Code of Conduct – Securities Dealing Procedures

Regulatory Compliance Framework: Formulated in strict compliance with the SEBI (Research Analysts) Regulations, 2014.

  • Entity Name: Stoic Wealth

  • SEBI Registration Number: INH000022224

  • Registered Office: A-101, 45 Paramount, Lalit Estate, Baner, Pune, Maharashtra, 411045

1. Introduction

  • 1.1. Regulatory Genesis: The Securities and Exchange Board of India (SEBI), via Notification No. LAD-NRO/GN/2014-15/07/1414 dated September 1, 2014, enacted the SEBI (Research Analysts) Regulations, 2014.

  • 1.2. Purpose: These regulations mandatorily require individual intermediaries and firms to foster complete structural transparency in security research, ensuring investors receive reliable, conflict-free, and actionable information.

  • 1.3. Corporate Mandate: This internal Code of Conduct outlines the specific securities dealing procedures established by Stoic Wealth to govern employee actions and ensure complete adherence to these statutory standards.

2. Applicability

This policy applies universally to the entire Stoic Wealth team, including all core Research Analysts, associated market experts, and operational support staff who are involved in or responsible for:

  • 2.1. Preparing, reviewing, editing, or publishing the content of official research reports.

  • 2.2. Providing direct research reports or real-time advisory updates to clients.

  • 2.3. Making directional ‘buy’, ‘sell’, or ‘hold’ recommendations on public securities.

  • 2.4. Assigning target prices or offering formal opinions on securities currently listed, or scheduled to be listed, on recognized stock exchanges.

3. Code of Conduct for Stoic Wealth Analysts

To maintain uncompromised market integrity, all covered personnel must actively adhere to the following core principles:

  • 3.1. Honesty and Good Faith: Act with absolute honesty, integrity, and utmost good faith in every professional, client, and market interaction.

  • 3.2. Professional Diligence: Exercise high levels of skill, care, and diligence, ensuring all published research and recommendations are backed by thorough, data-driven, and evidence-based analysis.

  • 3.3. Conflict of Interest Mitigation: Actively identify, document, and isolate conflicts of interest that could potentially impair the impartiality of the firm’s research, providing proactive disclosures to clients wherever necessary.

  • 3.4. Absolute Trading Prohibitions: Strictly avoid any form of insider trading, market manipulation, or front-running—including the front-running of the firm’s own upcoming research publications.

  • 3.5. Information Security & Confidentiality: Maintain absolute internal confidentiality regarding the contents of all research reports and recommendations until they are formally published and uniformly disseminated to entitled clients.

  • 3.6. Professional Standards: Uphold peak institutional standards throughout the analytical lifecycle and within all prepared investment content.

  • 3.7. Continuous Compliance: Maintain a real-time understanding of and complete compliance with all prevailing regulatory frameworks governing the research analyst domain.

4. Insider Dealing & Front-Running Policy

⛔ Zero-Tolerance Warning: Stoic Wealth enforces a strict, zero-tolerance policy concerning the misuse of non-public, price-sensitive information or advance knowledge of research schedules.

  • 4.1. Insider Dealing Restrictions: No member of the Stoic Wealth team who is in possession of unpublished price-sensitive information (UPSI) or inside corporate information may trade, execute transactions, make parallel recommendations, or publish research concerning the financial instruments to which that information pertains.

  • 4.2. Prohibition of Front-Running: Front-running is an absolute compliance violation. Covered personnel are strictly prohibited from:

    • 4.2.1. Utilizing Client Order Information: Taking personal or speculative advantage of advance knowledge regarding pending, large-scale client orders.

    • 4.2.2. Utilizing Research Release Timing: Using advance knowledge of the content, direction, or imminent publication timing of an upcoming Stoic Wealth research report to execute personal trades prior to the information being made accessible to our clients.

5. Governance and Enforcement

  • 5.1. Binding Agreement: This Code of Conduct serves as the core operational and ethical framework for Stoic Wealth.

  • 5.2. Trust Protection: By strictly adhering to these documented procedures, the firm ensures that client trust remains fully protected and that all public research services remain thoroughly objective, legally compliant, and transparent.