaged in the same type of business as companies the RA follows or recommends.[cite: 10]
  5. These restrictions do not apply where dealing follows a significant news or event concerning the subject company, or an unanticipated significant change in the RA's personal financial circumstances — provided the RA documents the basis for the exception in writing at the time of the transaction.[cite: 10]
  6. Before commencing research coverage of any listed company, the RA shall record his own shareholding/interest in that company and undertake in writing not to deal in its securities within 30 days Before to and 5 days after publication of the related research report or recommendation.[cite: 10]

8. RESTRICTIONS ON PUBLICATION AND PUBLIC APPEARANCE


The RA shall not publish or distribute a research report or research analysis, or make a public appearance, regarding a subject company within:[cite: 11]

  1. 40 days immediately following the day securities are priced, for an initial public offering;[cite: 11]
  2. 10 days immediately following the day securities are priced, for a further public offering;[cite: 11]
  3. 25 days from the date of the offering, where the RA has acted as underwriter of the issue.[cite: 11]
  4. Where the RA has acted as manager or co-manager of a public offering, he shall not publish/distribute a research report or make a public appearance concerning that company within 15 days before and 15 days after expiry, waiver or termination of any lock-up agreement restricting sale of securities held by the subject company post-offering.[cite: 11]
  5. The RA shall not participate in activities designed to solicit investment banking, merchant banking or brokerage business, such as sales pitches or deal road shows.[cite: 11]
  6. The RA shall have an adequate documentary basis, supported by research, for every research report published.[cite: 11]
  7. The RA shall not promise or assure a favourable review of any company/industry/sector as consideration for, or to influence, a business relationship or compensation.[cite: 11]
  8. The RA shall not issue a research report inconsistent with his own genuine view of the subject company.[cite: 11]

9. RESEARCH REPORT — CONTENT, RATINGS AND DISCLOSURES


9.1 Basis and Content

  1. Facts stated in research reports shall be based on reliable information, and terms used in recommendations shall be defined and applied consistently.
  2. Where a rating system is used, each rating shall be clearly defined, including the time horizon and benchmark on which it is based.
  3. Where a report carries a rating/price target that has been assigned to a security for at least one year, the report shall include a graph of the daily closing price for the period the rating has applied, or for three years, whichever is shorter.

9.2 Ownership and Conflict Disclosures

  1. Whether the RA/associate/relative has any financial interest in the subject company, and its nature;
  2. Whether the RA/associates/relatives hold 1% or more actual/beneficial ownership of the subject company's securities as at the end of the month preceding the report or appearance;
  3. Any other material conflict of interest at the time of publication/appearance.

9.3 Compensation Disclosures

  1. Compensation received from the subject company in the past 12 months;
  2. Whether the RA/associates managed or co-managed a public offering for the subject company in the past 12 months;
  3. Compensation for investment banking, merchant banking or brokerage services from the subject company in the past 12 months;
  4. Compensation for other products/services from the subject company in the past 12 months;
  5. Any other compensation/benefit received from the subject company or a third party connected with the research report;
  6. Whether the RA has served as an officer, director or employee of the subject company;
  7. Whether the RA has engaged in market-making activity for the subject company. When making a public appearance, the RA shall disclose his name, registration status and any financial interest in the subject company at the time of making the recommendation, responding to audience/journalist queries, or communicating the substance of the research report through public media.

10. DISTRIBUTION OF RESEARCH REPORTS


A research report shall not be made selectively available to any client or class of clients in advance of other entitled clients.[cite: 11]

  1. Any third-party research report distributed by the RA shall first be reviewed for untrue statements of material fact or false/misleading information.[cite: 11]

11. FEE, CLIENT CONSENT AND MINIMUM MANDATORY TERMS & CONDITIONS


The RA shall disclose the applicable terms and conditions to, and obtain consent from, every client before rendering any service or charging any fee, per the Minimum Mandatory Terms and Conditions (MITC) in Annexure B to the Master Circular:

  1. Fee charged to Individual and HUF clients shall not exceed ₹1,51,000 per annum per family of client (the cap does not apply to non-individual or accredited-investor clients), exclusive of statutory charges.
  2. Advance fee collection is limited to a maximum of one quarter at a time.
  3. Fees shall be collected only through banking channels (cheque, online transfer, UPI); cash collection is prohibited.
  4. Clients shall be encouraged, though not compelled, to use the optional Centralized Fee Collection Mechanism (CeFCoM) administered by BSE.
  5. Client consent shall record the RA's registration details, valid qualifications, a declaration that he is not engaged in any other whole-time/executive activity that could compromise research independence, the fee structure, and a statement that returns are not assured.
  6. On suspension exceeding 60 days or cancellation of registration, unexpired/residual fees already collected shall be refunded to the client pro-rata.
  7. Any change to voluntary/additional clauses in the client agreement requires at least 15 days' prior notice to the client.
  8. Updated terms/consent for existing clients shall be obtained on or before the renewal date, or next fee-collection date, whichever is earlier.
  9. The SEBI "Do's and Don'ts for investors dealing with Research Analysts" shall be brought to the notice of every client.

