Policies & Disclosures

Registration status

Business activity and terms of association

We are engaged solely in providing research services — the preparation and distribution of research reports and recommendations — as permitted under our registration. We are not a stock broker, portfolio manager, investment adviser or mutual fund distributor unless separately and specifically registered and disclosed as such. Where any group entity holds a separate registration for a different activity (broking, distribution, advisory), that activity is conducted under its own registration and is disclosed to you before you engage with it.

Disciplinary history

No penalty, enforcement action or material adverse finding has been recorded against us by SEBI, any stock exchange or any other regulatory authority as on the date of this disclosure, other than as specifically stated here: [Nil / details of any action]. This section is updated promptly upon any change in disciplinary status.

Conflict of interest

Before or at the time of issuing a research report, we disclose to you, our analysts' and the firm's financial interest (if any) in the subject company, actual or potential conflicts of interest, and whether the analyst or the firm has received compensation from the subject company in the preceding twelve months. Specific conflict disclosures are carried within each individual research report, in accordance with Regulation 18 and the Third Schedule of the SEBI (Research Analysts) Regulations, 2014.

• Ownership of securities of the subject company by the analyst, their relatives, or the firm
• Any material financial interest in the subject company
• Receipt of compensation from the subject company for any service in the past 12 months
• Any other conflict that a reasonable investor would expect to be disclosed

Fees and compensation

Our fee structure for research services is disclosed to clients prior to onboarding and is capped and structured in line with SEBI's prescribed fee limits for individual and HUF clients (with the relaxations available to Accredited Investors, see Section 07). We do not accept compensation from the companies we cover in exchange for favourable research.

Risk disclosure

Vision

To enable every investor to take well-informed, independent decisions in the securities market through research that is transparent, unbiased and grounded in disclosed methodology.

Mission

To provide research services in a fair, ethical and transparent manner, and to empower investors through financial education, timely disclosures and accessible grievance redressal.

Services we provide as a Research Analyst

• Preparation and distribution of independent research reports on listed and to-be-listed securities, based on published research methodology
• Public appearances and research calls consistent with our registered research activity
• Disclosure of recommendation history, past performance and rationale for each call
• Model portfolios and thematic research, where offered, with clearly stated assumptions

Our responsibilities to you

• Conduct research with independence, integrity, objectivity and due diligence
• Disclose all actual and potential conflicts of interest before or with the research report
• Maintain confidentiality of your non-public information
• Provide a copy of research reports and disclosures on request, within regulatory timelines
• Not offer any guaranteed or assured returns, directly or indirectly
• Redress grievances within the timelines specified by SEBI (see Section 03)

What we expect from you as an investor

• Read the disclosures, risk profile and terms of the research service before subscribing
• Verify our SEBI registration on the SEBI website and, where relevant, our BASL membership
• Rely on your own judgement and risk appetite — research is an input, not an instruction
• Report any unsolicited "guaranteed return" scheme claiming to be from us; we never make such claims
• Keep your contact details updated so grievance and service communications reach you

Do's and Don'ts

• Do deal only with a SEBI-registered Research Analyst; verify registration independently
• Do insist on a written agreement / terms of service before paying any fee
• Do pay fees only through banking channels, into an account in the RA's registered name
• Don't share login credentials, OTPs or trading account access with anyone, including us
• Don't act on unsolicited tips or "sure-shot return" messages purportedly from an RA
• Don't pay fees in cash or to a personal / third-party account

Grievance redressal at a glance

If you are dissatisfied with our service, you may first write to our Grievance / Compliance Officer. If unresolved, you can escalate to SEBI via the SCORES portal, and thereafter to the SEBI-notified Online Dispute Resolution (ODR) platform. Full timelines and contact details are in Section 03.

How to reach us first

Write to our designated Compliance / Grievance Officer with your name, PAN, contact details and a description of the grievance.

Escalation matrix

1. 1

   Internal grievance redressal

   Acknowledged within 3 working days; resolved within 21 calendar days of receipt, as prescribed by SEBI.

2. 2

   SEBI Complaints Redress System (SCORES)

   If unresolved or unsatisfactory, file a complaint on SCORES. SEBI monitors resolution by the RA on this platform.

3. 3

   Online Dispute Resolution (ODR)

   If still unresolved, initiate conciliation / arbitration through the SEBI-notified Online Dispute Resolution portal for the securities market.

Complaint data

Published monthly and annually as required under SEBI's disclosure norms for Research Analysts.

A trailing annual summary (received, resolved, pending, and average resolution time) is available on request and is updated on this page at the start of each month.

Integrity

We maintain high standards of integrity, promptitude and fairness in all research activity and client dealings.

