Policies

The Wright Research and its subsidiaries (“Wright Research”, “we” or “us”) welcome you to our website, mobile applications and other services provided via electronic means (together referred to as “Electronic Services”) and appreciate your interest in our products and services.

Wright Research attaches importance to appropriate data protection. This page explains how we treat your personal data in connection with your use of our Electronic Services (“Privacy Policy”).

By continuing to use the Wright Research Electronic Services, you confirm that you are 18 years of age or older. Please note that we may amend this Privacy Policy from time to time. The applicable version is always the current one, as referenced above.

Disclosures

For disclosures refer to disclosures

Purpose and scope of the privacy policy

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.

Types of data being processed

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..

Legal grounds and purpose of data processing

We process the data based on the following legal grounds:

• For the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
• For compliance with a legal obligation to which we are subject;
• For the purposes of our legitimate interests.

We process the data for the following purposes:

• To comply with bank’s own internal guidelines;
• To check the identity and suitability of clients for certain products and services;
• To establish a basis for future information on the products and services offered by Wright Research and to improve their quality;
• To facilitate technical administration, research and further development in connection with the Wright Research Electronic Services;
• To ensure the security and operation of our IT environment;
• To use it for marketing and advertising measures (e.g. newsletters via e-mail, online advertising);
• To analyse and monitor the usage, user behaviour and navigation while using the Electronic Services;
• To facilitate client administration.

We process all your personal data in accordance with the applicable laws on data protection and for as long as required.

Disclosure of electronic services usage data

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.

Security measures of Wright Research

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.

Additionally, access to personal data is restricted to only those employees, contractors and third parties who require this access in order to assure the purpose of data processing and the provision of products and services (need to know principle).

Transmission of data via an open network

Wright Research would like to draw your attention to the fact that if you use our Electronic Services via an open network, this may allow third parties (e.g. app stores, network providers or the manufacturer of your device), wherever they are located, to access and process your data. Open networks are beyond Wright Research’s control and can therefore not be regarded as a secure environment. Any transmission of data via such open network cannot be guaranteed to be secure or error-free as data may be intercepted, amended, corrupted, lost, destroyed, arrive late or incomplete, contain viruses or may be monitored. In particular, data sent via an open network may leave the country – even where both sender and recipient are in the same country – and may be transmitted to and potentially processed in third-party countries, where data protection requirements may be lower than in your country of residence.

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.

Cookies

The Wright Research Electronic Services use cookies for statistical purposes as a tool for our web developers and to improve the user experience. Cookies are small files which are stored on your electronic device to keep track of your visit to the Electronic Services and your preferences; as you move between pages, and sometimes to save settings between visits. Cookies help the builders of Electronic Services gather statistics about how often people visit certain areas of the site, and help in tailoring Electronic Services to be more useful and user-friendly.

Please note that most web browsers accept cookies automatically. You can configure your browser to not save any or only certain cookies on your electronic device or to always display a warning before receiving a new cookie. Deactivating cookies can, however, prevent you from using certain functions on our Electronic Services.

Remark: For some Electronic Services, cookies are only persistent during user session and will be deleted after the session is terminated.

Analysis tools

We use various analysis tools from third parties such as Google Analytics for the purpose of reporting for Electronic Services. This involves the creation of pseudo-anonymised data and use of cookies to help analyse how users use our Electronic Services. The information about your use generated by these cookies, such as the

• host name of the accessing electronic device (masked IP address)
• type/version of browser used
• operating system
• referrer URL (website from which visitors are redirected to the Wright Research Electronic Services by clicking a link)
• date and time of server request
• device-specific information

may be transmitted to third party servers located in countries and is used for analysis purposes.

Please refer to the previous section, “Cookies”, for information on deleting cookies.

Links

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.

Data subject rights

According to applicable data protection laws and regulations, you may have the following rights:

• requesting information on personal data that we hold about you,
• demanding that the information be rectified should it be incorrect,
• asking that your data be deleted if the Bank is not permitted or is not legally obliged to retain the data,
• demanding that the processing of your data be restricted,
• objecting to the processing by us,
• transferred in a generally useable, machine-readable, and standardised format.

