Regulatory Disclosures

Permitted Activities

We are permitted to provide:

• Investment advisory services in securities listed on recognized stock exchanges
• Financial planning and goal-based investment advice
• Portfolio review and rebalancing recommendations
• Risk profiling and asset allocation guidance
• Research reports and investment analysis

Prohibited Activities

We are NOT permitted to:

• Provide Portfolio Management Services (PMS) unless separately registered
• Act as distributors or receive commissions from product manufacturers
• Execute trades on behalf of clients or handle client funds
• Provide advice on unlisted securities without proper disclosure

SEBI Code of Conduct

We adhere to SEBI Code of Conduct principles:

• Honesty and Fairness: Act with integrity and fairness in all dealings
• Diligence: Exercise due diligence and professional care
• Capability: Maintain adequate knowledge and capability
• Confidentiality: Protect client information and privacy
• Professional Standards: Uphold professional standards of the industry

Fiduciary Responsibility

• We act as fiduciaries for our clients
• We prioritize client interests above our own
• We disclose and manage conflicts of interest
• We provide suitable advice based on client risk profile

Internal Mechanism

• Contact IA (Response within 3 working days)
• Email: jdgunjal@gmail.com Phone: +91 9717001609

Online Dispute Resolution (ODR)

• If dissatisfied with the outcomes of the SCORES, complaint may be lodged at https://smartodr.in

SEBI SCORES Platform

Unresolved complaints may be escalated to:

• SEBI SCORES Portal: https://scores.sebi.gov.in
• SEBI Investor Helpline: 1800-266-7575
• SEBI Office: PN-C/7, G Block BKC, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051.

Arbitration

• Disputes shall be referred to arbitration under Arbitration and Conciliation Act, 2015
• Venue of arbitration: Pune, India
• Language of arbitration: English
• Arbitrator to be appointed by mutual consent or as per Act

Compliance Officer

• Name: Jayadrath Gunjal
• Email: jdgunjal@gmail.com
• Phone: 9717001609
• Responsibilities: Monitoring compliance, handling complaints, regulatory reporting

Risk Management

• Comprehensive risk management framework
• Regular internal audits and compliance reviews
• Employee training on regulatory requirements
• Cybersecurity and data protection measures

Record Keeping

• Maintenance of records as per SEBI requirements
• Electronic record keeping with adequate backups
• Secure storage and access controls
• Retention periods as per regulatory guidelines

We maintain the following policy documents as required by SEBI:

These policies are reviewed annually and updated as needed to comply with regulatory requirements.

• We monitor regulatory developments and update our practices accordingly
• Material regulatory changes are communicated to clients
• Policies and procedures are reviewed annually or as needed
• Compliance with new regulations is implemented within stipulated timelines