Code of Conduct – Securities Dealing Procedures

In 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

The Securities and Exchange Board of India (SEBI), through Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1st September 2014, introduced the SEBI (Research Analysts) Regulations, 2014. These regulations are designed to foster transparency in security research and provide investors with reliable, actionable information to make informed investment decisions.

This Code of Conduct outlines the securities dealing procedures established by Stoic Wealth to ensure full adherence to these regulatory standards.

2. Applicability

This policy applies to the entire Stoic Wealth team, including all Research Analysts and support staff who are responsible for:

  • Preparing or publishing the content of research reports.

  • Providing research reports or advisory updates to clients.

  • Making ‘buy, sell, hold’ recommendations.

  • Assigning price targets or offering opinions on securities listed or to be listed on a stock exchange.

3. Code of Conduct for Stoic Wealth Analysts

To maintain the highest level of integrity, our team adheres to the following principles:

  • Honesty and Good Faith: We act with complete honesty and in good faith in all professional dealings.

  • Diligence: We exercise due skill, care, and diligence, ensuring that all research reports and recommendations are based on thorough, evidence-based analysis.

  • Conflict of Interest: We actively identify and address conflicts of interest that may impact the impartiality of our research and make proactive disclosures to mitigate such conflicts.

  • Prohibition of Insider Trading/Front Running: We strictly prohibit any form of insider trading or front-running, including the front-running of our own research reports or recommendations.

  • Confidentiality: We maintain strict confidentiality regarding all research reports and recommendations until they are formally published or disseminated to our respective clients.

  • Professional Standards: We uphold high professional standards in our analytical processes and in the preparation of all investment-related content.

  • Compliance: We are committed to complying with all regulatory requirements applicable to our business activities at all times.

4. Insider Dealing & Front-Running Policy

We maintain a zero-tolerance policy regarding the misuse of non-public information.

  • Insider Dealing: No member of the Stoic Wealth team who is in possession of inside information may trade, make recommendations, or publish research concerning the financial instruments to which that information pertains.

  • No Front-Running: Front-running is strictly prohibited. This includes:

    • Utilizing Client Order Information: Taking advantage of advance knowledge regarding pending client orders.

    • Utilizing Research Timing: Using knowledge about the content or imminent publication of research to trade for personal benefit prior to the information being made available to clients.

This Code of Conduct serves as the governing framework for our operations. By adhering to these standards, we ensure that the trust placed in Stoic Wealth by our clients remains protected and that our research services remain objective, transparent, and compliant.