Portfolio Management Services disclosures

Wryght Research & Capital Pvt Ltd is registered with SEBI as a Portfolio Manager with INP000007979 as the SEBI registration number (valid from Apr 03, 2023, perpetual). The registered office address of Wryght Research & Capital Pvt Ltd is 102, Shagun Vatika, Prag Narayan Road, Lucknow 226001, India. The CIN number of the company is U67100UP2019PTC123244.

The full Disclosure Document for the Portfolio Management Services of Wryght Research & Capital Private Limited, prepared in accordance with the SEBI (Portfolio Managers) Regulations, 2020, can be downloaded below.

Download the PMS Disclosure Document (PDF)

Investments in securities market are subject to market risks. Read all the related documents carefully before investing. Registration granted by SEBI, enlistment with BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

Annexure A

Investor Charter in Respect of Portfolio Management Services

A. Vision and Mission Statements for investors

Vision:
To implement diligently researched customised investment strategies which help investors meet their long-term financial goals in a risk appropriate manner.

Mission:
To ensure that the PMS industry provides a viable investment avenue for wealth creation by adopting high levels of skill, integrity, transparency and accountability.

B. Details of business transacted by the organization with respect to the investors

1. Appropriate risk profiling of investors.
2. Providing the Disclosure Document to investors.
3. Executing the PMS agreement.
4. Making investment decisions on behalf of investors (discretionary) or investment decisions at the discretion of the investor (non-discretionary) or advising investors regarding their investment decisions (advisory), as applicable.

C. Details of services provided to investors and estimated timelines

1. Discretionary & Non-Discretionary Portfolio Management Services (PMS)
   Under these services, the investor may provide portfolio assets in stocks, cash, or a combination of both. The minimum size of portfolio under discretionary and/or non-discretionary portfolio management services is Rs. 50 lakhs as per current SEBI Regulations. The PMS provider reserves the right to prescribe a higher threshold product-wise or otherwise, at its sole discretion.
   The PMS provider ascertains the investor's objectives to seek optimal returns in line with risk profile. Under discretionary PMS, investment decisions are taken by the PMS provider in line with investor objectives. Under non-discretionary PMS, investment decisions are taken at the investor's discretion.
2. Investment Advisory Services
   Under these services, the client is advised on buy/sell decisions within the overall profile, without back-office responsibility for trade execution, custody of securities, or accounting functions. The PMS provider acts solely as advisor and is not responsible for execution/divestment and administrative activities on the client's portfolio. The PMS provider acts in fiduciary capacity and maintains arm's-length relationship with other activities, in line with applicable regulatory directives.
3. Client On-boarding
   1. Ensuring compliance with KYC and AML guidelines.
   2. Franking and signing the Power of Attorney to make investment decisions on behalf of the investor.
   3. Opening demat account and funding from investor's verified bank account and/or transfer of securities from investor's verified demat account.
   4. Mapping the demat account with custodian.
4. Ongoing activities
   1. Providing periodic statements to investors under PMS Regulations 2020 and other SEBI notifications/circulars.
   2. Providing each client an audited account statement annually, including details required under PMS Regulations.
5. Fees and Expenses: Charging and disclosure of fees and expenses in accordance with PMS Regulations.
6. Closure and Termination: Upon termination of PMS agreement by either party, securities and funds in investor account are transferred to investor's verified bank/demat account.
7. Grievance Redressal: Addressing investor queries, service requests, and grievances in a time-bound manner on an ongoing basis.

Note: Number of days in service timelines are interpreted as clear working days.

D. Details of grievance redressal mechanism and how to access it

1. Every PMS provider must register on SEBI SCORES (SEBI Complaint Redress System), a centralized online complaint resolution platform: https://scores.sebi.gov.in.
2. The PMS Disclosure Document should provide details of the investor relations officer (name, address, telephone) attending investor queries and complaints.
3. The grievance redressal and dispute resolution mechanism should be clearly mentioned in the Disclosure Document.
4. Investors may approach SEBI for redressal of complaints. SEBI follows up with the concerned PMS provider upon receipt of complaints.
5. Investors may also write to: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, G Block, Bandra-Kurla Complex, Bandra (E), Mumbai - 400051.

E. Expectations from the investors (Responsibilities of investors)

1. Check registration status of the intermediary on SEBI website before availing services.
2. Submit KYC documents and application form in a timely manner with signatures and required supporting documents.
3. Read terms and conditions of the agreement carefully before signing.
4. Study the PMS Disclosure Documents thoroughly to understand risks associated with PMS investments.
5. Provide accurate and sincere responses in the Risk Questionnaire to help proper risk assessment.
6. Review quarterly statements shared by PMS provider on portfolio performance, constituents, and risk profile.
7. Provide complete and timely negative-list/freeze instructions at agreement time and for any subsequent changes.
8. Update PMS provider in case of changes in KYC and personal details, with supporting proof.

