Insider Trading Policy
Money Bells Global Research Services Pvt Ltd
SEBI Registered Research Analyst (INH100009901)
GSTIN: 07AAPCM2093R1ZL
1. Purpose
This Insider Trading Policy (“Policy”) outlines the framework to prevent, detect, and report insider trading by employees, officers, and associates of Money Bells Global Research Services Pvt Ltd (“the Company”). It ensures compliance with SEBI regulations and promotes ethical behavior, transparency, and investor trust.
2. Scope and Applicability
This policy applies to:
- Directors and Key Managerial Personnel
- Research Analysts and Support Staff
- Consultants, Advisors, and Interns
- Designated Persons and their Immediate Relatives
3. No Investment Advice
- The Research Information provided should not be construed as investment, legal, accounting, or tax advice, or as an offer or solicitation to buy, sell, or hold any securities or financial products.
- Users must use their discretion and consult with their financial advisers before making any investment decisions.
4. Definitions
Insider: Anyone in possession of or having access to Unpublished Price Sensitive Information (UPSI).
UPSI includes non-public information likely to affect stock price, such as:
- Financial results
- Merger/acquisition plans
- Regulatory actions
- Key management changes
Designated Persons: Employees or associates likely to have access to UPSI by virtue of role or responsibilities.
5. Policy on Communication and Trading
- No Insider shall communicate or disclose UPSI unless for legitimate purposes or legal obligations.
- No Insider shall trade in securities while in possession of UPSI.
- Research Analysts must not:
- Trade in securities 30 days before and 5 days after report publication.
- Provide biased or misleading recommendations.
- Omit disclosure of conflict of interest.
6. Trading Window Framework
A restricted trading window will remain closed during key events like:
- Quarterly/Half-yearly/Annual financial result preparation
- Corporate announcements or regulatory actions
The window will reopen 48 hours after public disclosure of the UPSI.
7. Pre-Clearance of Trades
Designated Persons must:
- Seek prior approval for trades above ₹10 lakh
- Execute the trade within 7 working days of clearance
- Disclose trades post-execution
8. Maintenance of Chinese Walls
To safeguard UPSI:
- Separation between Research, Admin, and Sales Teams
- Information shared strictly on need-to-know basis
- Physical and electronic barriers to prevent leakage
9. Compliance Officer
Mr. Sagar Goel is appointed as the Compliance Officer, responsible for:
- Policy dissemination and updates
- Monitoring trades and compliance
- Maintaining insider records
- Reporting to SEBI where necessary
10. Penalties for Violation
Violation of this policy will attract:
- Disciplinary action (suspension, termination)
- Monetary fines
- Regulatory reporting and prosecution under SEBI Act, 1992
11. Recordkeeping
All pre-clearances, disclosures, and insider activity logs will be securely retained for a minimum of 5 years.
12. Training and Awareness
An annual compliance training will be held for Designated Persons to reinforce obligations under this policy and SEBI laws.
13. Policy Review
The Policy will be reviewed annually or upon any change in SEBI regulations. Amendments shall be approved by the Board of Directors.
Authorized By
Mr. Sagar Goel
Compliance Officer & SEBI Registered Research Analyst
Money Bells Global Research Services Pvt Ltd
sagargoel191991@gmail.com