You also have a right of appeal (as far as this affects you) to the respective Data Protection Supervisory Authority.

Questions / Contact

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

1. Disclosure

For disclosures refer to disclosures

2. Agreement

By using the website www.wrightresearch.in and any of its pages (hereafter the “Site”), you confirm that you have reviewed, understand and agree to the following important legal information and terms of use (the “Terms”). If you do not agree to the Terms, please exit the Site immediately.

The Terms are subject to change at any time without notice and access to, and use of the Site may be restricted or terminated at any time. You are therefore advised to review these terms each time you access this website.

Access to and use of the Site as well as the Terms are governed by India law. The place of jurisdiction is Mumbai.

Further access to the website might also be subject to the laws applicable in the relevant jurisdiction from which the same is being accessed.

3. No offer, no advice

The information, products, data, services, tools and documents contained or described on this site (the “Content”) are for information purposes only and constitute neither an advertisement or recommendation nor an offer or solicitation to buy or sell investment instruments, to effect any transaction or to enter into any legal relations.

The financial products mentioned on this site are not suitable for all investors. Prior to making investment decisions investors should conduct a thorough investigation and obtain all necessary professional advice for all issues, including your eligibility to make such investment in terms of the applicable law.

Nothing on this site constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate for individual circumstances, or otherwise constitutes a personal recommendation for any specific in­vestor. Wright Research recommends that investors independently assess, with a professional advisor, the specific financial risks as well as legal, regulatory, credit, tax and accounting consequences.

4. Local legal restrictions

The Content is not intended for use by or distribution to any individual or legal entity in any jurisdiction or country where such distribution, publication or use would be contrary to the law or regulatory provisions or in which members of the Group of Companies controlled by Wryght Research & Private Ltd. (individually and together “Wright Research”) does not hold the necessary registration or license. Individuals or legal entities in respect of whom such prohibitions apply, whether on grounds of their nationality, their place of residence or on other grounds, must not access or use the site.

5. No warranty

Wright Research provides no warranty and makes no representations of any kind whatsoever regarding: (1) the currency, accuracy or completeness of the content; (2) the results to be obtained by any user of the Site; or (3) any third party content accessible on or through the Site.

Except to the extent required by current laws and/or regulations, Wright Research, including its directors, agents, employees or subcontractors: (1) disclaims any and all express or implied warranties and conditions including without limitation warranties and conditions as to quality and fitness for a particular purpose; and (2) does not warrant that the Site, any content (including any third party content), goods and services referred to therein will be uninterrupted or error free, that defects will be corrected or that the Site, the servers from which it is available or any connected website is free of viruses, trojan horses, worms, software bombs or similar items or processes or other harmful components. In order to safeguard against viruses, it is advisable to use up-to-date versions of browsers and to install and continuously update antivirus software. Users should strictly avoid opening e-mails of unknown origin or unexpected e-mail attachments.

Any data, including but not limited to financial market data, quotes, notices, research or other financial information accessible through this Site, have been obtained from carefully selected sources believed to be reliable. All such information is provided “as is” to the user without express or implied warranties of any kind, including warranties of quality, originality, non-infringement of intellectual property or fitness for any particular purpose.

The information and opinions in the Site are descriptive of Wright Research as a whole and the products and services described may not be available to or suitable for all investors. The fact that a user accesses the Site does not make him a client of Wright Research and you are requested to refer to paragraph 3 above.

Any expressions of opinion, estimates and projections on the Site are those of the authors at the date of writing. They do not necessarily reflect the view of Wright Research and are subject to change at any time without prior warning. Wright Research and its contractual partners may discontinue, or make changes in, the information, data and documents, and the products or services described herein, at any time without prior notice. Any information marked with a date is published as of this date only and no obligation or responsibility is undertaken to update or amend any such information.