Client’s queries / complaints may arise due to lack of understanding or a deficiency of service experienced by clients. Deficiency of service may include lack of explanation, clarifications, understanding which escalates into shortfalls in the expected delivery standards, either due to inadequacy of facilities available or through the attitude of staff towards client.

• Clients can seek clarification to their query and are further entitled to make a complaint in writing, orally or telephonically. An email may be sent to the Client Servicing Team on info@wrightresearch.in. Alternatively, the Investor may call on +91 6360127635
• A letter may also be written with their query/complaint and posted at the below mentioned address: Wright Research, The Capital 815A/B-Wing, opp. ICICI Bank, G Block BKC, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051
• Clients can write to the Compliance Officer at lovish@wrightresearch.in if the Investor does not receive a response within 10 business days of writing to the Client Servicing Team. The client can expect a reply within 10 business days of approaching the Compliance Officer.
• In case you are not satisfied with our response you can lodge your grievance with SEBI at https://scores.sebi.gov.in/ or you may also write to any of the offices of SEBI. SCORES may be accessed thorough SCORES mobile application as well, same can be downloaded from below link: https://play.google.com/store/apps/details?id=com.sebi&hl=en_IN

Trend of monthly disposal of complaints

Month Complaints

*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

*Inclusiveof complaints of previous years resolved in the current year.

#Inclusiveof complaintspending as on the last day of the year.

Investor Grievance Redressal Policy of Wryght Research & Capital Private Limited — SEBI Registered Research Analyst (Reg. No. INH000017295) and SEBI Registered Portfolio Manager (Reg. No. INP000007979).

1. 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.

2. 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.
• Accessibility: The Company will enable the Investors to communicate their complaints/issues and avail redressal services through multiple channels.
• 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.

3. Grievance Redressal Policy — Registration of Complaints

Client’s queries / complaints may arise due to lack of understanding or a deficiency of service experienced by clients. Deficiency of service may include lack of explanation, clarifications, understanding which escalates into shortfalls in the expected delivery standards, either due to inadequacy of facilities available or through the attitude of staff towards client.

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 titled info@wrightresearch.in.
• Grievance Redressal Officer: Investors can contact the Compliance Officer for redressal of issues.

• Clients can seek clarification to their query and are further entitled to make a complaint in writing, orally or telephonically. An email may be sent to the Client Servicing Team on info@wrightresearch.in. Alternatively, the Investor may call on +91 6360127635.
• A letter may also be written with their query/complaint and posted at the below mentioned address: Wright Research, The Capital 815A/B-Wing, opp. ICICI Bank, G Block BKC, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051.
• Clients can write to the Compliance Officer at hello@wrightresearch.in if the Investor does not receive a response within 10 business days of writing to the Client Servicing Team. The client can expect a reply within 10 business days of approaching the Compliance Officer.

4. 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.
• In case of any grievance / complaint, an investor may approach the concerned Research Analyst who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.
• In case an investor is not satisfied with our response they can lodge their grievance with SEBI at https://scores.sebi.gov.in/ or they may also write to any of the offices of SEBI. SCORES may be accessed thorough SCORES mobile application as well, same can be downloaded from below link: https://play.google.com/store/apps/details?id=com.sebi&hl=en_IN.
• ODR Portal could be accessed, if unsatisfied with the response. Attention is drawn to the SEBI circular no. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023, on “Online Resolution of Disputes in the Indian Securities Market”. A common Online Dispute Resolution Portal (“ODR Portal”) which harnesses conciliation and online arbitration for resolution of disputes arising in the Indian Securities Market has been established. ODR Portal can be accessed via the following link — https://smartodr.in/.

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 the 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.

5. Grievance Redressal Mechanism for Accessibility Issues

In compliance with the SEBI circular, Wryght Research & Capital Pvt Ltd has established a dedicated grievance redressal mechanism to address accessibility-related complaints from persons with disabilities (PwDs).

Dedicated Channels

• Email: info@wrightresearch.in
• Helpline: +91-6360127635 (operational Mon–Fri, 9:30 AM – 6:00 PM)
• Web Form: https://help.wrightresearch.in/support/tickets/new

Process

• All accessibility-related grievances will be acknowledged within 2 working days.
• Resolution/response will be provided within 15 working days.
• Complex issues requiring longer timelines will be communicated clearly to the complainant.

Escalation Matrix for accessibility issues

• Level 1: Mr. Lovish Jain, Nodal Officer, Email: lovish@wrightresearch.in, Contact: +91-6360127635
• Level 2: Mr. Siddhesh More, Compliance Officer, Email: siddhesh@wrightresearch.in, Contact: +91-6360127635

6. Escalation Matrix

The detail of escalation matrix for investor queries and complaints is mentioned below: