Research Disclaimer and Disclosure inter-alia as required under Securities and Exchange Board of India (Research Analysts) Regulations, 2014

• RELIGARE BROKING LIMITED (“RBL”) (“Research Entity”) is into the business of Stock Broking, Depository Participant, Mutual Fund Distributor, Corporate Agent for insurance distribution and Sub-Syndicate for public issue of securities.
• Disclaimer: This report/analysis / call / score card (by whatever name called) (hereinafter collectively "Research") has been prepared/ made pursuant to Research made by the Research Analysts is neither a solicitation nor a recommendation to buy/sell any security (as defined under section 2(h) of Securities Contracts (Regulation) Act, 1956). It does not take into account the particular investment objectives, financial situations, or needs of individual recipients and other issues (prohibitions to investments due to law / jurisdiction issues etc.) which may exist for certain persons. Recipients should rely on their own investigations and take their own professional advice before investment. RBL and its associates, subsidiaries and associated companies, their directors and employees and/or its associates (hereinafter referred as Religare) will not treat recipients as customers/ clients by virtue of their receiving this report. This Research may have been prepared/ made based on the analysis of data available publicly and/or other sources believed to be reliable. Religare, does not, accepts any liability arising from the use of this information.
  
  The user assumes the entire risk of any use made of this report/ analysis/ call. Price and value of the securities referred to in this Research call may go up or down. Past performance is not a guide for future performance. Research based on technical analysis centers on studying charts of price movement and trading volume, as opposed to focusing on fundamentals and as such, may not match with Research based on fundamentals.
  
  Opinions expressed are our current opinions as of the date appearing on this Research only. We do not undertake to advise you as to any change of our views expressed in this Research. Research reports / recommendations may differ between RBL’s RAs and/or RBL’s associate companies on account of differences in research methodology, personal judgment and difference in time horizons for which recommendations are made. User should keep this risk in mind and not hold RBL , its employees and associates responsible for any losses, damages of any type what so ever. or
  
  RBL and its associates or employees may: (a) from time to time, have long or short positions in, and buy or sell the investments in / securities of company (ies) mentioned herein or (b) be engaged in any other transaction involving such investments / securities and earn brokerage or other compensation or act as a market maker in the financial instruments of the company (ies) discussed herein or act as advisor or lender / borrower to such company (ies) these and other activities of RBL and its associates or employees may be construed as potential conflict of interest with respect to any recommendation and related information and opinions. Without limiting any of the foregoing, in no event shall RBL and its associates or employees or any third party involved in, or related to, computing or compiling the information have any liability for any damages of any kind.
  
