INDIVIDUAL CODE OF CONDUCT

Code of Conduct for Research Analysts
Varun Bhargav, Proprietor of Profit X Research, being a SEBI Registered Research
Analyst under Registration Number INH000014508 dated 16 January, 2024, adheres
to the following Code of Conduct in accordance with Regulation 24(2) of the SEBI
(Research Analyst) Regulations, 2014:

1. Honesty and Integrity:
    I shall uphold the highest standards of honesty and integrity in all my
   activities and dealings.
2. Diligence and Thoroughness:
    I shall conduct research and analysis with diligence and thoroughness,
   ensuring that all reports are based on comprehensive analysis.
3. Conflict of Interest Management:
    I shall effectively manage any conflicts of interest that may arise,
   ensuring the impartiality and objectivity of research analysis and
   reports. Any conflicts of interest shall be disclosed appropriately.
4. Prevention of Insider Trading and Front Running:
    I shall refrain from engaging in any form of insider trading or front
   running based on information contained in my research reports.
5. Confidentiality and Data Protection:
    I shall maintain the confidentiality of research reports and any sensitive
   information until such reports are made public. Confidentiality
   protocols shall be strictly followed.
6. Adherence to Professional Standards:
    I shall adhere to high professional standards in the preparation and
   dissemination of research reports, ensuring accuracy, objectivity, and
   transparency.
7. Regulatory Compliance:
    I shall fully comply with all regulatory requirements applicable to my
   business activities as a research analyst, including but not limited to
   SEBI regulations and guidelines.
8. Responsibility of Management:
    As the proprietor of Profit X Research, I bear primary responsibility for
   ensuring that all members of the organization uphold these standards
   and adhere to proper procedures in conducting research activities.
   This Code of Conduct is designed to foster trust, integrity, and professionalism in the
   field of research analysis, thereby promoting investor confidence and market
   integrity