General disclosures

Wryght Research & Capital Pvt Ltd (brand name: Wright Research) is registered with the Securities and Exchange Board of India (SEBI) as a Portfolio Manager and as a Research Analyst.

Entity at a glance

Entity name

Wryght Research & Capital Pvt Ltd

Brand name

Wright Research

CIN

U67100UP2019PTC123244

Nature of business

Portfolio Management Services (PMS) and Research Analyst (RA) services

Place of registration
Registered office

102, Shagun Vatika, Prag Narayan Road, Lucknow 226001, Uttar Pradesh, India

Place of business
Corporate office

The Capital 815A/B-Wing, opp. ICICI Bank, G Block BKC, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051, India

Licences held

Both registrations are perpetual: they do not carry an expiry date and remain in force unless surrendered by the company or suspended or cancelled by SEBI.

Customer support

Our customer support team is available Monday to Friday, 9:30 AM – 6:00 PM.

• Customer support helpline: +91 6360127635
• Accessibility helpline (persons with disabilities): +91 6360127635
• Client servicing e-mail: info@wrightresearch.in
• Customer care e-mail: hello@wrightresearch.in
• Support web form: help.wrightresearch.in

Principal Officer: Siddharth Singh Bhaisora, siddharth.bhaisora@wrightresearch.in. Compliance Officer: Siddhesh More, siddhesh@wrightresearch.in. Full escalation matrices are published under RA → Grievance Redressal Mechanism and PMS → Grievance Redressal Mechanism.

General disclosures

Disclaimer: Wryght Research & Capital Pvt (Brand name: Wright Research) is a SEBI Registered Portfolio Manager Reg No: INP000007979 (Validity: Apr 03, 2023 - Perpetual) and a SEBI Registered Research Analyst No: INH000017295 (Validity: Jul 03, 2024 - 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.

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. Securities quoted are for illustration only and are not recommendatory. For more information visit our website wrightresearch.in.

Investments in securities market are subject to market risks. Read all the related documents carefully before investing.

Regulatory and Compliance

Regulated entities, the nature of business carried on under each licence and the corresponding SEBI registration numbers.

Name of the entity	Nature of business	SEBI registered number
Wryght Research & Capital Pvt Ltd	Portfolio Management Services (Portfolio Manager)	INP000007979
Wryght Research & Capital Pvt Ltd	Research Analyst	INH000017295

Validity of each licence

Date of registration and expiry for each SEBI licence.

Licence	Registration number	Date of registration	Expiry
Portfolio Manager	INP000007979	Apr 03, 2023	Perpetual — does not expire unless surrendered, suspended or cancelled by SEBI
Research Analyst	INH000017295	Jul 03, 2024	Perpetual — does not expire unless surrendered, suspended or cancelled by SEBI

Where each licence applies on this website

• Research Analyst (INH000017295) — research reports, model portfolios, smallcase-style baskets and any securities analysis published by Wright Research. Disclosures for this licence are under the RA tab.
• Portfolio Manager (INP000007979) — discretionary, non-discretionary and advisory portfolio management services offered to clients with the minimum investment prescribed by SEBI. Disclosures for this licence are under the PMS tab.

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.

Each portfolio’s return is calculated from its Index value. To understand how index values are calculated and used to derive portfolio returns, please refer to following sections

What is an index value?

An index value allows the user to measure the change in the value of a portfolio relative to its value on a historical date. For example, let's assume that portfolio A was created on 1st Jan 2020. The index value of A on that day was 100. Suppose the index value of the portfolio on 31st March 2021 was 127. We can calculate the absolute return of A between the above-mentioned dates as (127/100)-1 * 100 = 27%.

How are portfolio index values calculated?

Lets understand this with an example. Portfolio TEST was created on 1st Jan 2014. The creator of the portfolio will rebalance TEST once in 3 months.Let's call the first version of TEST as TEST 1.0. The stocks and weights in TEST 1.0 portfolio are as below:

To calculate the index values, the portfolio creation date, constituents of the portfolio and their respective weights are required. On the date of creation of the portfolio, the index value is set to 100. This can also be understood as a hypothetical Rs.100 investment in TEST 1.0. The calculation on 1st Jan 2014 is as below:

Index value: 100

On 1st Jan 2014, the portfolio contained 4 stocks A, B, C and D. The weights of these stocks were 30%, 20%, 15% and 35% respectively. The closing prices of the stocks on that day is used to calculate the hypothetical number of shares that can be bought, assuming Rs.100 is invested in the portfolio. “100 * weight of the stock” will give the amount of money that can be invested in a specific stock. This number is divided by the closing price of the stock to derive the number of shares of that stock. Finally, by multiplying the number of shares of each stock with the stock’s closing price and adding the output for all the stocks, the index value is derived. Of course on the first day, the index value is the same as the amount invested, i.e 100.The number of shares of each stock will remain the same till the next rebalance date. Each trading day, the closing stock prices are multiplied by the number of shares. The sum of these data points will be the index value for that specific date.

