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Pursuant to Regulation 15(9) of the SEBI (Investment Advisers) Regulations, 2013
This Code of Ethics (“Code”) has been adopted by Pavan Kumar Manchiraju and is designed to comply with the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 [sub-regulation (9) of regulation 15].
This Code establishes rules of conduct for all employees of Pavan Kumar Manchiraju and is designed to govern personal securities trading activities in the accounts of employees, immediate family/household accounts, and accounts in which an employee has a beneficial interest. The Code is based upon the principle that both the Investment Adviser and its employees owe a fiduciary duty to clients to conduct their affairs in such a manner as to avoid:
The Code is designed to ensure that the high ethical standards long maintained by Pavan Kumar Manchiraju continue to be applied. The purpose of the Code is to preclude activities that may lead to or give the appearance of conflicts of interest, insider trading, or other forms of prohibited or unethical business conduct.
Pursuant to the SEBI (Investment Advisers) Regulations, both Pavan Kumar Manchiraju and his employees are prohibited from engaging in fraudulent, deceptive, or manipulative conduct. Compliance with this section involves more than acting with honesty and good faith alone — it requires an affirmative duty of utmost good faith to act solely in the best interests of clients.
In meeting fiduciary responsibilities, Pavan Kumar Manchiraju expects every employee to demonstrate the highest standards of ethical conduct as a condition of continued employment. Strict compliance with the provisions of the Code shall be considered a basic condition of employment.
Employees are urged to seek guidance from Pavan Kumar Manchiraju for any questions regarding the Code or its application. Material breaches of the Code may constitute grounds for disciplinary action, including termination of employment.
The provisions of the Code are not exhaustive; they serve as a guide for ethical behavior. In cases of uncertainty, employees should consult Pavan Kumar Manchiraju. Exceptions may only be granted when it is clear that the interests of clients will not be adversely affected.
An investment adviser shall act honestly, fairly, and in the best interests of its clients and uphold the integrity of the market.
An investment adviser shall act with due skill, care, and diligence in the best interests of its clients and ensure that advice is based on thorough analysis, considering all available alternatives.
An investment adviser shall have and effectively employ appropriate resources and procedures necessary for efficient business performance.
An investment adviser shall seek from clients information about their financial situation, investment experience, and investment objectives relevant to the services provided, while maintaining strict confidentiality of such information.
An investment adviser shall make adequate disclosures of all relevant and material information while dealing with clients to enable them to make informed decisions.
The investment adviser may charge fees to clients, subject to any ceiling specified by SEBI. Fees charged must always be fair, transparent, and reasonable.
The investment adviser shall endeavor to avoid conflicts of interest and, where unavoidable, ensure appropriate disclosures to clients and fair treatment of all parties involved.
The investment adviser and its representatives shall comply with all regulatory requirements applicable to their business to promote the best interests of clients and the integrity of the market.
The management of a proprietorship firm registered as an investment adviser shall bear primary responsibility for maintaining appropriate standards of conduct and adherence to proper procedures within the firm.
