Conflict of Interest Management

In terms of SEBI Circular CIR/MIRSD/5/2013 dated August 27, 2013 (General Guidelines for dealing with Conflicts of Interest of Intermediaries, Recognised Stock Exchanges, Recognised Clearing Corporations, Depositories and their Associated Persons in Securities Market) and the Code of Conduct prescribed under the SEBI (Stock Brokers) Regulations, 2026, CEBPL has laid down, with the active involvement of senior management, policies and internal procedures to identify, and to avoid or to deal with and manage, actual or potential conflicts of interest arising in the conduct of its business, and communicates these policies, procedures and the related code of conduct to all associated persons. CEBPL at all times maintains high standards of integrity in the conduct of its business, ensures fair treatment of its clients and does not discriminate amongst them, and endeavours to place the interest of its clients before its own interest.

Conflicts of interest may arise, inter alia: between proprietary trading of CEBPL or its group entities and the execution of client orders; between the research function and the broking / distribution businesses; from personal trading by employees, directors and their immediate relatives; from referral or incentive arrangements; from brokerage, commission or other compensation structures linked to particular products, segments or volumes; from transactions with, or services availed from, group companies; and from gifts, entertainment or other benefits offered by or to clients, vendors or counterparties. Business and functional heads are responsible for identifying such situations in their respective areas and reporting them to the Compliance Officer.

Identified conflicts are managed through: functional and physical segregation of departments, including the Chinese Wall and client-level segregation of research and distribution described in Section 27; priority of client orders over proprietary orders; pre-clearance and monitoring of personal trading by designated persons under CEBPL’s Insider Trading Policy; appropriate disclosure to clients of possible sources and potential areas of conflict of interest, including the disclosures in research reports under Section 31; the restrictions on referral arrangements set out in CEBPL’s Referral Policy; and controls over the giving and receiving of gifts and entertainment by associated persons. CEBPL does not deal in securities while in possession of material non-published information, does not circulate rumours or unverified information, and does not offer schemes of gifts, incentives or inducements to clients that are not permitted by SEBI or the exchanges.

Employees and associated persons are required to promptly report any actual or potential conflict of interest to the Compliance Officer, who maintains a record of the conflicts reported and the manner of their resolution. Where a conflict cannot be avoided or adequately managed through the measures above, the matter is escalated to senior management and, where material, to the Board, and CEBPL refrains from acting or makes appropriate disclosure to the affected client, as the circumstances require. No client is offered any advantage, or subjected to any disadvantage, on account of an undisclosed conflict.

Associated persons are educated on this framework as part of compliance training, and the adequacy of these conflict-of-interest policies and procedures is assessed periodically in line with the 2013 Guidelines, reviewed as part of the annual review of this policy under Section 40, and placed before the Board where material changes are required.