Disclosure.

A. History, present business and background

Kavi Kambarajan is the research practice of Kavi Kambarajan, registered with SEBI as a Research Analyst under registration number INH000029944. The practice provides independent equity research services — preparation and publication of research reports, buy / sell / hold recommendations, price and stop-loss targets, and opinions concerning public offers — under the SEBI (Research Analyst) Regulations, 2014.

No other business activity is carried on that would influence the independence of research.

B. Terms and conditions of research services

The terms on which research services are offered, including the scope of the service, fees and the limits of the engagement, are published in full on the Terms and Conditions page and should be read before subscribing.

C. Disciplinary history

There are no penalties, directions, strictures or pending proceedings imposed on or initiated against the research analyst by SEBI, any stock exchange or any other regulatory or statutory authority in connection with research or securities-market activity.

D. Details of associates

The research analyst has no associates as defined under the SEBI (Research Analyst) Regulations, 2014. Should any associate relationship arise, it will be disclosed here and in the relevant research reports.

E. Ownership and material conflicts of interest

In every research report and public appearance, the research analyst discloses:

• whether the research analyst, any associate or any relative has a financial interest in the subject company, and the nature of that interest;
• whether the research analyst, any associate or any relative holds actual or beneficial ownership of one per cent or more of the securities of the subject company, as at the end of the month immediately preceding the date of publication of the report or the date of the public appearance;
• whether the research analyst, any associate or any relative has any other material conflict of interest at the time of publication or public appearance.

F. Receipt of compensation

In every research report the research analyst discloses whether the analyst or any associate has, in the past twelve months:

• received any compensation from the subject company;
• managed or co-managed a public offering of securities for the subject company;
• received compensation for investment banking, merchant banking or brokerage services from the subject company;
• received compensation for products or services other than investment banking, merchant banking or brokerage services from the subject company;
• received any compensation or other benefit from the subject company or a third party in connection with the research report.

All revenue of the practice is derived from client subscription fees charged in accordance with SEBI regulations. No monetary or non-monetary incentive, gift or benefit is accepted from any company or third party in exchange for favourable research coverage.

G. Other disclosures

• Whether the research analyst has served as an officer, director or employee of the subject company is disclosed in each report.
• Whether the research analyst has been engaged in market-making activity for the subject company is disclosed in each report.
• Whether the subject company was a client during the twelve months preceding distribution of the report, and the types of services provided, is disclosed in each report.
• All other disclosures specified by SEBI under any other regulation are provided in the research report and in public appearances.

H. Conflict-of-interest policy

The practice maintains a written policy to identify, prevent, manage and disclose conflicts of interest. Its principal controls are:

• Personal trading. Personal holdings and transactions are recorded and periodically updated. Defined cooling-off periods restrict trading in a security before and after a recommendation on it is issued. Front-running, insider trading and the misuse of unpublished price-sensitive information are strictly prohibited.
• Independence of research. Research is based solely on independent analysis, professional judgement and publicly available information. No influence is accepted from issuers, intermediaries, clients or third parties, and recommendations are never altered for commercial reasons.
• Compensation. Revenue comes only from legitimate client fees. No benefit is accepted from a covered company.
• Disclosure. Any financial interest, relationship with a subject company or other potential conflict is disclosed clearly and prominently in the research report.
• Records and review. Records of reports, recommendations, communications and personal trading are preserved for the period specified under SEBI regulations and are available for regulatory inspection. The policy is reviewed periodically and any breach is documented and corrected.