Policies & Legal Information

DISCLOSURE

• The particulars given in this Disclosure Document have been prepared in accordance with SEBI (Research Analyst) Regulations, 2014.
• The purpose of the Document is to provide essential information about the Research and recommendation Services in a manner to assist and enable the perspective client/client in making an informed decision for engaging in Research and recommendation services before investing.
• For the purpose of this Disclosure Document, Research Analyst is Raja Chandrashekhar Venkatraman (hereinafter referred as “Research Analyst”)

Descriptions about “Research Analyst”

 History, Present business and Background:

Research Analyst is registered with SEBI with Registration No. INH000016223. The Analyst got its registration on 13th June, 2024 and is engaged in research and recommendation Services. The focus of Research Analyst is to provide research and recommendations services to the clients. Analyst aligns its interests with those of the client and seeks to provide well researched services.

 Terms and conditions of Research and Recommendation Services:

Terms and conditions of Research and Recommendation Services are detailed in the terms and condition document. Please refer to the same for details.

 Disciplinary history:

Terms and conditions of Research and Recommendation Services are detailed in the terms and condition document. Please refer to the same for details. There are no pending material litigations or legal proceedings, findings of inspections or investigations for which action has been taken or initiated by any regulatory authority against the Research Analyst or its associates or relatives.

 Details of its associates:

No Associates

 Disclosures with respect to Research and Recommendations Services:

• Research Analyst or his associate or his relative may have financial interest or actual / beneficial ownership of one per cent or more in the securities recommended in its personal portfolio at the end of the month immediately preceding the date of publication of the research report or date of the public appearance. Details of the same may be referred through the disclosures made at the time of recommendation.
• There are no actual or potential conflicts of interest arising from any connection of Research Analyst or his associate or his relative to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of Research Analyst services. Such conflict of interest shall be disclosed to the client as and when they arise.
• Research analyst or its associates or relatives, may 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 or research recommendation. Details of the same may be referred through the disclosures made at the time of recommendation.
• Research analyst or its associate or relatives has no connection or association of any sort with any issuer of products/ securities recommended herein.
• Research analyst or his associate or his relative has no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of research and recommendations services.
• Research analyst or its associates has not received any kind of remuneration or consideration form the products/ securities recommended herein.
• Research analyst or its associates have not received any compensation from the subject company in past 12 months.
• Research analyst or its associates have not managed or co-managed the public offering of Subject Company in past 12 months.
• Research analyst or its associates have not received any compensation for investment banking or merchant banking of brokerage services from the subject company in past 12 months.
• Research analyst or its associates have received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past twelve months.
• Research analyst or its associates have not received any compensation or other benefits from the subject company or third party in connection with the research report or research recommendations.
• Research analyst or its associates have not received any compensation for products or services from the subject company in past 12 months.
• The subject company is or was not a client of Research analyst or its associates during twelve months preceding the date of distribution of the research report and recommendation services provided.
• Research Analysts or its associates has not served as an officer, director or employee of the subject company.
• Research Analysts has not been engaged in market making activity of the subject company.

A. Vision and Mission Statements for investors.

 Vision

Invest with knowledge & safety.

 Mission

Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

B. Details of business transacted by the Research Analyst with respect to the investors.

• To publish research report based on the research activities of the RA
• To provide an independent unbiased view on securities.
• To offer unbiased recommendation, disclosing the financial interests in recommended securities.
• To provide research recommendation, based on analysis of publicly available
• information and known observations.
• To conduct audit annually
• To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Research Analysts.
• To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to the research services has taken place.

C. Details of services provided to investors (No Indicative Timelines)

• Onboarding of Clients

o Sharing of terms and conditions of research services

o Completing KYC of fee paying clients

• Disclosure to Clients:

o To disclose, information that is material for the client to make an informed decision, including details of its business activity, disciplinary history, the terms and conditions of research services, details of associates, risks and conflicts of interest, if any

o To disclose the extent of use of Artificial Intelligence tools in providing research services

o To disclose, while distributing a third party research report, any material conflict of interest of such third party research provider or provide web address that directs a recipient to the relevant disclosures

o To disclose any conflict of interest of the activities of providing research services with other activities of the research analyst.

