Internal Policy & Control Procedure


  1. Introduction and General Responsibilities

    This policy outlines the principles and procedures adhered to by RE2P Capital Partners (hereinafter referred to as "the Entity") to ensure compliance with the Securities and Exchange Board of India (Research Analysts) Regulations, 2014 (hereinafter referred to as "RA Regulations") and all other applicable SEBI Acts, circulars, and guidelines. The Entity is registered with SEBI as a Research Analyst. All research activities are conducted by employees designated as Research Analysts, who are integral to upholding these standards.

    The Entity and its employees shall at all times:
    • Act honestly and in good faith.
    • Act with due skill, care, and diligence.
    • Comply with all regulatory requirements applicable to its business activities.
    • Ensure that senior management bears primary responsibility for maintaining appropriate standards of conduct and adherence to proper procedures.
    • Abide by the provisions of the SEBI Act and the RA Regulations
    • Maintain a functional website containing specified details


  2. Qualification and Certification Requirements

    The Entity acknowledges its responsibility to ensure that its employees comply with all qualification and certification requirements under Regulation 7 of the RA Regulations
    • Individuals employed as Research Analysts (and partners, if any) shall, at all times, hold NISM certification for research analysts as specified by the Board or other recognized certification
    • Fresh certification must be obtained before the expiry of the validity of the existing certification to ensure continuity in compliance
    • Persons associated with research services must have a minimum qualification of a graduate degree in any discipline
    • The Entity ensures that its employees whose primary responsibility involves conducting research and rendering research-based recommendation are appropriately designated and qualified.


  3. Internal Policies and Procedures for Conflict of Interest Management


    The Entity shall maintain robust internal policies and procedures to manage conflicts of interest effectively and promote unbiased research.
    • Written internal policies and control procedures will govern the dealing and trading by any Research Analyst employee for:
      1. Addressing actual or potential conflicts of interest arising from dealings or trading of securities of subject companies
      2. Promoting objective and reliable research that reflects the unbiased view of the Research Analyst employee
      3. Preventing the use of research reports or analysis to manipulate the securities market
    • Appropriate mechanisms are in place to ensure the independence of its research activities from its other business activities The Entity shall maintain an arms-length relationship between its research activity and other activities
    • As a non-individual research analyst, the Entity shall provide research services through a separately identifiable department or division to maintain an arms-length relationship between research services and distribution activities
    • If registered as both an Investment Adviser (IA) and RA, an undertaking must be provided to maintain an arms-length relationship and clearly segregate investment advisory and research services
    • Client-level segregation is strictly enforced, meaning the same client cannot be offered both research and distribution services within the group. The Entity will not render research services to a client who is receiving distribution services from other family members


  4. Limitations on Trading by Research Analyst Employees


    The Entity imposes strict limitations on the personal trading activities of its Research Analyst employees to prevent conflicts of interest and market manipulation.
    • Personal trading activities of individuals employed as Research Analysts shall be monitored, recorded, and subject to a formal approval process
    • Research Analyst employees shall not deal or trade in securities that the research analyst recommends or follows within thirty days before and five days after the publication of a research report
    • Research Analyst employees shall not deal or trade directly or indirectly in securities that they review in a manner contrary to their given recommendation
    • Research Analyst employees shall not purchase or receive securities of the issuer before the issuer's initial public offering, if the issuer is principally engaged in the same types of business as companies that the research analyst follows or recommends
    • These trading restrictions also apply to the Entity unless it has segregated its research activities from all other activities and maintains an arms-length relationship
    • Exceptions to these restrictions may apply in cases of significant news or events concerning the subject company or based upon an unanticipated significant change in the personal financial circumstances of the Research Analyst, subject to prior written approval as per internal policies and procedures


  5. Disclosures and Content Standards for Research Reports and Public Appearances


    The Entity is committed to providing clear, accurate, and transparent information to its clients.
    • All research services provided by the Entity shall be corroborated by a research report containing the relevant data and analysis forming the basis for such research service. A "research report" includes any written or electronic communication that provides a basis for an investment decision, even SMS recommendations
    • All material information about the Entity shall be disclosed in research reports, including its business activity, disciplinary history, terms and conditions of offering research reports, and details of associates.
    • Disclosure of ownership and material conflicts of interest shall be made in research reports and during public appearances, including whether the Entity or its associates/relatives have any financial interest in the subject company or actual/beneficial ownership of one percent or more securities
    • The Entity will disclose any compensation received from the subject company
    • The Entity shall not provide any promise or assurance of a favorable review in its research reports to a company or industry as consideration to influence a business relationship or for compensation
    • Facts in research reports shall be based on reliable information, and terms used in recommendations shall be clearly defined and consistently used If a research report contains a rating or price target, a graph of the daily closing price for the period assigned or a three-year period (whichever is shorter) shall be provided.
    • When a Research Analyst employee or director makes a public appearance, they shall disclose their registration status and details of financial interest in the subject company
    • The Entity shall not make false, misleading, biased, or deceptive statements, or give any assurance or guarantee of returns in its advertisements or communications.
    • The Entity shall use the term ‘research analyst’ in all correspondences with its client.
    • The SEBI logo shall not be used.
    • A clear disclaimer that "Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors" shall be prominently displayed.


