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For disclosures refer to disclosures
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For disclosures refer to disclosures
Protecting your privacy and treating the personal data of all users of our Electronic Services in accordance with the law is important to us. We understand that by using our Electronic Services you may be entrusting us with personal information (“data”) and assure you that we take our duty to protect and safeguard this data very seriously. This Privacy Policy therefore explains the kind of data we process when using our Electronic Services, the purpose for which we process it, how we process it, whom we may disclose it to and the security measures we have put in place to protect it.
This Privacy Policy applies to all data we obtain through your use of our Electronic Services. It does not apply to data we obtain through other channels nor to Electronic Services of third parties (“third-party Electronic Services”), even if you access them via a link in our Electronic Services or even if they are necessary for the operation of our Electronic Services. We have no influence on the content or privacy policy of third-party Electronic Services and therefore cannot assume any responsibility for them.
When you use our Electronic Services, details of your usage may be automatically registered by our backend systems (such as your IP address, browser, http-header user agent, device-specific information the content you accessed, including time and date of access, usage and user interaction, and the redirecting website from which you came to our Electronic Services). We also process personal data such as your name, address, e-mail address, phone number, date of birth, gender and other data transmitted to us if you register for the usage of our Electronic Services or if you complete a registration form or comment field for a newsletter, product demos, etc..
We process the data based on the following legal grounds:
We process the data for the following purposes:
We process all your personal data in accordance with the applicable laws on data protection and for as long as required.
Wright Research only discloses Electronic Services usage data to third parties as permitted by law, if we are legally obliged to do so or if such disclosure becomes necessary to enforce our rights, in particular to enforce claims arising from a contractual relationship. Within this scope as well as for the purpose of optimising our products and services, we may transmit data within the Wright Research Group between Group companies in India or abroad. Furthermore, we may disclose data to external service providers if this is necessary for the provision of products and services. Such service providers may not use the data for any other purpose than to process the order in question. All of the above persons and entities that may receive data must observe the applicable national and international data protection laws as well as the data protection standards of Wright Research.
Where so prescribed by applicable legislation, Wright Research may on request or under an ongoing duty to provide information disclose data to supervisory authorities, judicial authorities or other persons of authority.
Wright Research will make every effort to take appropriate technical and organisational security measures to ensure that your personal data processed within the IT environment controlled by Wright Research is protected against unauthorised access, misuse, loss and/or destruction, taking account of the applicable legal and regulatory requirements.
Wright Research takes both physical and electronic process-specific security measures, including firewalls, personal passwords, and encryption and authentication technologies. Our employees and the service providers commissioned by us are bound by professional secrecy and must comply with all data protection provisions.
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Where data is transmitted via an open network, we cannot be held responsible for the protection of this data and we accept no responsibility or liability for the security of your data during transmission. We, therefore, recommend avoiding the transmission of any confidential information via open networks.
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The Wright Research Electronic Services may contain links to third-party Electronic Services that are not operated or monitored by us. Please be aware that such third-party Electronic Services are not bound by this Privacy Policy and that we are not responsible for their content or their principles regarding the handling of personal data. We therefore recommend consulting and checking the individual privacy policies or terms of use of third-party Electronic Services.
According to applicable data protection laws and regulations, you may have the following rights:
You also have a right of appeal (as far as this affects you) to the respective Data Protection Supervisory Authority.
If you have questions about the processing of your personal data, please feel free to contact us by using the following contact details:
Name of the person: Sonam Srivastava
Designation: Investment Advisor
Address: 18th Floor, Bombay Stock Exchange, Dalal Street, Mumbai 400001 Telephone: 91-9686195357
Email: info@wrightresearch.in
This process note is the property of Wright Research. The document is to be used for internal purposes only. Any unauthorized, copying, disclosure, use or distribution of the material is strictly forbidden
Providing excellent service on a regular and consistent basis is very important for the organisation’s sustained growth. Wright Research (“WR”) believes that quick and effective handling of complaints as well as prompt corrective & preventive actions and processes are essential for providing our services. This policy document is to enable to put in place an effective and suitable mechanism for receiving and addressing complaints from investors with specific emphasis on resolving such complaints fairly and expeditiously.