• Disciplinary History in brief - Following proceedings were initiated against RBL by Securities and Exchange Board of India (“SEBI”).
  • SEBI in the matters of IFSL Limited, Mega Corporation Limited, Karuna Cables Limited and Millenium Cybertech Limited, issued ad interim orders pursuant to the said orders, the SEBI had restrained RBL, among other stock brokers from buying, selling or dealing in the specified scrips of the companies mentioned above, directly or indirectly, on behalf of certain promoters, directors and clients specified by the SEBI Subsequently, SEBI disposed off the proceedings against RBL in matter of IFSL; by consent orders disposed of adjudication proceedings in relation to Mega Corporation Limited and Karuna Cables Limited with SEBI and issued an administrative warning in the matter of Millenium Cybertech Limited and later on vacated the direction issued in millennium cybertech. In similar nature of cases, SEBI through an ad interim order dated January 17, 2007, restrained RBL from buying, selling or dealing directly or indirectly in the shares of Nissan Copper Limited, until the receipt of further orders from SEBI. However, SEBI vide its order dated February 20, 2009 revoked the directions passed earlier on the merits of the case. The SEBI has also in the matter of Ind Tra Deco Limited, issued an ad interim order dated October 5, 2005 pending investigation, restraining RBL, among other stock brokers and the promoters and directors of Ind Tra Deco Limited from buying, selling or dealing in the securities of/ in the scrip of Ind Tra Deco Limited, directly or indirectly, from October 5, 2005 until the receipt of further orders, However, SEBI vide its order dated September 18, 2009 revoked the directions passed earlier on the merits of the case.
  • Pursuant to an inspection of books and records of the broking division of RBL for the period January 2004 to December 2004, SEBI has appointed an adjudicating officer vide its letter dated June 24, 2008. RBL. Based on submissions and presentations by RBL , the adjudicating officer vide its order dated December 22, 2008 disposed of the proceeding by SEBI.
  • Pursuant to an inspection of books and records of the PMS division of RBL for the period September 2004 to December 2005, SEBI has initiated an enquiry officer proceeding vide its letter dated November 8, 2007. Subsequently SEBI has issued a show cause notice dated October 22, 2009 under Regulation 28 of SEBI (Intermediaries) Regulations 2008 as to why penalty, as considered appropriate by the Designated Member, should not be imposed on RBL for the alleged violation of the Code of Advertisement and SEBI circulars no. 1(93-94) dated October 20, 1993 and no. IMD/PMS/CIR/1/21727/03. As the certificate of registration under the Portfolio Manager Regulations was transferred to RAMCL from RBL, RAMCL made an application for consent order dated January 12, 2010. SEBI. RAMC then again filed application for consent order with revised terms of settlement on May 21, 2010. SEBI vide its consent order dated September 27, 2010 has disposed of the proceedings initiated vide Show Cause Notice dated October 22, 2009.
  • SEBI vide its letter dated November 30, 2009 initiated adjudicating proceedings against RBL for the alleged violation of the SEBI Act, the Depositories Act, 1996, the Stock Broker Regulations, the Depository Regulations and certain SEBI circulars.. SEBI vide its Order dated November 10, 2010 imposed total penalty of Rs 3 Lacs on certain violations observed. RBL on January 17, 2011 has filed an appeal with The Securities Appellate Tribunal (SAT) against the order of adjudication officer. SAT had set aside the impugned order in this regard vide its order dated June 16, 2011.
  • SEBI has observed orders on behalf of client resulted into artificial demand in the scrip Nandan Exim Ltd during the period Sep 2006- Nov 2006. SEBI through its letter dated June 15, 2010 has warned RBL on the trading pattern of one client in the scrip Nandan Exim Ltd.
  • SEBI vide its letter dated May 24, 2011 has initiated a proceeding against RBL and has issued a show cause notice under regulation 25 of SEBI (Intermediaries) Regulations, 2008 in the matter of fraud committed by a relationship manager of Citibank. RBL has replied the same on June 20, 2011. SEBI vide its letter dated June 11, 2012 has disposed off the proceedings against RBL without imposing any penalty.
  • SEBI vide its letter dated June 20, 2011 has initiated a proceeding against RBL and has issued a show cause notice under regulation 25 and 38 of SEBI (Intermediaries) Regulations, 2008 in the matter of trading by client Ms. Pooja Menghani. SEBI vide intimation dated December 31, 2012 has rejected RBL consent application dated August 11, 2011 in the matter. SEBI has vide its letter dated November 29, 2012 warned RBL in the matter of trades carried out by Gajinder Paul Dhody. It was observed by SEBI that RBL has failed to exercise due diligence and allowed client to access securities market.
  • Pursuant to the limited purpose inspection conducted by SEBI in July, 2010 in relation to the investor grievances, SEBI vide its letter dated November 21, 2012 advised RBL not to repeat the irregularities mentioned in the inspection report and to provide comments of the Board in relation to various corrective steps taken by RBL to reduce/disallow the investor grievances. RBL vide its letters dated December 12, 2012 & December 28, 2012 filed status of various steps taken by RBL to disallow/reduce investor’s grievance and comments of the Board in this regard as required by SEBI.