  6. Record Keeping and Annual Audit Requirements


    The Entity maintains meticulous records to ensure transparency and compliance.
    • The Entity shall maintain the following records for a minimum period of five years:
      ◦ Research reports duly signed and dated.
      ◦ Research recommendations provided
      ◦ Rationale for arriving at research recommendations
      ◦ Records of public appearances
    • All records, whether physical or electronic, shall be preserved for this minimum period
    • Where records are required to be duly signed and are maintained in electronic form, they shall be digitally signed
    • The Entity shall conduct an annual audit in respect of compliance with these regulations from a member of the Institute of Chartered Accountants of India or Institute of Company Secretaries of India or Institute of Cost Accountants of India.
    • The annual compliance audit shall be completed within six months from the end of each financial year.
    • A compliance audit report shall be submitted to the Research Analyst Administration and Supervisory Body (RAASB)/SEBI within one month from the date of the audit report, but no later than October 31st of each year for the previous financial year.
    • Any adverse findings of the audit, along with action taken, duly approved by the management, shall be submitted.
    • The status of the compliance audit report and any adverse findings with action taken shall be published on the Entity's website, and the compliance audit report shall be provided to its clients.
    • The Entity shall maintain records of interactions with all clients, including prospective clients, where any conversation related to its services has taken place. These records shall be in physical form or digitally signed electronic form. Digitally signed electronic records shall be preserved for a minimum period of five years.


  7. Client Engagement and Grievance Redressal


    The Entity is committed to transparent client engagement and timely grievance resolution.
    • The Entity shall disclose the terms and conditions of its research services to the client and obtain the client's consent on such terms and
    • No research service shall be rendered, nor any fee charged, until consent is received from the client on these terms and conditions. Consent can be obtained through a legally acceptable mode, including DigiLocker enabled Aadhaar-based e-signature facility.
    • The Entity shall redress investor grievances promptly, but not later than twenty-one calendar days from the date of receipt of the grievance
    • The Entity shall publish its Investor Charter and disclose the data on complaints received against it (or issues dealt by it) and their redressal on its website and mobile applications (if any), by the 7th of the succeeding month
    • Clients are advised that grievances can be lodged with SEBI via the SCORES platform or with the RAASB.
    • The Entity cannot execute or carry out any trade (purchase/sell transaction) on behalf of the client, and clients are advised not to permit the Entity to execute any trade on their behalf.


  8. Outsourcing Guidelines


    The Entity strictly adheres to guidelines on outsourcing of activities.
    • Core business activities and compliance functions shall not be outsourced
    • The Entity will ensure compliance with KYC (Know Your Client) requirements as per SEBI {KYC (Know Your Client) Registration Agency} Regulations, 2011 and guidelines issued thereunder.
    • The Entity shall not lend its registration/license to third parties.
    • The Entity shall not allow third parties to give recommendations on its behalf or share client details for activities it does not control or has not formally engaged for.
    • Written contracts/agreements shall be in place for any outsourced activities.


  9. Obligations on Inspection


    The Entity recognizes its duty to cooperate fully with SEBI during inspections.
    • It shall be the duty of the Entity and any other associate person in possession of relevant information to produce to the inspecting authority such books, accounts, and other documents in its custody or control, and furnish such statements and information as may be required for inspection purposes
    • It shall also be the duty of the Entity and any other associate person to give all such assistance and extend all such cooperation as may be required in connection with the inspection.
    • The Entity shall not conceal or destroy records, including electronic records.


  10. Deposit Requirement


    The Entity shall maintain a deposit as per SEBI regulations, based on the maximum number of clients in the previous financial year:
    • Up to 150 clients: ₹1 lakh
    • 151 to 300 clients: ₹2 lakh
    • 301 to 1,000 clients: ₹5 lakhs
    • 1,001 and above clients: ₹10 lakhs
    • The deposit shall be maintained with a scheduled bank, marked as lien in favor of the RAASB.


  11. Use of Artificial Intelligence (AI) Tools in Research Analyst Services


    If the Entity uses AI tools for servicing clients, it acknowledges specific responsibilities:
    The Entity shall be solely responsible for the security, confidentiality, and integrity of client data, the use of any other information or data for research services, research services based on the output of Artificial Intelligence tools, and compliance with any law for the time being in force

  12. Periodic Reporting


    The Entity will submit periodic reports to the RAASB/SEBI in the specified format, covering half-yearly periods ending on September 30 and March 31 of every financial year, within 30 days from the end of the respective half-yearly period.