Objective of this policy document is to ensure that:
Definitions:
The various channels available to Investors for registering the complaints are as follows:
liaise with the other relevant departments (like Investment Advisory, Operations, Accounts, Legal, Compliance etc).
General Turn Around Time (TAT) for response to complaint is (from the receipt of the valid complaint in writing):
Note: The above TAT can change depending upon the nature and complexity of complaint.
If an investor is not satisfied with the resolution provided through various channels or the method of handling complaint; the investor can escalate the issues to the next higher level i.e. to the Managing Director of the Company. Such escalation should be made in writing and should be delivered in the hard copy to the Corporate Office of the Company
This Code of Ethics (“Code”) has been adopted by Wright Research and is designed to comply with Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 [sub-regulation (9) of regulation 15]
This Code establishes rules of conduct for all employees of Wright Research and is designed to, among other things, govern personal securities trading activities in the accounts of employees, immediate family/household accounts and accounts in which an employee has a beneficial interest. The Code is based upon the principle that Wright Research andits employees owe a fiduciary duty to Wright Research's clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility.
The Code is designed to ensure that the high ethical standards long maintained by Wright Research continue to be applied. The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. The excellent name and reputation of our firm continues to be a direct reflection of the conduct of each employee.
Pursuant to the Investment Advisers Regulation, both Wright Research and its employees are prohibited from engaging in fraudulent, deceptive or manipulative conduct. Compliance with this section involves more than acting with honesty and good faith alone. It means that the Wright Research has an affirmative duty of utmost good faith to act solely in the best interest of its clients.
Wright Research and its employees are subject to the following specific fiduciary obligations when dealing with clients:
In meeting its fiduciary responsibilities to its clients, Wright Research expects every employee to demonstrate the highest standards of ethical conduct for continued employment with Wright Research. Strict compliance with the provisions of the Code shall be considered a basic condition of employment with Wright Research. Wright Research's reputation for fair and honest dealing with its clients has taken considerable time to build. This standing could be seriously damaged as the result of even a single securities transaction being considered questionable in light of the fiduciary duty owed to our clients. Employees are urged to seek the advice of Sonam Srivastava, the Investment Advisor, for any questions about the Code or the application of the Code to their individual circumstances. Employees should also understand that a material breach of the provisions of the Code may constitute grounds for disciplinary action, including termination of employment with Wright Research.
The provisions of the Code are not all-inclusive. Rather, they are intended as a guide for employees of Wright Research in their conduct. In those situations where an employee may be uncertain as to the intent or purpose of the Code, he/she is advised to consult with Sonam Srivastava. Sonam Srivastava may grant exceptions to certain provisions contained in the Code only in those situations when it is clear beyond dispute that the interests of our clientswill not be adversely affected or compromised. All questions arising in connection with personal securities trading should be resolved in favor of the client even at the expense of the interests of employees.
An investment adviser shall act honestly, fairly and in the best interests of its clients and in the integrity of the market.
An investment adviser shall act with due skill, care and diligence in the best interests of its clients and shall ensure that its advice is offered after thorough analysis and taking into account available alternatives.
An investment adviser shall have and employ effectively appropriate resources and procedures which are needed for the efficient performance of its business activities.
An investment adviser shall seek from its clients, information about their financial situation, investment experience and investment objectives relevant to the services to be provided and maintain confidentiality of such information.
An investment adviser shall make adequate disclosures of relevant material information while dealing with its clients.
An investment adviser advising a client may charge fees, subject to any ceiling as may be specified by the Board, if any. The investment adviser shall ensure that fees charged to the clients is fair and reasonable.
An investment adviser shall try to avoid conflicts of interest as far as possible and when they cannot be avoided, it shall ensure that appropriate disclosures are made to the clients and that the clients are fairly treated.
