Code of Conduct

Statement of General Policy

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:

• Serving their own personal interests ahead of clients,
• Taking inappropriate advantage of their position with the firm, and
• Any actual or potential conflicts of interest or abuse of their position of trust.

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.

Fiduciary Obligations When Dealing with Clients

• The duty to have a reasonable, independent basis for investment advice provided;
• The duty to ensure that investment advice is suitable for meeting the client’s individual objectives, needs, and circumstances;
• A duty to be loyal to 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.

Code of Conduct for Investment Adviser