Internal Policy

Overview

This Internal Policy describes the internal controls, conduct standards, and conflict-of-interest management framework adopted by We Capitalize as a SEBI Registered Research Analyst. It applies to all research activities conducted under SEBI Registration No. INH000028981.

1. Independence of Research

Research recommendations published by We Capitalize are formed independently and objectively, based on publicly available information and our own analysis. The integrity of our research process is maintained at all times.

• Compensation received by the Research Analyst is not linked to specific recommendations or to a client's trading outcomes.
• Research reports are prepared without influence from any external party, including issuers of securities, brokers, or other intermediaries.
• Recommendations are based solely on publicly available market data, technical analysis, and independent assessment — not on undisclosed material information.
• No recommendation shall be made with the intent to benefit any particular client, associate, or third party at the expense of others.

2. Management of Conflicts of Interest

We Capitalize identifies, manages, and discloses conflicts of interest in accordance with the SEBI (Research Analysts) Regulations, 2014. The following principles govern our conflict-of-interest framework:

• We identify and, where relevant, disclose any conflict of interest associated with a research recommendation — including any financial interest held by the Research Analyst or associates in the recommended security.
• We do not deal in securities in a manner that is contrary to an outstanding recommendation in a way that disadvantages clients or creates unfair advantage for the Research Analyst.
• Any personal holdings that could affect the objectivity of research are managed and disclosed in line with the SEBI (Research Analysts) Regulations, 2014.
• Where a conflict of interest cannot be adequately managed or disclosed, the affected research or activity shall not be undertaken.
• Conflicts of interest disclosures are included in research reports as mandated by SEBI regulations and are updated whenever material changes occur.

3. Segregation of Activities

Where We Capitalize undertakes any activity other than research analysis, appropriate segregation and disclosure are maintained as required by SEBI regulations.

• Research activities are kept operationally separate from any other business or advisory activities to the extent required by the SEBI (Research Analysts) Regulations, 2014.
• The Research Analyst does not act as an Investment Adviser, Portfolio Manager, or Stockbroker, and does not provide services that overlap with or replicate those regulated categories.
• Any association with other SEBI-regulated entities is disclosed in our Disclosure Document in accordance with regulatory requirements.
• The Research Analyst is prohibited from executing or carrying out any purchase or sell transaction on behalf of any client, or from accepting client funds for investment under any circumstances.

4. Records & Documentation

We Capitalize maintains comprehensive records of all research activities and client interactions in accordance with the record-keeping requirements prescribed under SEBI regulations.

• Records of all research recommendations and the rationale supporting them are maintained for the period prescribed under the SEBI (Research Analysts) Regulations, 2014.
• Records of client communications — including interactions with prospective clients prior to onboarding where any conversation related to research services took place — are maintained as required by the SEBI Master Circular dated February 6, 2026.
• KYC records of fee-paying clients are maintained in the format and for the period prescribed under applicable SEBI regulations.
• Complaint records and their resolution status are maintained and reported in the monthly complaints data published on this website, updated by the 7th of every succeeding month.
• An annual audit of research activities and records is conducted as required under the Regulations. See our Audit Reports page for current audit status.

5. Confidentiality & Data Security

Client information shared with We Capitalize in the course of availing research services is treated as strictly confidential.

• Client information is protected by reasonable security measures against unauthorised access, disclosure, or misuse.
• Confidential client information will not be disclosed to third parties except where required by law, a regulatory obligation, or where the client has provided specific written consent.
• Research reports are maintained as confidential until they are published and made available to all subscribers simultaneously — without selective prior disclosure.
• Clients are advised not to share login credentials, demat account details, or trading account passwords with the Research Analyst or any representative of We Capitalize.

6. Training & Certification

We Capitalize maintains all certifications and qualifications required under the SEBI (Research Analysts) Regulations, 2014, and keeps abreast of regulatory developments to ensure ongoing compliance.

• The Research Analyst holds a valid NISM Series XV — Research Analyst Certification as required under the SEBI (Research Analysts) Regulations, 2014.
• Certification is renewed in accordance with the timelines prescribed by NISM and SEBI to ensure continued eligibility to act as a Registered Research Analyst.
• Regulatory updates — including SEBI circulars, master circulars, and RAASB communications — are monitored on an ongoing basis to ensure compliance practices remain current.
• All advertisements, disclosures, and client communications are reviewed against the applicable SEBI Advertisement Code and regulatory standards before publication.

7. Review

This Internal Policy is reviewed periodically — at least annually — and updated to reflect regulatory changes, SEBI circulars, and evolving best practice in the research analyst industry.

• Policy reviews are triggered by any material change in SEBI regulations, new master circulars, or significant changes to the scope of research activities conducted by We Capitalize.
• The most recent governing circular is the SEBI Master Circular for Research Analysts dated February 6, 2026 (Ref: HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026), which superseded the May 21, 2024 Master Circular.
• Any material update to this policy will be reflected in the “Last Updated” date shown on this page and communicated to subscribers where required by regulation.