12. ADVERTISEMENT CODE


Any advertisement or promotional communication issued by the RA (pamphlets, brochures, email, SMS, social media, audio-visual content, or a promotional research report) shall comply with the following:

  1. State accurately and unambiguously the RA's registered name, office address and SEBI registration number; contain no false, misleading, biased or exaggerated claims, and no misleading testimonials.
  2. Carry the standard risk warning, minimum 10-point font: "Investment in securities market are subject to market risks. Read all the related documents carefully before investing," without alteration (audible equivalent for audio-visual media).
  3. Carry the standard disclaimer that SEBI registration, BSE enlistment and NISM certification do not guarantee performance or assure returns.
  4. Not promise or guarantee assured/risk-free returns; not use unverified past-performance or risk-return claims; not use superlative terms ("Best," "No. 1," "Leading") other than verifiable third-party awards; not discredit competitors; not display the SEBI logo.
  5. Not involve games, contests or leagues with prize money; advertisement copies shall be preserved for 5 years.
  6. Display the RA's name, SEBI registration number and grievance/compliance contact details on his website (if any), notice board, KYC forms and client agreements, together with the standard disclaimer.

13. KNOW YOUR CLIENT AND ANTI-MONEY LAUNDERING

The RA shall obtain and maintain KYC records for every fee-paying client through a SEBI-registered KYC Registration Agency (KRA), and shall comply with SEBI’s master circulars on KYC and on Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) applicable to securities market intermediaries, as updated from time to time. Records of all client and prospective-client interactions, from first contact through completion of service, shall be maintained, and any suspicious transaction shall be reported to the Financial Intelligence Unit (FIU-IND).

14. CYBERSECURITY AND CYBER RESILIENCE

The RA shall comply with the Cybersecurity and Cyber Resilience Framework (CSCRF) prescribed by SEBI, as applicable to his scale of operations, including reasonable data-protection, access-control and system-security measures for electronic client data and research records, and shall observe applicable timelines for cyber-audit, incident reporting and self-certification.

15. OUTSOURCING (CONDITIONAL)

Core research and compliance functions shall not be outsourced. Where any non-core, back-office or IT-support function is outsourced, the RA shall undertake a documented risk assessment, conduct due diligence on the vendor, execute a written contract addressing scope, liability, confidentiality, data security, business continuity and SEBI’s inspection rights, and shall at all times retain full responsibility and liability to clients and SEBI for the outsourced activity.

16. MAINTENANCE OF RECORDS


The RA shall maintain the following records, in physical or electronic form (digitally signed where required), for a minimum of five years, and longer where a dispute is pending or SEBI directs preservation:

  1. Research reports, duly signed and dated, with the recommendation and rationale for each;
  2. Records of public appearances;
  3. KYC records of fee-paying clients;
  4. A client register showing PAN, date and nature of research service, product/security involved, and fee charged/received;
  5. Records of all communications with clients and prospective clients, from first contact through completion of service;
  6. Terms and conditions disclosed to each client and the client's consent thereon.
  7. Any other record/s as per the regulations

17. ANNUAL AUDIT


  1. An annual compliance audit shall be conducted by a member of ICAI, ICSI or ICMAI.
  2. The audit shall be completed within 6 months of the financial year-end, and the report submitted to RAASB/SEBI within 1 month of the audit report date, and in any case not later than 31st October each year.
  3. The audit shall cover compliance with the record-maintenance requirements under Regulation 25(1) and, where applicable, the client-level segregation certification under Regulation 26C, to be personally approved by the RA.
  4. The status of the compliance audit report, and details of any adverse findings with corrective action, shall be published on the RA's website (if any) and made available to clients on request.
  5. The Research Analyst shall conduct an annual Digital Accessibility Audit of its website, mobile application and other digital platforms through an IAAP-certified accessibility professional or other suitably qualified expert to assess compliance with applicable accessibility standards, including WCAG guidelines. Any deficiencies identified during the audit shall be documented and rectified within a reasonable period.

18. COMPLIANCE FUNCTION

Regulation 26, which mandates appointment of a dedicated Compliance Officer, applies to a non-individual research analyst or research entity. As an Individual Research Analyst, Ravi Chouhan is not statutorily required to appoint a separate Compliance Officer; he personally performs the compliance function, monitoring adherence to the Act, the RA Regulations, the Master Circular and this policy; maintaining records of Code of Conduct adherence; and acting as the point of contact for SEBI/RAASB on compliance matters.

In terms of Regulation 26C, being an individual research analyst, the RA shall not provide distribution services, and no relative (as per definition in RA Regulations) of the RA shall provide distribution services to any client who receives research services from the RA.