An investment adviser including its representative(s) shall comply with all regulatory requirements applicable to the conduct of its business activities so as to promote the best interests of clients and the integrity of the market.
The senior management of a body corporate which is registered as investment adviser shall bear primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures by the body corporate.
For the purpose of suspicious transactions reporting apart from `transactions integrally Connected', `transactions remotely connected or related need to be considered.
“Suspicions Transactions” means a transaction whether or not made in cash which to a person acting in good faith –
The main objectives of the PMLA are as follows:
Brokers being SEBI registered intermediaries have to comply with the spirit of anti money laundering provisions. To comply with PMLA, the following three specific parameters should be observed, which are related to the overall `Client Due Diligence Process':
For the purpose of CDD, Broker is dealing with institutional clients. According to SEBI regulation / rules Institutional clients includes:
According to SEBI, all trades done by institutional clients should be settled through Clearing House. In clearing house trade, trades are settled by the Broker and custodian of the respective client.
In view of above, following steps to be taken to comply with `Customer Due Diligence' process before registering as client:
Before registering a client, obtain antecedent information. Verify independently information submitted by client but not limited to his identity, registered office address, correspondence address, contact details, occupation, Promoters /Directors, source of income, experience in securities market, PAN no. SEBI Registration No. etc. Obtain as many as information. Generally Institutional clients are recognized at global level. We need to verify clients identity and origin using services of Bloomberg, Reuters, internet services or any other reliable, independent source documents, data or information. After verifying information, registration form along with other supporting documents should be approved by the Compliance Officer designated for verification.
After completing the registration process, the client account should be verified by an independent employee to check the actual beneficial ownership and control of the particular account. We need to obtain the details with respect to Shareholders, Promoters from the client and it has to be verified independently. In this process we should find out who is authorized to operate the client's account and who is ultimately controlling the account. Also verify the sources of funds for funding the transaction. We also have to take care at the time of settlement regarding the nature of transaction, movement / source of transaction, etc. Periodically ask for client's financial details to determine the genuineness of transaction
The “Beneficial Owner” is the natural person or persons who ultimately own, control or influence a client and / or persons on whose behalf a transaction is being conducted. It also incorporates those persons who exercise ultimate effective control over a legal person or arrangement.
Periodically we need to conduct due diligence and scrutiny of client's transactions and accounts to ensure that transactions are being conducted in knowledge, to find out the risk profile, source of funds, etc. At regular interval, ongoing due diligence and scrutiny need to be conduct i.e. perform ongoing scrutiny of the transactions and account throughout the course of the business relationship to ensure that the transactions being conducted are consistent with the Organization’s knowledge of the client, its business and risk profile, taking into account, where necessary, the customer's source of funds.
Before registering client, we need to identify the following details of the prospective client:
The following safeguards are to be followed while accepting the clients:
The parameters of clients into low, medium and high risk should be classified. Clients of special category (as given below) may be classified as higher risk and higher degree of due diligence and regular update of KYC profile should be performed.
We can also evaluate whether there is suspicious trading in determining whether to freeze or close the account. Should be cautious to ensure that it does not return securities or money that may be from suspicious trades. However, we can consult the relevant authorities in determining what action should be taken when it suspects suspicious trading.
Acceptance of clients through Risk-Based Approach:
The clients may be of a higher or lower risk category depending on circumstances such as the customer's background, type of business relationship or transaction etc. We should apply each of the clients due diligence measures on a risk sensitive basis. We should adopt an enhanced customer due diligence process for higher risk categories of customers. Conversely, a simplified customer due diligence process may be adopted for lower risk categories of customers. In line with the risk-based approach, we should obtain the type and amount of identification information and documents necessarily dependent on the risk category of a particular customer.
Clients of special category (CSC):
CSC clients include the following:
The above mentioned list is only illustrative and we should exercise independent judgment to ascertain whether new clients should be classified as CSC or not.
