Disclosures In Research Reports In Terms Of Securities And Exchange Board Of India (Research Analysts) Regulations, 2014

Disclosures In Research Reports:

1. "JA Research" or any of its associates or fellow research analysts shall disclose all material information about itself including its business activity, disciplinary history, the terms and conditions on which it offers research reports, details of associates, and such other information as is necessary to take an investment decision, including the following:
i. Whether "JA Research", its associates or fellow research analysts, or its associate or its relative has any financial interest in the subject company and the nature of such financial interest.
ii. Whether "JA Research", its associates or fellow research analysts, or its relatives, have actual/beneficial ownership of one percent or more securities of the subject company, at the end of the month immediately preceding the date of publication of the research report or date of the public appearance.
iii. Whether "JA Research", its associates or fellow research analysts or its associate or its relative, have any other material conflict of interest at the time of publication of the research report or at the time of public appearance.
iv. "JA Research" or any of its associates or fellow research analysts shall disclose the following in the research report and in public appearance with regard to ownership and material conflicts of interest.

2. "JA Research" or any of its associates or fellow research analysts shall disclose the following in the research report with regard to the receipt of compensation:
i. Whether "JA Research" or its associates have received any compensation from the subject company in the past twelve months MBA IN FINANCE AND MARKETING.
ii. Whether "JA Research" or its associates have managed or co-managed public offering of securities for the subject company in the past twelve months.
iii. Whether "JA Research" or its associates have received any compensation for investment banking or merchant banking or brokerage services from the subject company in the past twelve months.
iv. Whether "JA Research" or its associates have received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past twelve month.
v. Whether "JA Research" or its associates have received any compensation or other benefits from the Subject Company or third party in connection with the research report.

3. "JA Research" or any of its associates or fellow research analysts shall disclose the following in public appearance with regard to receipt of compensation.
i. Whether "JA Research" and its associates have received any compensation from the subject company in the past twelve months:
ii. Whether the subject company is or was a client during the twelve months preceding the date of distribution of the research report and the types of services provided: Provided "JA Research" or any of its associates or fellow research analysts shall not be required to make a disclosure as per sub-clauses (c), (d), and (e) of clause (ii) or sub-clauses (a) and (b) of clause regarding specific future investment banking or merchant banking or brokerage services transactions of the subject company.

4."JA Research" or any of its associates or fellow research analysts has served as an officer, director, or employee of the subject company.

5. Whether "JA Research" or any of its associates or fellow research analyst’s entity has been engaged in a market-making activity for the subject company.

6. Whether "JA Research" or any of it's associates or fellow research analysts shall provide all other disclosures in a research report and public appearance as specified by the Board under any regulations.

Contents Of The Research Report:

1."JA Research" or any of its associates or fellow research analysts shall take steps to ensure that facts in its research reports are based on reliable information and shall define the terms used in making recommendations, and these terms shall be consistently used.

2. "JA Research" or any of its associates or fellow research analysts that employs a rating system must clearly define the meaning of each such rating including the time horizon and benchmarks on which a rating is based.

3. Risk Disclosure - Investing in financial markets involves risks. Past performance is not indicative of future results. You should carefully consider your risk tolerance and financial situation before making any investment.

4. If a research report contains either a rating or price target for the subject.company’s securities and "JA Research" or any of its associates or fellow research analysts has assigned a rating or price target to the securities for at least one year, such research report shall also provide the graph of the daily closing price of such securities for the period assigned or for a three year period, whichever is shorter.

Recommendations In Public Media:

1. "JA Research" or any of its associates or fellow research analysts including the interest in the subject company if they make a public appearance.
2. If any person including a director or employee of "JA Research" or credit rating agency or asset management company or fund manager, makes a public appearance or makes a recommendation or offers an opinion concerning securities or public offers through public media, all the provisions of regulations 16 and 17 shall apply mutatis mutandis to him and he shall disclose his name, registration status and details of financial interest in the subject company at the time of:
a. Making such recommendation or offering such opinion in a personal capacity.
b. Responding to queries from audiences or journalists in a personal capacity.
c. Communicating the research report or substance of the research report through the public media.

Distribution Of Research Reports:

1. "JA Research"or any of its associates or fellow research analysts shall not make a client or class of clients in advance of other clients who are entitled to receive the research report.
2."JA Research" or any of its associates or fellow research analysts who distribute any third-party research report shall review the third-party research report for any untrue statement of a material fact or any false or misleading information.
3."JA Research" or any of its associates or fellow research analysts who distribute any third-party research report shall disclose any material conflict of interest of such third-party research provider or we shall provide a web address that directs a recipient to the relevant disclosures.
4. Provisions of sub-regulations (2) and (3) shall not apply to "JA Research" or any of its associates or fellow research analysts if we have no direct or indirect business or contractual relationship with such third-party research provider.

Additional Disclosures By The Proxy Adviser:

1. "JA Research" or any of its associates or fellow research analysts shall abide by all the provisions of Chapter II, III, IV, V, and VI mutatis mutandis in case they act as proxy advisers. Provided that its employees, when we acting as a proxy advisors, who are engaged in providing proxy advisory services shall be required to have a minimum qualification of being a graduate in any discipline: Provided further that certification requirements for its employees, when I or any of my associates or fellow research analysts act as proxy advisors, engaged in providing proxy advisory services shall be as specified by the Board: Provided further that the time period for compliance with capital adequacy as provided in sun-regulation (3) of regulation 8, for proxy advisors shall be three years.
2. "JA Research" or any of its associates or fellow research analysts acting as a proxy adviser shall additionally disclose the following:
a. The extent of research involved in a particular recommendation and the extent and/or effectiveness of its controls and procedures in ensuring the accuracy of issuer data.
b. Policies and procedures for interacting with issuers, informing issuers about the recommendations, and review of recommendations.
3. "JA Research" or any of its associates or fellow research analysts acting as Proxy advisers shall maintain the record of our voting recommendations and furnish the same to the Board on request.
4. In case of any inconsistency or difficulty in respect of the applicability of provisions of these regulations to "JA Research" or any of its associates or fellow research analysts acting as a Proxy adviser, the Board may issue such clarifications or exemptions as may be deemed appropriate.

General Responsibility:

1. "JA Research" or any of its associates or fellow research analysts shall maintain an arms-length relationship between its research activity and other activities.
2. "JA Research" or any of its associates or fellow research analysts shall abide by the Code of Conduct as specified in Third Schedule.
3. In case of change in my or any of its associates or fellow research analysts control, prior approval from the Board shall be taken.
4. "JA Research" or any of its associates or fellow research analysts shall furnish to the Board information and reports as may be specified by the Board from time to time.
5. "JA Research" shall be responsible to ensure that itself or any of its associates or fellow research analysts shall comply with the certification and qualification requirements under regulation 7 at all times.

Maintenance Of Records:

1. "JA Research" or any of its associates or fellow research analysts shall maintain the following records:
a. Research report duly signed and dated.
b. Research recommendation provided.
c. The rationale for arriving at research recommendation.
d. Record of public appearance.
2. All records shall be maintained either in physical or electronic form and preserved for a minimum period of five years: Provided that where records are required to be duly signed and are maintained in electronic form, such records shall be digitally signed.
3. "JA Research" or any of its associates or fellow research analysts shall conduct an annual audit in respect of compliance with these regulations from a member of the Institute of Chartered Accountants of India or the Institute of Company Secretaries of India.
4. "JA Research" or any of its associates or fellow research analysts which is a body corporate or limited liability partnership firm shall appoint a compliance officer who shall be responsible for monitoring the compliance of the provisions of the Act, these regulation and circulars issued by the Board.