How does rebalance affect the index value?

Rebalancing is the process of reviewing the stocks and their respective weights to ensure that it remains true to the theme or strategy of the portfolio.Continuing with the same example, let's assume The TEST portfolio gets rebalanced on 31st March 2014. The index values leading upto the rebalance date were as below:

In the rebalance, the weights of both A and D were reduced and a new stock E was added to the portfolio. Let’s call this new portfolio TEST 2.0. Post rebalance, the stocks and their corresponding weights were as below:

On 31st March, the Rs.100 that was initially invested in the portfolio had grown to Rs.112.65. The latter amount is the one that should be reinvested.A simple of way calculating the new number of shares is by multiplying 112.65 * weight of stocks in the rebalanced portfolio and dividing the output by closing price of the individual stocks. Continuing the earlier process, these new numbers of shares can be multiplied by the daily close price of respective stocks and their summation could be the new index value. The index values calculated using this method will be as below:

Index value: 112.65

However this methodology has limitations. Investors will be able to execute the trade only after the market opens the next day. It is unlikely that these trades will be executed at the previous day's close price. If the price of securities that the investor is buying goes up and the price of securities that the investor is selling goes down, then the investor's portfolio will underperform the our portfolio. If the scenario is reversed and the investor is able to buy at a lower price and sell at a higher price, then his/her portfolio will outperform the our portfolio. In order to lessen the impact of this issue and ensure that the investor's returns are in line with that of the our portfolio, we use the following methodology.The legend mentioned below should help readers follow the methodology.

T0 : Rebalance date, 31st March 2014 in this instance

T1 : Calendar day after rebalance date, 1st April 2014

V0 : portfolio version before rebalance, TEST 1.0

V1 : portfolio version after rebalance, TEST 2.0

OHLC average : Average of Open, High, Low and Close price of the stock on a particular trading day

1. Calculating intermediate index value on T1
   Intermediate index value = Sum of (No. of shares of each stock in V0 * OHLC average of the respective stock on T1)

2. Calculating the new number of shares for stocks in V1
   New no. of shares = (Intermediate index value * weight of the individual stock in V1) / OHLC average of the respective stock on T1
   Index value: 112.68

3. Calculating the final index value on T1
   Final index value = Sum of (No. of shares of each stock in V1 * Closing price of the respective stock on T1)Again, the number of shares of each stock will remain the same till the next rebalance date. As earlier, each trading day the closing stock prices are multiplied by the number of shares. The sum of these data points will be the index value for that specific date.The index values calculated using the improved method will be as below:

Please note that portfolio returns were impacted when the above updated methodology wrt to calculating impact of rebalance on index values was implemented on 25th Apr’22. Returns were adjusted to reflect the impact of updated methodology on all the historical rebalances of the portfolio since launch.

Calculating returns using index values

As clarified earlier, index values are used to calculate portfolio returns. Index values of the portfolio and the corresponding category performance are available on the platform.The “Download” button on the rebalance timeline feature in the stocks and weights section of the portfolio page can be used to download the index value of the portfolio and historical components.To calculate the 1-month return of a portfolio, first decide on the base date and historical date. Suppose the base date is 1st Jan 2015, the historical date is 1st Dec 2014. Let's suppose the index values on these dates are 470.2 and 482.6 respectively. Then the 1 month return is (470.2/482.6)-1 = 2.58%. The absolute returns between any 2 dates can be calculated similarly.

Calculating returns when we have not prescribed any weights

Equal weights are used to calculate the returns, for portfolios where we have just prescribed a list of stocks/ETFs, but has not prescribed any weights. So if there are 5 stocks/ETFs in the portfolio, each would be considered to have 20% weight while using the above-mentioned methodology for returns calculation. Similarly, if there are 10 stocks/ETFs in the portfolio, each would be considered to have 10% weight while using the above-mentioned methodology for returns calculation.

Does portfolio performance include the impact of transaction fees?

No, transaction fees and other related costs are not included to calculate the index value and performance of the portfolios. No actual money was invested or trades were executed while calculating portfolio performances. Returns are based on end of day prices of stocks in a portfolio.