Record Keeping:
For the purpose of the record keeping provision, we should ensure compliance with the record keeping requirements contained in the SEBI Act, 1992, Rules and Regulations made there-under, PLM act, 2002 as well as other relevant legislation, Rules, Regulations, Exchange Bye-laws and Circulars.
Records to be maintained should be sufficient to permit reconstruction of individual transactions (including the amounts and type of currencies involved, if any) so as to provide, if necessary, evidence for prosecution of criminal behavior.
Should there be any suspected drug related or other laundered money or terrorist property, the competent investigating authorities would need to trace through the audit trail for reconstructing the financial profile of the suspect's account. To enable this reconstruction, organizations should retain the following information for the accounts of their customers in order to maintain a satisfactory audit trail.
Organization should ensure that all client and transaction records and information are made available on a timely basis to the competent investigating authorities.
The following document retention terms should be observed:
In situations where the records relate to on-going investigation or transactions, which Have been the subject of a suspicious transaction reporting, they should be retained until it is confirmed that the case has been closed.
Monitoring of transactions:
Regular monitoring of transactions is required for ensuring effectiveness of the Anti Money laundering procedures.
Special attention required to all complex, unusually large transactions / patterns which Appear to have no economic purpose. Internal threshold limits to specify for each class of client's accounts and pay special attention to the transaction, which exceeds these limits.
Should ensure that the records of the transaction are preserved and maintained in terms of the PMLA 2002 and that transactions of suspicious nature or any other transaction notified under section 12 of the act are reported to the appropriate authority. Suspicious transactions should also be regularly reported to the higher authorities / head of the department.
Further the Compliance Department should randomly examine select transaction
undertaken by clients to comment on their nature i.e. whether they are in the suspicious
Transactions or not
.
Whether a particular transaction is suspicious or not will depend upon the background, details of the transactions and other facts and circumstances. Followings are the circumstances, which may be in the nature of suspicious
Transactions:-
Any suspicion transaction needs to be notified immediately to the designated Principal Officer. The notification may be done in the form of a detailed report with Specific reference to the client's transactions and the nature / reason of suspicion. However, it should be ensured that there is continuity in dealing with the client as Normal until told otherwise and the client should not be told of the report /suspicion. In exceptional circumstances, consent may not be given to continue to operate the Account and transactions may be suspended, in one or more jurisdictions concerned in the transaction, or other action taken.
Wright Research has designated Ms. Sonam Srivastava, as the Principal Officer for due compliance of anti money laundering policies. He will be responsible for implementation of internal controls & procedures for identifying and reporting any suspicious transaction or activity to the FIU – IND.
The particulars given in this Disclosure Document have been prepared in accordance with SEBI (Investment Advisers) Regulations, 2013.
The purpose of the Document is to provide essential information about the Investment Advisory Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging Investment Advisor before investing.
For the purpose of this Disclosure Document, Investment Adviser is “Wright Research & Capital Pvt Ltd” company registered with the Securities and Exchange Board of India as an Investment Advisor under SEBI (Investment Advisers) Regulations, 2013 vide registration no. INA100015717 dated Jan 12, 2021 having its registered office at 102, Shagun Vatika, Prag Narayan Road, Lucknow 226001, India.
WR was originally started as a trademark name for the investment advisory services given by Sonam Srivastava and the registration got transferred to private limited company “Wryght Research & Private Limited”
In the capacity as advisers WR aligns its interests with those of the client and seeks to provide the best suited advice based on clients risk profile. WR first tries to understand the client's return expectations, risk taking ability & goals, which in turn helps to arrive at an asset allocation suitable for the client. WR conducts frequent portfolio reviews and suggests any corrective action/s if required.
WR will provide Advisory Services which shall be in the nature of investment advice, and may include buying and selling the securities for an for an agreed fee structure and which may be for a definite period of time and which may vary / change from time to time, entirely at the Client’s risk. The detailed terms and conditions are as per the agreement executed between client and WR.
No action has been taken against the Individual or the Company as an Investment Adviser by any regulator.
