This Code of Ethics (“Code”) has been adopted by Mehak Wealth Investment Advisors Pvt. Ltd 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 Mehak Wealth Investment Advisors Pvt. Ltd and is designed to, among other things, 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 Mehak Wealth Investment Advisors Pvt. Ltd and its employees owe a fiduciary duty to Mehak Wealth Investment Advisors Pvt. Ltd’s clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position within the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility.
The Code is designed to ensure that the high ethical standards long maintained by Mehak Wealth Investment Advisors Pvt. Ltd continue to be applied. The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. The excellent name and reputation of our firm continues to be a direct reflection of the conduct of each employee.
Pursuant to the Investment Advisers Regulation, both Mehak Wealth Investment Advisors Pvt. Ltd and its employees are prohibited from engaging in fraudulent, deceptive or manipulative conduct. Compliance with this section involves duty of utmost good faith to act solely in the best interests of its clients.
Mehak Wealth Investment Advisors Pvt. Ltd and its employees are subject to the following specific fiduciary obligations when dealing with clients:
In meeting its fiduciary responsibilities to its clients, Mehak Wealth Investment Advisors Pvt. Ltd expects every employee to demonstrate the highest standards of ethical conduct for continued employment with Mehak Wealth Investment Advisors Pvt. Ltd. Strict compliance with the provisions of the Code shall be considered a basic condition of employment with Mehak Wealth Investment Advisors Pvt. Ltd. Mehak Wealth Investment Advisors Pvt. Ltd’s reputation for fair and honest dealing with its clients has taken considerable time to build. This standing could be seriously damaged as the result of even a single securities transaction being considered questionable in light of the fiduciary duty owed to our clients.
Employees are urged to seek the advice of Mr. Rajan Malhotra , Investment Advisor, for any questions about the Code or the application of the Code to their individual circumstances. Employees should also understand that a material breach of the provisions of the Code may constitute grounds for disciplinary action, including termination of employment with Mehak Wealth Investment Advisors Pvt. Ltd.
The provisions of the Code are not all-inclusive. Rather, they are intended as a guide for employees of Mehak Wealth Investment Advisors Pvt. Ltd in their conduct. In those situations where an employee may be uncertain as to the intent or purpose of the Code, he / she is advised to consult with Sonam Srivastava. Sonam Srivastava may grant exceptions to certain provisions contained in the Code only in those situations when it is clear beyond dispute that the interests of clients will not be adversely affected or compromised. All questions arising in connection with personal securities trading should be resolved in favor of the client even at the expense of the interests of employees.
An investment adviser shall act honestly, fairly and in the best interests of its clients and in the integrity of the market.
An investment adviser shall act with due skill, care and diligence in the best interests of its clients and shall ensure that its advice is offered after thorough analysis and taking into account available alternatives.
An investment adviser shall have and employ effectively appropriate resources and procedures which are needed for the efficient performance of its business activities.
An investment adviser shall seek from its clients information about their financial situation, investment experience and investment objectives relevant to the services to be provided and maintain confidentiality of such information.
An investment adviser shall make adequate disclosures of relevant material information while dealing with its clients.
An investment adviser advising a client may charge fees, subject to any ceiling as may be specified by the Board, if any. The investment adviser shall ensure that fees charged to the clients are fair and reasonable.
An investment adviser shall try to avoid conflicts of interest as far as possible and when they cannot be avoided, it shall ensure that appropriate disclosures are made to the clients and that the clients are fairly treated.
An investment adviser including its representative(s) shall comply with all regulatory requirements applicable to the conduct of its business activities so as to promote the best interests of clients and the integrity of the market.
The senior management of a body corporate which is registered as an investment adviser shall bear primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures by the body corporate.