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“Victory Terminal financial services as investment adviser” respects and values the right to Privacy of each and every individual. We are esteemed by the relationship and by becoming our clients you have a promise from our side that we shall remain loyal to all our clients and non clients whose information resides with us. This Privacy Policy of “Victory Terminal financial services as investment adviser” applies to the current clients as well as former clients.
Below are the word by word credentials of our Privacy Policy:
Your information whether public or private will not be sold, rented, exchanged, transferred or given to any company or individual for any reason without your consent for the same, all information which provide will keep confidential.
The only use we will be bringing to your information will be for providing the services to you for which you have subscribed to us for which you gave us your information.
Your information given to us represents your identity with us. If any changes are brought in any of the fields of which you have provided us the information, you shall bring it to our notice by either calling us or dropping a mail to us, then after we able to change.
In addition to the service provided to you your information (Mobile Number, E-Mail ID, whattsapp etc.) can be brought in use for sending you newsletters, survey, contest information, or information about any new services of the Company which will be for your own good and while subscribing for our services you agree that “Victory Terminal financial services as investment adviser” has the right to do so.
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This Code of Ethics (“Code”) has been adopted by Victory Terminal Financial Services and is designed to comply with 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 Victory Terminal Financial Services 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 Victory Terminal Financial Services and its employees owe a fiduciary duty to Victory Terminal Financial Services 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 with 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 Victory Terminal Financial Services 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 Victory Terminal Financial Services and its 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 means that the Victory Terminal Financial Services has an affirmative duty of utmost good faith to act solely in the best interest of its clients.
Victory Terminal Financial Services and its employees are subject to the following specific fiduciary obligations when dealing with clients:
The duty to have a reasonable, independent basis for the investment advice provided;
The duty to obtain best execution for a client’s transactions where the Firm is in a position to direct brokerage transactions for the client;
The duty to ensure that investment advice is suitable to meeting the client’s individual objectives, needs and circumstances; and
A duty to be loyal to clients.
In meeting its fiduciary responsibilities to its clients, Victory Terminal Financial Services expects every employee to demonstrate the highest standards of ethical conduct for continued employment with Victory Terminal Financial Services. Strict compliance with the provisions of the Code shall be considered a basic condition of employment with Victory Terminal Financial Services. Victory Terminal Financial Services 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 Vikram Singh Thakur, the 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 Victory Terminal Financial Services.
The provisions of the Code are not all-inclusive. Rather, they are intended as a guide for employees of Victory Terminal Financial Services 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 Vikram Singh Thakur. Vikram Singh Thakur may grant exceptions to certain provisions contained in the Code only in those situations when it is clear beyond dispute that the interests of our 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.
Code of Conduct for Investment Advisor
1. Honesty and fairness
An investment adviser shall act honestly, fairly and in the best interests of its clients and in the integrity of the market.
2. Diligence
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.
3. Capabilities
An investment adviser shall have and employ effectively appropriate resources and procedures which are needed for the efficient performance of its business activities.
4. Information about clients
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.
5. Information to its clients
An investment adviser shall make adequate disclosures of relevant material information while dealing with its clients.
6. Fair and reasonable charges
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 a fee charged to the clients is fair and reasonable.
7. Conflicts of interest
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.
8. Compliance
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.
9. Responsibility of senior management
The senior management of a body corporate which is registered as investment adviser shall bear primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures by the body corporate.
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