“Disclosure with respect to compliance with Annual compliance audit requirement under Regulation 19(3) of SECURITIES AND EXCHANGE BOARD OF INDIA (INVESTMENT ADVISERS) REGULATIONS, 2013 for last and current financial year are as under :
| Financial Year | Compliance Audit Status | Remarks |
|---|---|---|
| FY20-21 | Completed | |
| FY21-22 | In progress |
No other affiliations or intermediaries have been registered.
WR do not have any distribution or execution arrangement with the issuers of the securities, that WR advises on. The fellow subsidiaries of WR may receive distribution commission/referral fee or similar income in respect of the product or securities for which investment advice is provided to the client by WR. The indicative commissions received by fellow subsidiaries are available on the website.
WR does not recommend services of any stock broker or intermediary to a client. WR does not have any commission sharing agreement with any intermediary for recommending the services either as a stock broker or as other intermediary.
Although WR is not registered as a broker with SEBI, it is not actively engaged into any proprietary trading. It might invest in financial products / securities in the future.
WR is a separate legal entity which has an independent activity of providing the Investment Advisory services. WR does not provide any other services in stock broking, depository, research, portfolio management and distribution of mutual funds and third party products.
Clients are requested to go through the detailed key features, performance track record of the product, or security including warnings, disclaimers etc. before investing as and when provided by the Investment Advisor. Such product materials may also be available towww.sebi.gov.inorwww.nseindia.comorwww.bseindia.com.
WR and the Investment Advisers of WR who provide the investment advice to the clients, shall draw the client’s attention to the warnings, disclaimers in documents, advertising materials relating to an investment product/s which he/she/they is/are recommending to the client/s.
We trust that, before executing on the advice of the Investment Adviser, our Relationship Manager at WR has provided you with all the information about the products, risk factors etc. and you have gone through all the relevant information about the product being advised and have sought requisite clarification about the same.
WR shall maintain complete confidentiality of all information provided by the client/s and shall not disclose any such information, without your prior consent except if such disclosure is required to be made in compliance with any applicable law or regulatory direction. WR will obtain information pertaining to your orders/transactions/portfolio/funds availability/securities availability etc. from the individual Investment Adviser to enable us to provide you with informed and appropriate advice.
The detail of investor relation officer who shall attend to the investor queries and complaints is mentioned below:
Name of the person: Sonam Srivastava
Designation: Investment Advisor
Address: 18th Floor, Bombay Stock Exchange, Dalal Street, Mumbai 400001 Telephone: 91-9686195357
Email: info@wrightresearch.in
In case of any grievances the investors may email to info@wrightresearch.in
|
Sr.No. |
Month |
Carried forward from previous month |
Received |
Resolved* |
Pending# |
|
1 |
Jan, 2021 |
0 |
0 |
0 |
0 |
|
2 |
Feb, 2021 |
0 |
0 |
0 |
0 |
|
3 |
Mar, 2021 |
0 |
0 |
0 |
0 |
|
4 |
Apr, 2021 |
0 |
0 |
0 |
0 |
|
5 |
May, 2021 |
0 |
0 |
0 |
0 |
|
6 |
Jun, 2021 |
0 |
0 |
0 |
0 |
|
7 |
Jul, 2021 |
0 |
0 |
0 |
0 |
|
8 |
Aug, 2021 |
0 |
0 |
0 |
0 |
|
9 |
Sep, 2021 |
0 |
0 |
0 |
0 |
|
10 |
Oct, 2021 |
0 |
0 |
0 |
0 |
|
11 |
Nov, 2021 |
0 |
0 |
0 |
0 |
|
12 |
Dec, 2021 |
0 |
0 |
0 |
0 |
|
13 |
Jan, 2022 |
0 |
0 |
0 |
0 |
|
14 |
Feb, 2022 |
0 |
0 |
0 |
0 |
|
15 |
Mar, 2022 |
0 |
0 |
0 |
0 |
|
16 |
Apr, 2022 |
0 |
0 |
0 |
0 |
|
17 |
May, 2022 |
0 |
0 |
0 |
0 |
|
18 |
Jun, 2022 |
0 |
0 |
0 |
0 |
|
19 |
Jul, 2022 |
0 |
0 |
0 |
0 |
|
20 |
Aug, 2022 |
0 |
0 |
0 |
0 |
|
21 |
Sep, 2022 |
0 |
0 |
0 |
0 |
|
Grand Total |
0 |
0 |
0 |
0 |
*Inclusiveof complaints of previous months resolved in the current month.
