1. Objective:

The purpose of this policy is to:

• Establish a structured approach for outsourcing by a SEBI-registered Research Analyst.
• Ensure that outsourced activities do not compromise regulatory obligations, data integrity, or business continuity.
• Outline controls to manage associated risks and ensure adherence to SEBI guidelines.

2. Applicability:

This policy applies to:

• All outsourcing arrangements entered into by the Research Analyst, including past and future engagements.
• • All departments and business functions engaging or proposing to engage third-party vendors for services related to RA operations.

3. Definition of Outsourcing:

Outsourcing refers to the use of a third party (whether affiliated or independent, within India or abroad) to perform activities associated with services offered by the Research Analyst, which the RA may otherwise perform internally.

Examples include:

• Data processing
• Back-office operations
• Client query handling (non-investment advisory)
• IT support or infrastructure
• Document digitization and storage