Insider Trading Policy

Issued by: Equity Guru MS

SEBI Registration Number: INH000019497

Effective Date: 2 June 2025

Approved by: Manjushree Sharma

Compliance Officer: Deepak Singhal

Email: info.compliancebuzz@gmail.com

Contact: +91 90159 33164

Objective

This policy ensures strict compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015. It promotes transparency, fairness, and protection of investors from misuse of Unpublished Price Sensitive Information (UPSI).

Who Must Follow This Policy?

Applicable to:

• Proprietor / Partners / Directors of Equity Guru MS
• Employees, interns, contractors, and consultants
• Anyone with access to UPSI

Key Definitions

• Insider: Anyone with access to UPSI or a connected person
• UPSI: Non-public information that can impact stock prices, such as:
  • Financial results
  • Mergers/acquisitions
  • Dividend announcements
  • Leadership changes
  • Business deals
• Trading: Buying, selling, or dealing in securities

Key Guidelines

a) Prohibition on Insider Trading

• Insiders must not trade when in possession of UPSI
• UPSI must not be shared except for official duties or legal requirements

b) Restricted List

A list of stocks under analysis (Restricted List) will be maintained. No trades are allowed in these during the analysis period.

c) Chinese Wall Policy

• Research & trading teams operate independently
• UPSI is stored securely with restricted access
• No internal sharing of confidential recommendations

Trading Window Policy

• Closed Window: During UPSI-sensitive periods, trading is banned
• Open Window: Begins 48 hours after UPSI is publicly disclosed
• No trades are allowed during the closed window period

Pre-Clearance of Trades

• Trades above ₹2,00,000 require prior written approval from the Compliance Officer
• Approved trades must be executed within 7 days or re-approved

Mandatory Disclosures

• All connected persons must report holdings and trades
• Employee and family transactions must be disclosed in SEBI's prescribed format

Violations & Penalties

Violating this policy can lead to:

• Internal disciplinary action (including termination)
• Regulatory action by SEBI (monetary penalties, market bans, prosecution)

Policy Review

The policy will be reviewed and updated periodically in line with SEBI guidelines, with approval from the Compliance Officer.

Compliance Contact

Name: Deepak Singhal

Designation: Compliance Officer

Email: info.compliancebuzz@gmail.com

Phone: +91 90159 33164