6. No liability

To The Maximum Extent Permitted By Current Laws And/Or Regulations, Wright Research, Including Its Directors, Agents, Employees, Sub-contractors And Its Sales Partners Disclaim Any And All Liability For Losses Or Damages (Direct Or Indirect) Of Any Kind Whatsoever Arising Directly Or Indirectly As A Result Of (1) The Content, Accuracy, Completeness Or Otherwise Of The Content Or Any Links Or Third Party Content; (2) Any Errors In Or Omissions From The Site; (3) Use Of Or Access To The Site; (4) Any Inability To Access Or Use The Website For Any Reason.

To The Full Extent Permitted By Current Laws And/Or Regulations, Wright Research Shall Not Be Liable For Any (1) Loss Of Profits Or Revenue Or Savings Or Other Economic Loss, (2) Loss Of Business Or Goodwill, (3) Loss Of Or Damage To Data, (4) Incidental Or Special Loss, (5) Wasted Or Lost Management Time, Or (6) Indirect Or Consequential Loss Arising From Use Of Or Access To The Site, Even If Advised Of The Possibility Of Any Such Loss Or Damage Or If Such Loss Or Damage Was Foreseeable.

7. Proprietary information

Unless accompanied by an explicit statement to the contrary, all content on this Site is protected by copyright, database rights, or other intellectual property rights, and is the property of Wright Research.

Except as otherwise specifically agreed in writing or to the extent necessary to use the Site in accordance with these Terms, you shall not: (1) copy the Site in whole or in part (except to make backup copies solely for disaster recovery purposes); (2) display, reproduce, create derivative works from, transmit, sell, distribute, rent, lease, sublicense, time-share, lend or transfer or in any way exploit the Site in whole or in part; (3) embed the Site into other products; (4) use the Site in any timesharing arrangement; (5) create function calls or other embedded links from any software program to the Site; (6) remove or obscure any copyright notice of Wright Research or any of its suppliers; (7) use any trademarks, service marks, domain names, logos, or other identifiers of Wright Research or any of its third party suppliers; or (8) save to the extent permitted under by law, reverse engineer, decompile, disassemble, or access the source code of the Site.

Nothing on the Site is designed to grant any license or right to use any image, trademark or logo. No act of downloading or otherwise copying from the Site will transfer any legal entitlement to any software or material on the Site to you. Wright Research reserves all intellectual property rights (such as copyright and trademark rights) to all material on the Site, and will enforce such rights to the full extent of applicable law.

8. Third-party content

Statements on this site may contain information obtained from third parties, including ratings from rating agencies such as Standard & Poor’s, Moody’s, Fitch and other similar rating agencies, and research from research providers Reproduction and distribution of third-party content in any form is prohibited except with the prior written permission of the related third party. Third-party content providers do not guarantee the accuracy, completeness, timeliness or availability of any information, including ratings or research, and are not responsible for any errors or omissions (negligent or otherwise), regardless of the cause, or for the results obtained from the use of such content. Third-party content providers give no express or implied warranties, including, but not limited to, any warranties of merchantability or fitness for a particular purpose or use. Third-party content providers shall not be liable for any direct, indirect, incidental, exemplary, compensatory, punitive, special or consequential damages, costs, expenses, legal fees or losses (including lost income or profits and opportunity costs) in connection with any use of their content, including ratings or research. Credit and/or research ratings are statements of opinions and are not statements of fact or recommendations to purchase, hold or sell securities. They do not address the market value of securities or the suitability of securities for investment purposes and should not be relied on as investment advice.

9. Material interests

Wright Research and/or its board of directors, executive management and employees may have or have had interests or positions or traded or acted as market makers in securities referred to on the Site. Furthermore, such entities or persons may have or have had a relationship with or may provide or have provided corporate finance or other services to or serve or have served as directors of companies referred to on the Site.

10. Performance

The past is not an indication of the future performance of an investment. The value of investments may be subject to fluctuations and investors may not get back the amount invested. Changes in rates of foreign exchange may also cause the value of investments to go up or down.

11. Monitoring

Please note that all your actions while using this Site may be recorded and analyzed for various purposes, including security, marketing and system monitoring purposes.