#Inclusiveof complaintspending as on the last day of the month.
|
SN |
Year |
Carried forward from previous year |
Received |
Resolved* |
Pending# |
|
1 |
2020-21 |
0 |
0 |
0 |
0 |
|
2 |
2021-22 |
0 |
0 |
0 |
|
|
3 |
2022-23 |
0 |
0 |
0 |
|
|
GrandTotal |
0 |
0 |
0 |
0 |
*Inclusiveof complaints of previous years resolved in the current year.
#Inclusiveof complaintspending as on the last day of the year.
Contact us directly at info@wrightresearch.in for assistance with any queries, complaints or grievances. We will ensure your grievance is resolved within 30 days. If you feel that your grievance is not redressed satisfactorily, you may lodge a complaint with SEBI through the Scores website or the SEBI Scores app for Android or iOS.
|
Sr.No. |
Month |
Carried forward from previous month |
Received |
Resolved* |
Pending# |
|
1 |
Jan, 2021 |
0 |
0 |
0 |
0 |
|
2 |
Feb, 2021 |
0 |
0 |
0 |
0 |
|
3 |
Mar, 2021 |
0 |
0 |
0 |
0 |
|
4 |
Apr, 2021 |
0 |
0 |
0 |
0 |
|
5 |
May, 2021 |
0 |
0 |
0 |
0 |
|
6 |
Jun, 2021 |
0 |
0 |
0 |
0 |
|
7 |
Jul, 2021 |
0 |
0 |
0 |
0 |
|
8 |
Aug, 2021 |
0 |
0 |
0 |
0 |
|
9 |
Sep, 2021 |
0 |
0 |
0 |
0 |
|
10 |
Oct, 2021 |
0 |
0 |
0 |
0 |
|
11 |
Nov, 2021 |
0 |
0 |
0 |
0 |
|
12 |
Dec, 2021 |
0 |
0 |
0 |
0 |
|
13 |
Jan, 2022 |
0 |
0 |
0 |
0 |
|
14 |
Feb, 2022 |
0 |
0 |
0 |
0 |
|
15 |
Mar, 2022 |
0 |
0 |
0 |
0 |
|
16 |
Apr, 2022 |
0 |
0 |
0 |
0 |
|
17 |
May, 2022 |
0 |
0 |
0 |
0 |
|
18 |
Jun, 2022 |
0 |
0 |
0 |
0 |
|
19 |
Jul, 2022 |
0 |
0 |
0 |
0 |
|
20 |
Aug, 2022 |
0 |
0 |
0 |
0 |
|
21 |
Sep, 2022 |
0 |
0 |
0 |
0 |
|
Grand Total |
0 |
0 |
0 |
0 |
*Inclusiveof complaints of previous months resolved in the current month.
#Inclusiveof complaintspending as on the last day of the month.
|
SN |
Year |
Carried forward from previous year |
Received |
Resolved* |
Pending# |
|
1 |
2020-21 |
0 |
0 |
0 |
0 |
|
2 |
2021-22 |
0 |
0 |
0 |
|
|
3 |
2022-23 |
0 |
0 |
0 |
|
|
GrandTotal |
0 |
0 |
0 |
0 |
*Inclusiveof complaints of previous years resolved in the current year.
#Inclusiveof complaintspending as on the last day of the year.
Contact us directly at info@wrightresearch.in for assistance with any queries, complaints or grievances. We will ensure your grievance is resolved within 30 days. If you feel that your grievance is not redressed satisfactorily, you may lodge a complaint with SEBI through the Scores website or the SEBI Scores app for Android or iOS.
