DISCLOSURE AND DISCLAIMER
Disclosure Policy
Neeraj Dewan
SEBI Registration No.: INH000014614
As a SEBI-registered Research Analyst, I, Neeraj Dewan, am committed to full transparency and regulatory compliance in the preparation and distribution of my research reports. The following disclosure policy is provided in accordance with SEBI (Research Analyst) Regulations, 2014, and other applicable guidelines.
General Statement
This website outlines the general policies related to disclosures. Specific and material disclosures, as required under SEBI regulations, will be provided within each individual research report.
Disclosures made in Research Reports
As applicable, each research report will include the following disclosures:
1. Ownership and Conflicts of Interest
• Whether I, Neeraj Dewan, or any of my associates or relatives have any financial interest in the subject company, and the nature of such interest.
• Whether I or any of my associates or relatives hold 1% or more of the securities (actual or beneficial ownership) of the subject company as of the end of the month preceding the date of publication or appearance.
• Any other material conflict of interest at the time of publication of the research report or during the public appearance.
2. Receipt of Compensation
The following disclosures will be included in the research report, where applicable:
• Whether I or my associates have received compensation from the subject company during the past 12 months.
• Whether I or my associates have managed or co-managed any public offering of securities for the subject company during the past 12 months.
• Whether I or my associates have received compensation for investment banking, merchant banking, or brokerage services from the subject company during the past 12 months.
• Whether I or my associates have received compensation for products or services other than those mentioned above from the subject company in the past 12 months.
• Whether I or my associates have received any compensation or other benefits from the subject company or any third party in connection with the research report.
Note: Disclosures under clauses 2(c), 2(d), and 2(e) of the research report, may be withheld if disclosure would reveal material non-public information related to specific potential future investment banking or related transactions.
3. Other Material Relationships and Roles
• Whether I have ever served as an officer, director, or employee of the subject company.
• Whether I have been engaged in market-making activities for the subject company.
4. Additional Regulatory Disclosures
• All other disclosures required under SEBI regulations or any other applicable law will be provided as necessary within the respective research report or during the public appearance.
Disclaimer:
If none of the above disclosures are applicable to a specific research report or public appearance, the report or appearance will clearly state that no material disclosures or conflicts exist.