  • SEBI has issued administrative warning to RBL vide its letter dated September 03, 2013 pursuant of inspection of books and records of Depository Participant operations conducted during 2012-13.
  • Pursuant to the inspection of books and records of RBL conducted by SEBI for the period September 22, 2011 to February 15, 2012, SEBI vide its letter dated September 23, 2013 has issued administrative warning to be careful in future and improve compliance standards by specifying the rate and period of delayed payment charges in the policy and procedures for clients and any change in it should be intimated to client. SEBI has advised to take corrective steps in this regard. RBL has taken corrective steps in this regard.
  • SEBI had carried out inspection of books and records of RBL during January 15, 16, 2013. Pursuant to the inspection, SEBI has issued administrative warning vide its letter dated March 28, 2014 to be careful in future and improve compliance standards to avoid recurrence of such instances, failing which appropriate action may be initiated in accordance with the provisions of SEBI Act 1992 and Regulations framed there under. RBL has been advised to take appropriate corrective steps to rectify the deficiencies observed in the inspection and submit an action taken report with SEBI within 30 days. RBL has also been advised to place the findings and deficiencies observed in the inspection, corrective steps taken, SEBI Warning letter in the immediate next meeting of the board of RBL and forward its comments on the corrective steps taken to SEBI within 30 days of immediate board meeting of RBL.
  • SEBI has vide its letter dated November 12, 2013 forwarded a Show Cause Notice dated September 25, 2013 under Rule 4 of the SEBI (Procedure for Holding Inquiry and Imposing Penalties by the Adjudication Officer) Rules, 1995 read with section 15-I of the SEBI Act, 1992 in the matter of Veritas (India) Limited. SEBI has observed the trading activity of client Jai Kishan Lakhmani in the scrip Veritas (India) Limited as fictitious as he was one of the top last traded price contributor during January 1, 2009 to March 31, 2012.. SEBI vide its order dated August 27, 2014 has levied a penalty of Rs. 8.00 lacs and Rs. 2.00 lacs under section 15HA and 15HB of SEBI Act 1992 respectively. RBL has filed an appeal against the order before Securities Appellate Tribunal.
• List of Associates as per SEBI (Research Analysts) Regulations, 2014
  • Religare Advisors Limited (Formerly Religare Wealth Management Limited)
  • Religare Business Solutions Limited
  • Religare Commodities Limited
  • Religare Comtrade Limited
  • Religare Enterprises Limited
  • Religare Finvest Limited
  • Religare Capital Markets Limited
  • Religare Health Insurance Company Limited
  • Religare Insurance Limited
  • Religare Global Asset Management Inc.
  • Religare Credit Advisor Private Limited
  • Religare Housing Development Finance Corporation Limited
  • Religare Capital Markets International (Mauritius) Limited
  • Religare Capital Markets (Europe) Limited
  • Religare Capital Markets (UK)Limited
  • Religare Capital Markets Corporate Finance Pte Limited
  • Religare Capital Markets Inc.
  • Religare Capital Markets (Hong Kong) Ltd.
  • Tobler (UK) Limited
  • Kyte Management Limited
  • Religare Capital Markets (Singapore) Pte Limited
  • Bartleet Religare Securities (Private) Limited
  • Bartleet Asset Management (Private) Limited
  • Strategic Research Limited
  • Bartleet Wealth Management (Private) Limited
  • IBOF Investment Management Private Limited
  • Religare Credit investment Trust
• Statements on ownership and material conflicts of interest, compensation - RBL and Associates

  S. No.	Statement	Answers to the best of RBL’s knowledge and belief to questions/ statements for RBL and associates are No/ Nil except for the companies listed against specific question/ statement below
  a	RBL or any of its associates has any financial interest in the subject company? Nature of Interest (if applicable), is given against the company’s name .
  b	RBL or any of its associates, have actual/beneficial ownership of one per cent. or more securities of the subject company, at the end of the month immediately preceding the date of publication of the research report or date of the public appearance
  c	RBL or any of its associates, has any other material conflict of interest at the time of publication of the research report or at the time of public appearance?
  d	RBL or any of its associates has received any compensation from the subject company in the past twelve months?
  e	RBL or any of its associates has managed or co-managed public offering of securities for the subject company in the past twelve months?
  f	RBL or any of its associates has received any compensation for brokerage services from the subject company in the past twelve months?
  g	RBL or any of its associates has received any compensation for products or services other than brokerage services from the subject company in the past twelve months?
  h	RBL or any of its associates has received any compensation or other benefits from the subject company or third party in connection with the research report?
  i	RBL has been engaged in market making activity for the subject company?

• For statements on ownership and material conflicts of interest , compensation for individual Research Analyst(s) (RA), please refer to each specific research report.

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