12. Links to third-party websites

Links to third-party websites on the Site are provided solely for your convenience as pointers to information on topics that may be useful to users of the Site. Wright Research has no control over the content on such third-party websites nor are such websites monitored by Wright Research. Activating some links to third-party websites on this Site may cause you to leave this Site. No warranties or liability concerning the content of such websites are made, including assurances that it is correct, accurate, complete, true, up-to-date or fit for any particular purpose. Nor does Wright Research warrant that such website or content is free from any claims of copyright or trademark or other infringement of the rights of third parties or that such site or content is free of viruses or other harmful components. No guarantee as to the authenticity of documents on the Internet is given.

Using links to third-party websites provided on this Site is at your sole discretion and at your own risk.

Please note that third-party websites are not subject to Wright Research data protection policy and Wright Research is not responsible for the policies they apply with regard to collection and treatment of your personal data. We recommend that you carefully read the terms of use and data protection policies governing the third-party website before using it in order to check how it protects your personal data and privacy.

13. Data processing

For information on the kind of data collected, the purpose for which it is collected, how it is processed, to whom it may be disclosed and the security measures that have been put in place to protect it, please consult the Wright Research Data Privacy Policy under the following link:

Data Privacy Policy

14. Derivatives, research

This Site contains information on derivatives and research material. You will only be able to access detailed information on these subjects after indicating your country of origin. You will then be given access to information on derivatives and research material of Wright Research authorized for distribution in your jurisdiction. When obtaining access to such information you are required to pay particular attention to any accompanying legal information.

15. Assignment, Subcontracting and Delegation

These Terms are for the benefit of Wright Research its successors and assigns. Wright Research may assign or transfer any of its rights under these Terms. Wright Research may delegate or subcontract the performance of any obligation under these Terms.

16. Refund/Cancellation Policy

You can cancel your membership any time by contacting our team at info@wrightresearch.in and get a refund. You will be refunded the subscription amount only on pro-rata basis from the date you submit for cancellation and refund. Allotment/ Refund time of response – 10 working days

Private & Confidential

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 

Objective

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:

• Issues raised by investors are dealt with courtesy and are resolved on time.
• The Company will treat all the complaints efficiently and fairly without any bias.

Definitions:

• Investors: shall mean an individual, entity, body corporate or such other person who shall be an investor in securities 
• Complaint or grievance: is “An expression of dissatisfaction made by the Investor related to the services of Wright Research”. This however needs to be differentiated from matters like from general feedback, enquiry before the due date.
• Client/ Customer: shall mean client/ customer of Wright Research
• Redressal: can be defined as a process or action resulting in giving solution to the problem faced by an Investor

Guiding Principles

• Transparency: The “Investor” to be provided with information regarding the channels to convey and resolve their issues. In addition, if the resolution is expected to take longer time, same should be communicated to the Investor.

2. Accessibility: The Company will enable the Investors to communicate their complaints/issues and avail redressal services through multiple channels.
3. Escalation: Information on the process of escalation of complaints to higher level, in case the Investor is not satisfied with the resolution provided by the current person handling the same.

Greivance Redressal Policy Registration of Complaints

The various channels available to Investors for registering the complaints are as follows:

• SEBI Complaints Redress System (SCORES)- SEBI maintains SCORES which is a web based centralized grievance redressal system of SEBI. Investors can lodge their grievances / complaints through the SCORES link available on the SEBI website. SCORES enables investors to lodge and follow up their complaints and track the status of redressal of such complaints online from the above website from anywhere. Investors can also lodge grievances / complaints in physical form at any of the offices of SEBI. Such grievances complaints would be scanned and uploaded in SCORES for processing.
• E-Mail or Fax: Investors can log their complaint or escalate the investor grievance to an email id titledinfo@wrightresearch.in
• Grievance Redressal Officer: Investors can contact the Compliance Officer for redressal of issues.

