Disclosures, Conflict of Interest Policy & Regulatory Information

Standard Risk Disclosure

“Investments in securities markets are subject to market risks. Read all related documents carefully before investing.”

Registration granted by SEBI and certification from NISM do not guarantee performance or assure returns to investors.

1. About the Research Analyst

  • Name: Arjit Anand
  • SEBI Registration No.: INH000018072
  • Registered Address:
    HD-260, WeWork Embassy TechVillage
    Devarabisanahalli, Outer Ring Road
    Bellandur, Bengaluru – 560103

Iridium Capital operates as a SEBI-registered Research Analyst, providing research reports, investment views, and advisory insights.

2. Nature of Research Services

All research:

  • Is based on publicly available data, analysis, and assumptions
  • Reflects the analyst’s independent judgment at the time of publication
  • May change without prior notice

No research report or opinion should be construed as a guarantee of performance.

3. Limitations on Trading by Research Analyst

To prevent conflicts of interest, the Research Analyst shall not:

  • Trade in securities 30 days prior and 5 days after publication of research reports
  • Trade contrary to published recommendations
  • Invest in securities prior to IPO where a conflict may arise

Exceptions may apply in case of:

  • Significant market events
  • Unanticipated personal financial circumstances

4. Research Integrity & Conduct

The Research Analyst:

  • Ensures all reports are supported by adequate research and documentation
  • Does not provide favourable coverage in exchange for compensation or business relationships
  • Maintains independence, objectivity, and professional standards

Research is never selectively shared with specific clients before public release.

5. Mandatory Disclosures

Where applicable, the Research Analyst will disclose:

  • Financial interest in the subject company
  • Ownership of 1% or more in the subject company
  • Any material conflict of interest
  • Compensation received from the subject company (past 12 months)
  • Any investment banking, brokerage, or other service relationships
  • Any role as officer, employee, or director of the subject company
  • Market-making activity, if any

These disclosures will be made:

  • In research reports
  • During public appearances
  • At the time of recommendations

6. Public Appearances & Media

During any public communication (media, webinars, interviews):

  • The analyst will disclose name, registration status, and relevant interests
  • Opinions expressed are personal and based on available information

7. Record Keeping & Compliance

The Research Analyst maintains records for a minimum of 5 years, including:

  • Research recommendations
  • Supporting rationale
  • Records of public appearances

The Analyst:

  • Holds valid NISM certification
  • Conducts periodic compliance audits (via ICAI/ICSI professionals)
  • Notifies SEBI of any material changes in submitted information

Conflict of Interest Policy

1. Regulatory Background

This policy is framed in accordance with guidelines issued by the Securities and Exchange Board of India (SEBI) on managing conflicts of interest for market intermediaries.

2. Applicability

This policy applies to:

  • The Research Analyst
  • Any associated persons involved in research or advisory activities

3. Objective

The objective of this policy is to:

  • Identify potential conflicts of interest
  • Establish procedures to manage them
  • Ensure client interests are protected at all times

4. Key Principles

The Research Analyst shall:

  • Maintain high standards of integrity and fairness
  • Ensure client interest always takes priority
  • Avoid situations that create actual or perceived conflicts
  • Disclose any potential conflict transparently

5. Conflict Management Framework

To manage conflicts effectively, the Research Analyst:

  • Implements internal policies and procedures
  • Maintains independence in research and recommendations
  • Restricts inappropriate influence over research outcomes
  • Avoids misuse of confidential or unpublished information

6. Prohibited Activities

The Research Analyst shall not:

  • Trade using material non-public information
  • Share confidential client information for personal gain
  • Manipulate markets or influence security prices
  • Recommend products unsuitable for a client’s risk profile
  • Structure incentives that compromise objectivity

7. Information Barriers

Where applicable, appropriate safeguards are implemented to:

  • Prevent misuse of sensitive information
  • Restrict flow of information that may create conflicts

8. Fair Treatment of Clients

  • All clients are treated fairly and equitably
  • No preferential access to research or recommendations is provided

9. Disclosure of Conflicts

Where conflicts cannot be avoided, they will be:

  • Clearly disclosed
  • Explained in a transparent manner
  • Managed to ensure unbiased advice

10. Commitment to Compliance

The Research Analyst is committed to:

  • Full compliance with SEBI regulations
  • Ethical conduct in all advisory and research activities
  • Continuous monitoring and improvement of internal processes