Does portfolio performance include historical rebalances?

Yes, portfolio performance accounts for all the rebalances. portfolios are reviewed and rebalanced as per a schedule depending on the portfolio. As a result of this review process, some stocks may be added, some may be removed and some may undergo weight changes. portfolio returns reflect all these changes.

Does portfolio returns include any backtested data?

No, portfolio returns do not include any backtested data. Interested users can separately checkout the backtest performance through the factsheet of a portfolio.

Does portfolio performance include the adjustment for stocks which users are not able to buy/sell in rebalances due to stocks hitting the upper/lower circuits?

Yes, at the end of every month, we identify all the portfolios which experienced following events :

• We added or removed the stocks which were in the upper/lower circuit on the day when users received the rebalance update for execution (next market open day after the we added the rebalance)

• We reduced or increased the weights of the stocks which were in the upper/lower circuit on the day users received the rebalance update for execution

For such portfolios, we recalculate the index value for the last month in a manner that ensures :

• Circuit stocks are not removed/added from our portfolio for the period in which they remained in the circuit. This will ensure that our portfolio returns are in line with the user portfolio returns, as users would also not be able to buy/sell these stocks for the same period.

Recalculated index value is used to calculate all the ratios like CAGR, volatility labels, etc

1. Disclosure

For disclosures refer to the Research Analyst disclosures and the Portfolio Management Services disclosures.

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Data Privacy Policy

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For disclosures refer to the Research Analyst disclosures and the Portfolio Management Services disclosures.

Purpose and scope of the privacy policy

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Itemised description of the personal data collected from users, the service it relates to and the purpose of collection.

Serial No.	Nature of personal information collected from users on website	Description of services to be provided to users	Purpose of collecting information from the users
1	Name of the User	Research Analyst and Portfolio Management Services	For KYC
2	Email ID of the User	Research Analyst and Portfolio Management Services	For KYC and OTP authentication
3	Contact Number of the User	Research Analyst and Portfolio Management Services	For KYC and OTP authentication
4	PAN Card of the User	Research Analyst and Portfolio Management Services	For KYC to fetch data from KRAs
5	Risk Profile of the User	Portfolio Management Services	For PMS advisory tool to prospective clients under PMS business

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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).

Notification about breach of data

On becoming aware of any personal data breach, Wright Research shall, to the best of its knowledge, intimate to each affected User, in a concise, clear and plain manner and without delay, through their user account or any mode of communication registered by them with Wright Research, —

• a description of the breach, including its nature, extent and the timing of its occurrence;
• the consequences relevant to them, that are likely to arise from the breach;
• the measures implemented and being implemented by Wright Research, if any, to mitigate risk;
• the safety measures that users may take to protect their interests; and
• business contact information of a person who is able to respond on behalf of Wright Research, to queries, if any, of the Data Principal.

Further, Wright Research shall intimate to the Board, —

• without delay, a description of the breach, including its nature, extent, timing and location of occurrence and the likely impact;
• within seventy-two hours of becoming aware of the breach, or within such longer period as the Board may allow on a request made in writing in this behalf, —
  • updated and detailed information in respect of such description;
  • the broad facts related to the events, circumstances and reasons leading to the breach;
  • measures implemented or proposed, if any, to mitigate risk;
  • any findings regarding the person who caused the breach;
  • remedial measures taken to prevent recurrence of such breach; and
  • a report regarding the intimations given to affected users.

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.

Retention of User’s data in case when specified purpose to be deemed as no longer being served

Wright Research shall erase such personal data, unless its retention is necessary for compliance with any law for the time being in force, if the User neither approaches Wright Research for the performance of the specified purpose nor exercises their rights in relation to such processing.

At least forty-eight hours before completion of the time period for erasure of personal data, Wright Research shall inform the User that such personal data shall be erased upon completion of such period, unless they log into their user account or otherwise initiates contact with Wright Research for the performance of the specified purpose or exercises their rights in relation to the processing of such personal data.

Wright Research shall retain, in respect of any processing of personal data undertaken by it, such personal data, associated traffic data and other logs of the processing for a minimum period of one year from the date of such processing, after which Wright Research shall cause such personal data and logs to be erased, unless further retention is required for compliance with any other law for the time being in force or notified by the Government.

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: Founder, CEO
• Address: The Capital 815A/B-Wing, opp. ICICI Bank, G Block BKC, Bandra Kurla Complex, Bandra East, Mumbai, Maharashtra 400051
• Telephone: +91 6360127635
• Email: info@wrightresearch.in