Raghunandan Money – Investment Khushiyon Ka.

Policy on Circulation of Unauthenticated News

Policy on

Code of Conduct &

Controls relating to

Unauthenticated News

Circulation

Objectives

To protect investors from and to stop unauthenticated news circulation by the Employees / Staffs or other dealing person of Raghunandan Capital Private Limited

Regulation

As per the code of conduct for Stock Broker in SEBI (Stock Brokers and Sub‐brokers) Regulations, 1992 and SEBI circular CIR/ISD/1/2011 dated March 23, 2011, all SEBI registered market intermediaries are required to have proper internal codes of conduct to obstruct the market  news  circulation  through  blogs/chat  forums/email  by  employees without adequate caution may cause considerable damage to the normal functioning and behavior of the market and distort the mechanisms thereof.

Therefore all the employees of Raghunandan Capital Private Limited should follow internal codes of conduct and controls.  Employees/staff etc.  working  in the  office  will  not  encourage  or circulate rumours or unverified information obtained from the client, industry and trade or any other sources without verification.

Implementation of code of Conduct

In this regard, Raghunandan Capital Private Limited implements the  codes  of  conduct  for  the various modes of communication. Company Directors/ Officers / Employees/ Staff etc.

are prohibited from:-

  1. Circulating rumors or unverified information obtained from clients, industry, any trade or any other sources without verification.
  • Circulation   of unauthenticated   news   related   to various   Scripts   in blogs/chat forums/e-mail, social networking sites etc.
  • Forwarding any market related news received in their official mail/personal mail/blog except after the same has been seen and approved by the Compliance Officer. All the reporting with regard to violation of the same shall be done to the designated Compliance Officer.
  • Circulation of rumors or unverified information obtained from client, industry, any trade or other sources without verification.
  • Access to Blogs/chat forums/messenger sites etc. has been restricted by   

    Raghunandan Capital Private Limited and is not allowed.

ACCESS CONTROL

There will be no access to chat forums/ Messenger sites to Employees/ staff excepts senior officials including Directors, Compliance Officer. All the logs of such sites shall be treated as records and are maintained by the IT deptt. Any information or market related news received by staff in official mail or their personal mail should be forwarded after seen and approved by the Compliance officer.

If an employee violated the provisions contained in SEBI Act/Rules/Regulations etc. and shall be liable for disciplinary action/ strict actions.

Where  the  Client  has  any  grievances,  he  should  promptly  notify  the  same  to  our Compliance   Officer   in  writing,   mentioning   sufficient   details   along   with  supporting documents to e-mail ID of the Compliance Officer   and the grievances email ID. The complaint shall be analyzed and redressed and replied to the client within 7 days/ sufficient time period from the date of the complaint with the resolution of the complaint.

For Raghunandan Capital Private Limited 

  Sd/- Director

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Policy on Circulation of Unauthenticated News

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