19. INVESTOR CHARTER

The RA shall ensure compliance with the Investor Charter for Research Analysts specified by SEBI and shall bring it to clients’ notice by displaying it prominently at his office, publishing it on his website/app (if any), and providing it at client onboarding. The Charter sets out the RA’s vision and business activities, the services provided (including onboarding, disclosure of any AI-tool usage in research, confidentiality and data-privacy practices), the grievance mechanism described in relevant Clause and investors’ rights and responsibilities, including the Do’s and Don’ts for dealing with a Research Analyst.

20. REDRESSAL OF INVESTOR GRIEVANCES


The RA shall redress investor grievances not later than 21 calendar days from receipt, and, as a client-facing service standard under the MITC, shall endeavour to resolve grievances within 7 business working days before any escalation.

  1. The RA shall prominently display, at his office and on his website/app (if any), the Compliance officer’s contact name, email and phone number, the SCORES link (https://scores.sebi.gov.in), and the SEBI toll-free helpline numbers 1800 22 7575 / 1800 266 7575.
  2. Investors may lodge a complaint on SCORES, subject to a two-level review, first by RAASB, then by SEBI.
  3. If unresolved or unsatisfactory, the investor may proceed to the Online Dispute Resolution mechanism via the SmartODR portal (https://smartodr.in) for conciliation and, if required, arbitration.
  4. Physical complaints may be addressed to SEBI's Office of Investor Assistance and Education, SEBI Bhavan, Bandra-Kurla Complex, Mumbai or relevant regional office.

21. COMPLAINT DATA DISCLOSURE

By the 7th of every succeeding month, the RA shall publish on his website/app (if any): a monthly summary of complaints received (directly, via SCORES, and via other sources), resolved and pending, including complaints pending beyond three months and average resolution time; a trend of monthly complaint disposal; and a trend of annual complaint disposal each in the format prescribed in the relevant Circular.

22. PERIODIC REPORTING TO SEBI/RAASB


  1. A half-yearly periodic report for periods ending 30th September and 31st March shall be submitted within 30 days of each half-year end, in the format notified by RAASB.
  2. Where applicable, a half-yearly undertaking of compliance with SEBI's SaaS advisory for financial sector organisations shall be submitted.
  3. The annual compliance audit report, and details of adverse findings, shall be submitted per relevant Clause.

23. CHANGE IN CONTROL

Prior SEBI approval is required for any change in control of the RA. As the RA operates in an individual/proprietary capacity, transfer or bequest of the RA’s business to a legal heir or transferee constitutes a change in control, requiring the transferee to obtain prior SEBI approval (valid for 6 months, within which a fresh registration application must be filed) and a fresh certificate of registration. Any application shall be made online to RAASB/SEBI with the disclosures and declaration prescribed in the Master Circular, including confirmation that existing clients will be informed before the change takes effect and that the incoming person meets the Fit and Proper criteria under Schedule II to the SEBI (Intermediaries) Regulations, 2008.

24. CODE OF CONDUCT


  1. Honesty and Good Faith: The RA shall act honestly and in good faith.
  2. Diligence: The RA shall act with due skill, care and diligence, ensuring every research report is prepared after thorough analysis.
  3. Conflict of Interest: The RA shall effectively address conflicts of interest affecting the impartiality of his research, with appropriate disclosure.
  4. Insider Trading / Front-Running: The RA shall not engage in insider trading or front-running, including of his own research report.
  5. Confidentiality: The RA shall maintain confidentiality of a research report until it is made public.
  6. Professional Standards: The RA shall observe high professional standards in preparing research reports.
  7. Compliance: The RA shall comply with all regulatory requirements applicable to his research activities.
  8. Responsibility: The RA bears primary responsibility for maintaining appropriate standards of conduct and proper procedure, including obtaining prior SEBI approval for any change in control and furnishing SEBI/RAASB information and reports as specified from time to time.

In addition, the RA shall not accept remuneration or benefit from an issuer for publication of research; shall not offer or accept inducements for favourable research, including selective disclosure by an issuer of material non-public information; shall not offer favourable research, ratings or price targets as consideration for business or compensation; and shall not threaten to change research, a rating or price target as consideration for business or compensation.

25. REVIEW AND ADOPTION


This policy shall be reviewed periodically and updated whenever SEBI amends the RA Regulations or reissues/updates the Master Circular, with each material revision dated and recorded.

This Internal Policy & Control Procedure has been considered, adopted and implemented by Ravi Chouhan, SEBI Registered Individual Research Analyst (Reg. No. INH000019451, BSE/RAASB Enlistment No. 6482), with effect from 1st April, 2026.

Ravi Chouhan (Individual Research Analyst)
| SEBI Reg. No. INH000019451 | BSE Enlistment No. 6428
Don’t hesitate to contact us, we are here to help you in your trading journey.
Facebook Twitter Linkedin

Quick link

Useful Links

Contact