Internal policy to effectively address conflict of interest
This policy is drafted to effectively address conflict of interest.
This policy is applicable to the proprietor and all the employees who are involved in research activities.
This policy is applicable only to trades in commodity derivatives.
The following are the details:
1. None of the employees and / or the proprietor will deal or trade in derivative contracts that the proprietor recommends or follow within 30 days before and 5 days after the publication of the research report / research recommendation.
2. If any employee wants to trade in any derivative contract, prior written approval of proprietor is necessary. The approval can be via email too.
3. The proprietor may approve the trade if the proprietor is not following or recommending the same to the clients.
4. The approval will be valid only for that day.
5. The proprietor and his employees will have proper documentation of the research and analysis at all times.
6. All information used for research and analysis will be from a reliable and authentic source. The research will not be biased due to any news which is not from authentic or reliable source.
7. If there is any material conflict of interest at the time of publishing the research analysis, adequate disclosures will be given to the clients about the same.
Disclosures as required under SEBI (Research Analyst) Regulations, 2014
I, Anand Kumar Modi, proprietor of M/s Tradecom Financial Services, am a Research Analyst registered with SEBI (Registration no INH100005640). I have experience of commodities markets for over 10 years now. My services will be provided through my website www.commodityalert.com/App and App/Sms/Email
I offer research products on various commodities like agricultural commodities, metal, bullion and energy. The research reports will be based on thorough research and information on weather and crop reports, domestic and international market data news on various commodities.
There is no disciplinary action which is / was running / initiated against me and there are no outstanding litigations against me.
General Terms and Conditions:
Click here to view the terms and conditions for research reports.
List of Associates
1. I am one of the directors and shareholders of Digital Mandi News Private Limited
2. I am one of the partners in partnership firm M/s Ashuram Basantlal
3. I have a proprietorship firm named M/s Shivshakti Traders
Note: Subject Company is a company on which buy / sell / hold recommendation or target price is given or changed in the research report.
Disclosure with regards to ownership and material conflicts of interest
1. Neither I nor my associates / relatives have any financial interest in the subject company.
2. Neither I nor my relatives / associates have actual/beneficial ownership of 1% or more in securities of the subject company, at the end of the month immediately preceding the date of publication of the document.
3. Neither I nor my relatives /associates have any other material conflict of interest at the time of publication of the document.
Disclosure with regards to receipt of compensation:
1. Neither I nor my associates / relatives have received any compensation from the subject company in the past 12 months.
2. Neither I nor my associates / relatives have managed or coR08;managed public offering of securities for the subject company in the past 12months.
3. Neither I nor my associates / relatives have received any compensation for investment banking or merchant banking or brokerage services from the subject company in the past 12 months.
4. Neither I nor my associates / relatives 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 12 months.
5. Neither I nor my associates / relatives have received any compensation or other benefits from the subject company or third party in connection with the document.
1. I have not served as an officer, director or employee of the subject company.
2. I am not engaged in market making activity for the subject company.
The information and views given by the research analyst is believed to be reliable but no responsibility or liability is accepted for error of facts and opinion and its accuracy and completeness cannot be guaranteed. The information provided herein should not be considered as an investment advice. The users should rely on their own research and analysis and should consult their own investment advisors to determine the merit, risks and suitability of recommendation. I, my team members, associates and employees will not be liable for any loss or liability incurred to the subscriber due to investments made or decisions taken based on the information provided in the reports or on the website.
Research Analyst may be trading in or having positions in the calls / recommendations given to the client. Investments in futures / physical commodities involve high risks and there is a possibility of you losing your money. Past performance is not a guarantee for future performance or future results
The information provided is based on the knowledge and information taking from physical commodity market. We are not responsible or liable for any information on this website or on sms, chat, app, msn, mail, web, failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure.
Copyright © Anand Modi, Proprietor of Tradecom Financial Services