Resolution of Complaints Responsibility

• Primary responsibility is with the Compliance Officer to resolve the complaint for which he would

liaise with the other relevant departments (like Investment Advisory, Operations, Accounts, Legal, Compliance etc).

• If the issue cannot be resolved by the Compliance Officer, the same will be escalated to the Senior Management
• All complaints received shall be recorded internally including how the same has been resolved

Time for Response

General Turn Around Time (TAT) for response to complaint is (from the receipt of the valid complaint in writing):

• Allotment/ Refund related – 10 working days
• Legal notices – 30 working days
• Cases involving third party- 30 working days
• Fraud related – 45 working days
• All other cases- 30 working days
• Scores related- as specified by the regulator from time to time

Note: The above TAT can change depending upon the nature and complexity of complaint.

Escalation of Complaints

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

Statement of General Policy

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:

• The duty to have a reasonable, independent basis for the investment advice provided;
• The duty to obtain best execution for a client’s transactions where the Firm is in a position to direct brokerage transactions for the client;
• The duty to ensure that investment advice is suitable to meeting the client’s individual objectives, needs and circumstances; and
• A duty to be loyal to 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.

Code of Conduct for Investment Advisor

1. Honesty and fairness

An investment adviser shall act honestly, fairly and in the best interests of its clients and in the integrity of the market.

2. Diligence

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.

3. Capabilities

An investment adviser shall have and employ effectively appropriate resources and procedures which are needed for the efficient performance of its business activities.

4. Information about clients

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.

5. Information to its clients

An investment adviser shall make adequate disclosures of relevant material information while dealing with its clients.

6. Fair and reasonable charges

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.

7. Conflicts of interest

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.

8. Compliance

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.

9. Responsibility of senior management

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.

Introduction

• The Prevention of Money Laundering Act, 2002 (PMLA) has been brought into force with effect from 1st July, 2005. Necessary Notifications /Rules under the said Act have been published in the Gazette of India on 1stJuly 2005 by the Department of Revenue, Ministry of Finance, Government of India.

• As per PMLA, every banking company, financial institution (which includes Chit Fund company, a co-operative bank, a housing finance institution and non-banking financial company) and Intermediary (which includes stock-broker, sub-broker, share transfer agent, banker to an issue, trustee to a trust deed, registrar to an issue, merchant banker, underwriter, Portfolio Manager, Investment adviser and any other intermediary Associated with securities market and registered under section 12 of the Securities and Exchange Board of India Act, 1992) shall have to maintain a cord of all the transactions, the nature and value of which has been prescribed in the Rules notified under the PMLA. For the purpose of PMLA, transactions include:

• All cash transactions of the value of more than Rs.10 lakhs or its equivalent in foreign currency.
• All series of cash transactions integrally connected to each other, which have been valued below Rs.10 lakhs or its equivalent in foreign currency, such series of transactions within one calendar month.
• All suspicious transactions whether or not made in cash and including inter-alia, credits or debits into from any non monetary account such as Demat account, security account maintained by the registered intermediary.

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 –

• Gives rise to a reasonable ground of suspicion that it may involve the Proceeds of crime; or

• Appears to be made in circumstances of unusual or unjustified complexity; or
• Appears to have no economic rationale or bonafide purpose

• The Anti-Money Laundering Guidelines provides a general background on the subjects of money laundering and terrorist financing in India and provides guidance on the practical implications of the PMLA. The PMLA Guidelines sets out the steps that a registered intermediary and any of its representatives need to implement to discourage and identify any money laundering or terrorist financing activities.

Objective

The main objectives of the PMLA are as follows:

• To have a proper Customer Due Diligence (CDD) process before registering clients.
• To monitor / maintain records of all cash transactions of the value of more than Rs.10 lacs.
• To maintain records of all series of integrally connected cash transactions within one calendar month. 
• To monitor and report suspicious transactions.
• To discourage and identify money laundering or terrorist financing activities.
• To take adequate and appropriate measures to follow the spirit of the PMLA.

Guidelines

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':

• Policy for acceptance of clients;
• Procedure for identifying the clients;
• Transaction monitoring and reporting especially Suspicious Transactions Reporting (STR).