• To distribute research reports and recommendations to the clients without discrimination.
• To maintain confidentiality w.r.t publication of the research report until made available in the public domain.
• To respect data privacy rights of clients and take measures to protect unauthorized use of their confidential information
• To disclose the timelines for the services provided by the research analyst to clients and ensure adherence to the said timelines
• To provide clear guidance and adequate caution notice to clients when providing recommendations for dealing in complex and high-risk financial products/services
• To treat all clients with honesty and integrity
• To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations or a client has provided specific consent to share such information.

D. Details of grievance redressal mechanism and how to access it

1. Investor can lodge complaint/grievance against Research Analyst in the following ways:

Mode of filing the complaint with research analyst

In case of any grievance / complaint, an investor may approach the concerned Research Analyst who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.

Mode of filing the complaint on SCORES or with Research Analyst Administration and Supervisory Body (RAASB)

i. SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://scores.sebi.gov.in)

Two level review for complaint/grievance against Research Analyst:

 First review done by designated body (RAASB)

 Second review done by SEBI

ii. Email to designated email ID of RAASB

2. If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.

With regard to physical complaints, investors may send their complaints to:

Office of Investor Assistance and Education,
Securities and Exchange Board of India,
SEBI Bhavan, Plot No. C4-A, ‘G’ Block,
Bandra-Kurla Complex, Bandra (E),
Mumbai - 400 051

E. Rights of investors

• Right to Privacy and Confidentiality
• Right to Transparent Practices
• Right to fair and Equitable Treatment
• Right to Adequate Information
• Right to Initial and Continuing Disclosure

-Right to receive information about all the statutory and regulatory disclosures

• Right to Fair & True Advertisement
• Right to Awareness about Service Parameters and Turnaround Times
• Right to be informed of the timelines for each service
• Right to be Heard and Satisfactory Grievance Redressal
• Right to have timely redressal
• Right to Exit from Financial product or service in accordance with the terms and conditions agreed with the research analyst
• Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
• Additional Rights to vulnerable consumers

- Right to get access to services in a suitable manner even if differently abled

• Right to provide feedback on the financial products and services used
• Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from the investors (Responsibilities of investors)

 Do’s

i. Always deal with SEBI registered Research Analyst.

ii. Ensure that the Research Analyst has a valid registration certificate.

iii. Check for SEBI registration number.

Please refer to the list of all SEBI registered Research Analyst which is available on SEBI website in the following link: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=14)

iv. Always pay attention towards disclosures made in the research reports before investing.

v. Pay your Research Analyst through banking channels only and maintain duly signed receipts mentioning the details of your payments. You may make payment of fees through Centralized Fee Collection Mechanism (CeFCoM) of RAASB if research analyst has opted for the mechanism. (Applicable for fee paying clients only)

vi. Before buying/ selling securities or applying in public offer, check for the research recommendation provided by your Research Analyst.

vii. Ask all relevant questions and clear your doubts with your Research Analyst before acting on recommendation.

viii. Seek clarifications and guidance on research recommendations from your Research Analyst, especially if it involves complex and high risk financial products and services.

ix. Always be aware that you have the right to stop availing the service of a Research Analyst as per the terms of service agreed between you and your Research Analyst.

x. Always be aware that you have the right to provide feedback to your Research Analyst in respect of the services received.

xi. Always be aware that you will not be bound by any clause, prescribed by the research analyst, which is contravening any regulatory provisions.

xii. Inform SEBI about Research Analyst offering assured or guaranteed returns.

 Don’ts

i. Do not provide funds for investment to the Research Analyst.

ii. Don’t fall prey to luring advertisements or market rumors.

iii. Do not get attracted to limited period discount or other incentive, gifts, etc. offered by Research Analyst.

iv. Do not share login credential and password of your trading, demat or bank accounts with the Research Analyst.