Due skill, care and diligence

Research is prepared with reasonable care, based on adequate and reliable information, and with a documented, consistently applied methodology.

Independence and objectivity

Recommendations reflect our analysts' genuine, independent view and are not influenced by the subject company, our own trading positions, or any other business interest of the firm.

Segregation of research from other business

Where the firm carries out any other regulated activity, research is functionally and, where required, structurally separated to prevent research being influenced by that activity.

No assured or guaranteed returns

We never represent, explicitly or implicitly, that any recommendation carries an assured, minimum or guaranteed return.

Confidentiality

Non-public client information and pre-publication research is kept confidential and is not used for the personal trading advantage of any employee or associate.

Restriction on personal trading

Analysts and access persons are subject to a trading restriction / cooling-off period around the publication of research on a covered security, and must disclose their holdings in accordance with our internal Code for Prevention of Insider Trading.

Fair dealing

Research is disseminated to all subscribers of a given service simultaneously; no client or group of clients receives research or recommendations ahead of others.

Compliance

We comply with the SEBI (Research Analysts) Regulations, 2014, applicable SEBI circulars, the SEBI (Prohibition of Insider Trading) Regulations, 2015, and other securities laws in force.

Redressal of investor grievances

Grievances are handled promptly, fairly, and within the timelines set out in Section 03 of this page.

General principles

• Returns are computed using the same, pre-defined methodology across all recommendations — we do not selectively choose favourable calculation windows
• Past performance of recommendations is not indicative of, and does not guarantee, future performance
• Displayed returns exclude brokerage, transaction charges, taxes (including STT and capital gains tax) and any cost of implementation, unless explicitly stated otherwise
• Both open (running) and closed (achieved target / stop-loss hit / time-based exit) recommendations are included in aggregate performance disclosures — we do not report closed calls selectively

Point-to-point return

For a single recommendation, absolute return is calculated as:

The "Recommendation Price" is the closing price of the security on the trading day the report is published (or the price explicitly stated in the report). The "Exit Price" is the price at which the target, stop-loss or time-bound holding period specified in the report was achieved.

Annualised return (CAGR)

For recommendations held longer than one year, we additionally disclose the compounded annual growth rate:

Hit ratio and aggregate disclosures

Where we publish a "hit ratio" or success rate, it is calculated as the number of closed recommendations that achieved their stated target, divided by the total number of closed recommendations in the relevant period, and is shown alongside the total count of recommendations so it isn't read in isolation.

Client due diligence (CDD)

Where a client relationship requires KYC (for example, paid subscription services), we verify identity and address using SEBI/KRA-prescribed KYC documentation, and apply enhanced due diligence for higher-risk clients, including politically exposed persons (PEPs) and clients from jurisdictions flagged by the Financial Action Task Force (FATF).

Risk categorisation and ongoing monitoring

• Clients are risk-rated (low / medium / high) at onboarding and re-assessed periodically
• Transactions and subscription payments are screened against UN Security Council and other applicable sanctions lists
• Unusual patterns — such as payments from unrelated third parties, structuring of payments, or refusal to provide KYC information — are treated as red flags for review

Reporting and record-keeping

Suspicious Transaction Reports (STRs), where warranted, are filed with the Financial Intelligence Unit – India (FIU-IND) through our Principal Officer. Client identification records, transaction records and correspondence are retained for a minimum of five years from the end of the business relationship, or longer where required by SEBI record-keeping norms, in a manner that ensures confidentiality and integrity.

Governance

Who qualifies

An individual, HUF, family trust, sole proprietorship, partnership firm, trust or body corporate may seek accreditation from a SEBI-recognised Accreditation Agency by demonstrating, broadly, one of the following (thresholds as prescribed by SEBI from time to time and subject to change):

• Annual income of at least ₹2 crore; or
• Net worth of at least ₹7.5 crore, with at least half held in financial assets; or
• A combination of annual income of at least ₹1 crore and net worth of at least ₹5 crore, with at least half of net worth in financial assets

Non-individual entities (family trusts, corporates, partnership firms) have separate prescribed net-worth thresholds. Accreditation is granted by an Accreditation Agency (typically a subsidiary of a recognised stock exchange or depository) and is valid for a fixed period, subject to renewal.

What changes for an Accredited Investor client

• Fee arrangements may be mutually agreed and are not subject to the standard fee caps applicable to non-accredited individual/HUF clients
• The standard, prescribed client agreement format may be substituted with a negotiated agreement, provided all mandatory disclosures are retained
• Certain onboarding and disclosure timelines may differ, as permitted under the applicable SEBI circular

These relaxations do not dilute conduct, disclosure or grievance-redressal obligations owed to you — they apply only to the specific commercial and documentation flexibilities SEBI has permitted for accredited relationships.