Client / Customer Due Diligence (CDD):

For the purpose of CDD, Broker is dealing with institutional clients. According to SEBI regulation / rules Institutional clients includes:

• Banks
• Mutual Funds
• Foreign Institutional Investors (FII)
• Financial Institutions
• Insurance Companies

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:

• Obtain basic details for the purpose of complying with KYC norms prescribed by SEBI.
• List of Directors and authorized person to trade on behalf of client and copy of Board resolution to that effect.
• Obtain SEBI registration number.
• Custodian details with whom clients trade to be settled.
• Obtain contact details of client front / back office and contact person.
• Obtain PAN NO. (Income Tax number).
• Obtain risk Disclosure Document duly executed by prospective client as prescribed by SEBI.

The client / customer due diligence (CDD) measures comprise the following:

Client Information & Identity:

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.

Beneficial Ownership and control:

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.

Ongoing due diligence and scrutiny:

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.

Policy for acceptance of clients:

Before registering client, we need to identify the following details of the prospective client:

• Ascertain the category of clients before registration as Client. (i.e. Individual or Corporate, FII, Mutual Fund, PMS or other).
• Obtain all necessary documents for registration. (Photograph, Photo Identity, Proof of Address, copy of PAN, etc.). Documents should be verified with original and same to be counter signed by Authorized representative of the organization.
• Obtain a copy of Bank Statement for ascertaining the mode of payment of transaction.
• Registration of clients to be made on the physical presence of the prospective client.
• Obtain antecedent details of the prospective client.
•  Ensure that new registration is to be made in clients name only.
• Ensure that the account should not open in a fictitious or benami name.
• Client's occupation, sources of income.
• Determine the parameter to categories of client as per risk.
• Obtain financial statements for at least for the last 2 years duly certified by Chartered Accountants.
• Ensure that all details of KYC form should be complete in all respect Incomplete KYC should not accept by organization.
• Organization should not register clients in case any kind of doubt has been raised by the client (i.e. unable to submit required form/proof, any suspicious behavior noticed at the time of registration, etc.)
• Account should not open where the organization cannot apply Customer Due Diligence / KYC policies.
• The client's account should be scrutinized regularly for determining the nature of the transaction taking place. In case of any suspicious transaction, the account should be freezer or securities / money should not be delivered to client.

The following safeguards are to be followed while accepting the clients:

• The client account should not be opened in a fictitious / benami name or on an Anonymous basis.
• Risk perception of the client need to defined having regard to :
• Client's' location (registered office address, correspondence addresses and Other addresses if applicable);
• Nature of business activity, tracing turnover etc. and
• Manner of making payment for transactions undertaken.

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.

• Documentation like KYC, Broker-client agreement and Risk Disclosure Document and other information from different category of client prescribed by SEBI and any other regulatory authority to be collected depending on perceived risk and having regard to the requirement to the Prevention of Money Laundering Act, 2002,guidelines issued by RBI and SEBI from time to time.

• Ensure that a client account is not opened where the organization is unable to apply appropriate client's due diligence measures / KYC policies. This may be applicable in cases where it is not possible to ascertain the identity of the client, information provided to the organization is suspected to be non-genuine, perceived non-co-operation of the client in providing full and complete information. Discontinue to do business with such a person and file a suspicious activity report.

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.

• We need to comply with adequate formalities when a client is permitted to act on behalf of another person / entity. It should be clearly specified the manner in which the account should be operated, transaction limits for the operation, additional authority required for transactions exceeding a specified quantity /value and other appropriate details. The rights and responsibilities of both the persons (i.e. the agent-client registered with Broker, as well as the person on whose behalf the agent is acting) should be clearly laid down. Adequate verification of a person's authority to act on behalf of the customer should be carried out.

• Necessary checks and balances to be put in place before opening an account so as to ensure that the identity of the client does not match with any person having known criminal background or is not banned in any other manner, whether in terms of criminal or civil proceedings by any enforcement agency worldwide.

