🛡️ Internal Policy & Governance Framework

Entity: TRUE TURTLES LLP

SEBI Research Analyst Registration No.: INH000023621

(Applicable to: Research Analyst, Employees, Directors, Partners, and Associates)

  1. 📘 Objective

This internal policy framework has been developed in compliance with the SEBI (Research Analyst) Regulations, 2014, to ensure that TRUE TURTLES LLP, its employees, directors, partners, and associates adhere to the highest standards of professional ethics, transparency, confidentiality, and regulatory compliance in the conduct of research advisory activities.

  1. ⚖️ Applicability

This internal policy is binding on:

(a) The SEBI-registered Research Analyst (individual/entity)

(b) Employees directly or indirectly involved in the research activity

(C) Directors and Partners

(d) Associated persons or entities that may influence or execute investment-related decisions or research inputs

  1. 🔒 Confidentiality & Data Security

(a) All client-related and market-sensitive information shall be handled with the strictest confidentiality.

(b) Employees, associates, or directors shall not disclose any non-public, proprietary, or personal data unless explicitly required by law or regulatory authority.

(c) Use of client information for personal investment gains or internal advantage is strictly prohibited.

  1. 📑 Compliance with Research Analyst Regulations

All employees and associates must:

(a) Comply with SEBI Research Analyst Regulations, 2014, and any amendments thereof.

(b) Refrain from providing unauthorized investment advice (beyond the scope of research).

(c) Disclose any material or financial interest in the securities mentioned in research.

(d) Avoid front-running, insider trading, or involvement in market manipulation practices.

(e) Follow the internal documentation process for research note issuance, review, and approvals.

  1. ⚠️ Conflict of Interest & Disclosure

(a) All personnel must disclose relationships or ownership in securities under coverage (direct or indirect).

(b) Anyone with 1% or more ownership in a subject company must declare and recuse themselves from the research process for that security.

(c) Associates should not accept incentive-based compensation tied to stock recommendations.

  1. 📚 Code of Conduct

All team members of TRUE TURTLES LLP must:

(a) Uphold integrity, professionalism, and independence in research activities.

(b) Avoid using research for promotional or marketing purposes unless specifically approved.

(c) Handle queries and interactions with investors in a truthful, fair, and balanced manner.

(d) Refrain from promising or guaranteeing investment returns, either explicitly or implicitly.

  1. 🔍 Research and Recommendation Controls

All research reports shall be:

(a) Prepared independently, with verifiable data sources.

(b) Accompanied by proper disclosures, rating rationale, and risk statements.

(c) Reviewed, approved, and archived by the compliance officer or designated authority before dissemination.

(d) Draft reports are confidential and not to be shared prior to release.

  1. 📈 Personal Trading Policy

Employees and insiders must:

(a) Restrict their own trading activities in securities under analysis (as per trading window restrictions).

(b) Report personal holdings and trades at regular intervals to the Principal Officer / Compliance team.

(c) Avoid acting on unpublished research or confidential client information.

  1. 📤 Dissemination of Recommendations

(a) All investment research shall be disseminated uniformly and publicly to all clients without any preferential access.

(b) Research must not be shared or influenced by portfolio management service (PMS), stockbroking, or investment advisory entities.

  1. 📝 Recordkeeping & Audit Trail

Maintain robust documentation and logs of:

(a) All published research reports

(b) Communications, disclosures, and conflict declarations

(c) Proof of dissemination / client receipt

(d) Audit trails for verification and regulatory queries

(e) Records are retained for a minimum of five years, or longer if under review or inquiry.

  1. 📢 Grievance Redressal Process

(a) Any complaint from clients, team members, or regulators will be addressed per the company’s Grievance Redressal Policy.

(b) Escalation matrix is clearly defined, with fallback to SEBI’s SCORES platform when unresolved.

  1. ⚙️ Policy Review

(a) The Internal Policy is reviewed annually or upon major changes in regulations/workflows.

(b) Any amendments shall be notified to all staff, and training shall be conducted as required.

  1. ✅ Declarations & Compliance

All current and new employees, directors, and associates of TRUE TURTLES LLP shall:

(a) Acknowledge and adhere to this policy in writing,

(b) Participate in mandatory trainings, and

(c) Always act in the best interest of investors, ensuring fairness and regulatory discipline.

This Internal Policy and Framework is in alignment with the applicable SEBI regulations, ensuring ethical, independent, and compliant functioning of the Research Analyst entity and its personnel.

  1. ✅ Independence of its research activities from its other business activities:

As a research analyst or research entity, we follow appropriate “Chinese Walls” and internal controls to ensure that our research activities remain independent of other business functions (such as investment banking, broking, proprietary trading, teaching, or sales and marketing).

❌ Termination Clause

Any employee, partner, associate, or director of TRUE TURTLES LLP (SEBI Reg. No.: INH000023621) who fails to acknowledge, adhere to, or comply with the Internal Policy and Framework will be subject to immediate termination of service or contractual relationship, without further notice.

Furthermore:

(a) In the event of any regulatory breach or violation resulting in penalties or sanctions imposed by SEBI or any other competent authority, the entire liability—including financial penalties or legal consequences—shall be borne solely by the individual responsible for the breach.

(b) TRUE TURTLES LLP shall not indemnify or be held accountable for such violations attributable to personal misconduct or negligence of its employees or associates.

All team members are expected to uphold the highest standards of compliance, ethics, and regulatory awareness at all times. Breach of any provision of the internal code, SEBI Research Analyst Regulations, or AML guidelines will invoke strict disciplinary action, including termination, blacklisting, and regulatory reporting wherever applicable.

📝 Contact Information & Grievance Redressal

For comprehensive and up-to-date details about our Principal Officer, Compliance Officer, and the process to raise any grievances, please visit the official website of TRUE TURTLES LLP:

🌐 www.trueturtles.in

What You’ll Find on Our Website:

(a) Principal Officer Details: Name, designation, contact information, and responsibilities regarding compliance and anti-money laundering measures.

(b) Compliance Officer Details: Contact information for addressing regulatory, investor protection, and operational compliance matters.

(c) Grievance Mechanism: Step-by-step instructions for submitting complaints, escalation procedures, contact points, and links to regulatory portals (such as SEBI SCORES and ODR platforms).

(d) Investor Support: Dedicated email and helpline numbers for prompt response.

(e) Additional Resources: FAQ, risk disclosures, and investor rights information.

For immediate assistance, always refer to the contact section of our website, where the latest information, including escalation contacts and service timelines, is available.

Your trust and confidence are important to us. We encourage you to reach out through our official channels if you need support regarding compliance or grievance issues.