Your right to opt out

Being eligible for accreditation does not obligate you to be treated as an Accredited Investor. You may choose to continue as a standard client under the regular fee and agreement framework at any time, and we will disclose in writing the specific implications of opting for accredited treatment before any such agreement is executed.

Acceptance

By accessing this website, you agree to these Terms of Use. If you do not agree, please discontinue use of the site.

Nature of website content

General content on this website (services overview, portfolio descriptions, articles) is for information only and does not, by itself, constitute a research report or personalised investment advice. Only content explicitly issued as a research report under our SEBI registration, to a subscribed client, carries the status of research under the SEBI (Research Analysts) Regulations, 2014.

No guarantee of returns

Nothing on this website should be construed as a promise or guarantee of any investment return. All investments are subject to market risk, including possible loss of principal.

Intellectual property

All content, design, logos and research on this site are the property of Adhyarth Wealth & Asset Management or its licensors and may not be reproduced, redistributed or used commercially without prior written consent.

Third-party links

Links to external websites (including SCORES, ODR and other regulator portals) are provided for convenience; we do not control and are not responsible for the content of third-party sites.

Limitation of liability

To the maximum extent permitted by law, we are not liable for any direct or consequential loss arising from reliance on general website content, technical failure, or unauthorised access to the site.

Governing law and jurisdiction

These terms are governed by the laws of India, and courts at [City], India shall have exclusive jurisdiction, without prejudice to the dispute-resolution avenues described in Section 03.

Changes to these terms

We may update these Terms of Use from time to time; the "last updated" date at the top of each section reflects the most recent revision.

Who we are, as Data Fiduciary

Adhyarth Wealth & Asset Management is the Data Fiduciary in respect of personal data collected through this website and our research services, and determines the purpose and means of processing your personal data.

What we collect and why

• Identity & contact data (name, email, phone, PAN where required for KYC) — to onboard you, deliver research services, and meet SEBI KYC/AML obligations
• Financial/KYC data, where a paid service requires it — to comply with SEBI and PMLA obligations
• Newsletter and enquiry data submitted through our forms — to respond to you and, where you've consented, send research updates
• Website usage data (pages visited, device/browser type) — to operate and secure the site and understand aggregate usage

We process personal data only on the basis of your consent, or for a "certain legitimate use" recognised under the DPDP Act (for example, a purpose you've voluntarily provided data for, or compliance with a legal obligation such as SEBI record-keeping).

Data minimisation, storage and retention

We collect only the personal data necessary for the stated purpose, and retain it only for as long as necessary for that purpose or as required by law — for KYC and transaction records, this generally means the retention periods prescribed under SEBI regulations and the PMLA (typically a minimum of five years from the end of the relationship). Data no longer required is deleted or anonymised, subject to those legal minimums.

Your rights as a Data Principal

• Right to access a summary of the personal data we hold about you and how it is processed
• Right to correction, completion, and updating of your personal data
• Right to erasure of personal data that is no longer necessary for the purpose it was collected, subject to our legal retention obligations
• Right to grievance redressal directly with us, and thereafter with the Data Protection Board of India
• Right to nominate another individual to exercise these rights on your behalf in the event of death or incapacity

To exercise any of these rights, write to the Grievance / Data Protection Officer above. We will acknowledge and respond within the timelines prescribed under the DPDP Act and its rules.

Sharing and cross-border transfer

We share personal data only with service providers, regulators (including SEBI, SCORES and the ODR platform), and statutory authorities (including FIU-IND) as needed for the purposes above, under contractual confidentiality obligations. Personal data may be stored or processed outside India through our technology providers, except where transfer to a specific country or territory is restricted by the Central Government under the DPDP Act.

Security safeguards and breach notification

We use reasonable technical and organisational safeguards — including access controls, encryption in transit, and restricted internal access on a need-to-know basis — to protect personal data against unauthorised access, loss or misuse. In the event of a personal data breach, we will notify the Data Protection Board of India and affected Data Principals as required under the DPDP Act.

Children's data

Our services are intended for adults capable of entering into a binding contract. We do not knowingly collect personal data of children (individuals under 18) without verifiable parental or guardian consent, as required under the DPDP Act.

Cookies

This site uses strictly necessary cookies to operate correctly, and, where you consent, analytics cookies to help us understand aggregate site usage. You can control cookies through your browser settings.

Changes to this policy

We may revise this Privacy Policy from time to time to reflect changes in law (including DPDP Act rules as notified) or our practices. Material changes will be highlighted on this page with an updated "last reviewed" date.