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:

• Non-resident clients (NRI);
• High Net worth clients (HNI)
• Trust, Charities, NGOs and organizations receiving donations.
• Companies having close family shareholdings or beneficial ownership.
• Politically exposed persons (PEP) of foreign origin
• Current /Former Head of State, Current or Former Senior High profile politicians and connected persons (immediate family, close advisors and companies in which such individuals have interest or significant influence);
• Companies offering foreign exchange offerings;
• Clients in high risk countries (where existence / effectiveness of money laundering controls is suspect, where there is unusual banking secrecy. Countries active in narcotics production, Countries where corruption (as per Transparency International Corruption Perception Index) is highly prevalent, Countries against which government sanctions are applied, Countries reputed to be any of the following -- Havens / sponsors of international terrorism, offshore financial centers, tax havens, countries where fraud is highly prevalent;
• Non-face to face clients;
• Clients with dubious reputation as per public information available etc.

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.

Client identification procedure:

To follow the Client Identification procedure we need to follow the following

Factors:

• The `Know Your Client' (KYC) policy should be strictly observed with respect to the client identification procedures which need to be carried out at different states i.e. while establishing the Broker – client relationship, while carrying out transactions for the client or when have any doubts regarding the veracity or the adequacy of previously obtained client identification data.
• The client should be identified by using reliable sources including documents / information. Obtain adequate information to satisfactorily establish the identity of each new client and the purpose of the intended nature of the relationship.
• The information should be adequate enough to satisfy competent authorities (regulatory / enforcement authorities) in future that due diligence was observed in compliance with the Guidelines. Each original document should be seen prior to acceptance of a copy and it is verified and duly attested.
• Failure by prospective clients to provide satisfactory evidence of identity should be noted and reported to the higher authority within the organization.
• SEBI has prescribed the minimum requirements relating to KYC for certain classes of the registered intermediaries from time to time. Taking into account the basic principles enshrined in the KYC norms, internal guidelines should be followed in dealing with clients and legal requirements as per the established practices. Also maintain continuous familiarity and follow-up where it notices inconsistencies in the information provided by the client. The principles enshrined in the PML Act, 2002 as well as the SEBI Act, 1992 should be followed, so that Company is aware of the clients on whose behalf it is dealing

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.

• The beneficial owner of the account;
• The volume of the funds flowing through the account; and
• For selected transactions:

• The origin of the funds;
• The form in which the funds were offered or withdrawn, e.g cash, cheques, etc;
• The identity of the person undertaking the transaction;
• the destination of the funds;
• The form of instruction and authority.

Organization should ensure that all client and transaction records and information are made available on a timely basis to the competent investigating authorities.

Retention of Records:

The following document retention terms should be observed:

• All necessary records on transactions, both domestic and international, should be Maintained at least for the minimum period of ten years (10) from the date of Cessation of the transaction.
• Records on customer identification (e.g. copies or records of official identification documents like passports, identity cards, driving licenses or similar documents), account files and business correspondence should also be kept for the ten years from the date of cessation of the transaction.
• Records shall be maintained in hard and soft copies.

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

.

Suspicious Transaction Monitoring & Reporting:

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:-

• Clients whose identity verification seems difficult or clients appear to be not cooperating.

• Asset management services for clients where the source of the funds is not clear Or not in keeping with client's apparent standing / business activity;

• Clients in high -risk jurisdictions or clients introduced by banks or affiliates or other Clients based in high risk jurisdictions;

• Substantial increases in business without apparent cause.

• Unusually large cash deposits made by an individual or business;

• Clients transferring large sums of money to or from overseas locations with Instructions for payment in cash;

• Transfer of investment proceeds to apparently unrelated third parties;

• Unusual transactions by “Client of special category (CSCs)” and businesses Undertaken by shall corporations, offshore banks / financial services, business Reported to be in the nature of export-import of small items.

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.

Principal Officer Designation and duties:

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.

Sonam Srivastava

(Principal Officer)

Trend of monthly disposal of complaints

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.

Trend of annual disposal of complaints

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.