Investor Charter in respect of Research Analyst (RA):

AJAY KURIAN VARGHESE

A. Vision and Mission Statements for Investors

B. Details of Business Transacted by the Research Analyst with Respect to the Investors

• To publish research reports based on the research activities of the Research Analyst.
• To provide an independent unbiased view on securities.
• To offer unbiased recommendation, disclosing the financial interests in recommended securities.
• To provide research recommendations 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 where any conversation related to research services has taken place.

C. Details of Services Provided to Investors

Onboarding of Clients

• Sharing of terms and conditions of research services.
• Completing KYC of fee-paying clients.

Disclosure to Clients

• To disclose information that is material for the client to make an informed decision, including details of business activity, disciplinary history, terms and conditions of research services, details of associates, risks and conflicts of interest, if any.
• To disclose the extent of use of Artificial Intelligence tools in providing research services.
• To disclose, while distributing a third-party research report, any material conflict of interest of such third-party research provider or provide a web address directing recipients to relevant disclosures.
• To disclose any conflict of interest of activities related to providing research services with other activities of the Research Analyst.
• To distribute research reports and recommendations to clients without discrimination.
• To maintain confidentiality with respect to publication of research reports until made available in the public domain.
• To respect data privacy rights of clients and take measures to protect unauthorized use of confidential information.
• To disclose timelines for services provided by the Research Analyst and ensure adherence to those timelines.
• To provide clear guidance and adequate caution notices 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 required for legal obligations or with specific client consent.

D. Details of Grievance Redressal Mechanism and How to Access It

Investors can lodge complaints/grievances against the Research Analyst through the following methods:

Mode of Filing Complaint with Research Analyst

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

Mode of Filing Complaint on SCORES or with RAASB

SCORES 2.0 is a web-based centralized grievance redressal system of SEBI that facilitates effective grievance resolution in a time-bound manner.

Two-Level Review Process

• First review is done by the designated body (RAASB).
• Second review is done by SEBI.
• Investors may also email the designated email ID of RAASB.

SMARTODR Platform

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

Physical Complaints

Investors may send physical complaints to:

E. Rights of Investors

• Investors' right to have digital accessibility.
• 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 statutory and regulatory disclosures.
• Right to Fair & True Advertisement.
• Right to Awareness about Service Parameters and Turnaround Times.
• Right to be informed of timelines for each service.
• Right to be Heard and receive satisfactory grievance redressal.
• Right to have timely redressal of grievances.
• Right to Exit from financial products or services in accordance with agreed terms and conditions.
• Right to receive clear guidance and caution notices when dealing with complex and high-risk financial products and services.
• Additional rights for vulnerable consumers - Right to access services in a suitable manner even if differently abled.
• Right to provide feedback on financial products and services used.
• Right against coercive, unfair, and one-sided clauses in financial agreements.

F. Expectations from Investors (Responsibilities of Investors)

Do's

• Always deal with SEBI registered Research Analysts.
• Ensure that the Research Analyst has a valid registration certificate.
• Check the SEBI registration number from the official SEBI website before investing.
• Always pay attention to disclosures made in research reports before investing.
• Pay Research Analyst fees through banking channels only and maintain duly signed receipts mentioning payment details.
• Before buying/selling securities or applying in public offers, check the research recommendations provided by your Research Analyst.
• Ask relevant questions and clear doubts with your Research Analyst before acting on recommendations.
• Seek clarification and guidance on research recommendations, especially for complex and high-risk financial products and services.
• Be aware that you have the right to stop availing Research Analyst services according to agreed terms.
• Provide feedback regarding the services received.
• Ensure that you are not bound by any clause that contravenes regulatory provisions.
• Inform SEBI about Research Analysts offering assured or guaranteed returns.

Don'ts

• Do not provide funds for investment to the Research Analyst.
• Do not fall prey to misleading advertisements or market rumours.
• Do not get attracted to limited-period discounts, incentives, gifts, or similar offers provided by Research Analysts.
• Do not share login credentials and passwords of trading, demat, or bank accounts with the Research Analyst.

Important Guidance