Code of Conduct


Responsibility of Management

The senior management of the research analyst firm bears the primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures.

Honesty and Good Faith

Research analysts must act with honesty and in good faith in all their business activities.

Compliance

Research analysts must comply with all regulatory requirements applicable to their business activities.

Conflict of Interest

Research analysts must address any conflict of interest that may affect the impartiality of their analysis or reports. Appropriate disclosures should be made to manage these conflicts.

Diligence

Research analysts must act with due skill, care, and diligence, ensuring that their reports are prepared after thorough and complete analysis.

Insider Trading or Front Running

Research analysts or their employees must not engage in insider trading or front-running of their own research reports.

Confidentiality

Research analysts and their employees must maintain confidentiality of reports until the report is made public.

Professional Standard

Research analysts and their employees must observe high professional standards when preparing research reports.
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