Policy for Conflict of Interest

Policy and Procedure to identify and avoid or to deal or manage actual or potential conflict of interest SEBI vide its Circular No. - CIR/MIRSD/5/2013 dated August 27, 2013 laid down general guidelines for avoiding or dealing with or managing conflict of interest.

As per the Circular Vogue Commercial Co. Ltd. has laid down the policy and procedure in order to avoid or deal with or manage conflict of interest.

The policy is as mentioned below:-

1. Vogue Commercial Co. Ltd. (Vogue) at all times maintains high standards of integrity in the conduct of its business. This means Vogue shall have high standards of honesty and truthfulness while dealing with its clients.
2. Vogue shall ensure fair treatment to all their clients and shall not discriminate amongst them. This means that Vogue shall give good services to all its clients.
3. Vogue shall ensure that any person dealing for and on behalf of Vogue with any of its clients, there shall not conflict with his duty to its clients and shall ensure that clients’ interest shall always be in primary thing in case of investment advice or any transaction entered into with company.
4. Vogue or any person acting for and on behalf of Vogue while dealing with the client shall ensure that if at all there is bound to be conflict of interest, the proper disclosure shall be made to the clients to ensure that fair and unbiased services are rendered to the clients.
5. Vogue and person acting for and on behalf of Vogue shall ensure that they shall not deal in securities if they are having any material information about that security which is not published.
6. Vogue and person acting on behalf of the Vogue shall ensure that they shall not communicate to its clients any unpublished information.
7. Vogue shall not contribute which lead to manipulation of demand and supply of the securities in the market or to influence prices of securities.
8. Vogue and the person acting for and on behalf of Vogue shall not share any information received from clients, while dealing for their personal interest.
9. Vogue shall not have incentive structure which encourages sale of products not suiting the risk profile of the clients.

The above policy can be revised at the regular interval of time.

By the board of Directors
For Vogue Commercial Co. Ltd