DISCLOSURE

Research Report & Disclosure as per the Research Analyst Regulations

“LotusFunds Research Analyst” is the trading name of Mr. Pradyut Patnaik., and he is a SEBI-registered research analyst with “SEBI Registration No. INH000001238.” He is Graduate from Bombay University with 30 years of work experience in Stock Advisory Firms and is involved in carrying his business activity as a proprietary concern. He has his website LotusFunds.com for providing research services on stocks and derivatives (stocks & commodities) based on technical & fundamental analysis. The research activity includes providing buy, sell, or hold recommendations and price targets for various scripts in the stock exchange and commodity exchange.

Disciplinary history

There is no disciplinary action that is/was running/initiated against him. There is no outstanding litigation against him. He has not been debarred/suspended by SEBI or any other regulatory authority for accessing/dealing in the securities Market. The above is true.

Conflict of Interest Disclosure for Research Analyst

  1. Neither Research Analyst nor his/her relative has any financial interest in the subject Company
  2. Neither the Research Analyst nor his/her relative have actual/beneficial ownership of one percent or more securities of the subject Company, at the end of the month immediately preceding the date of publication of the research report;
  3. Neither Research Analyst nor his/her relative has any other material conflict of interest at the time of publication of the research report.

Disclosure with regard to receipt of Compensation

  1. Research Analyst has not received compensation from the subject Company in the past twelve months.
  2. Research Analyst has not managed or co-managed the Company in the past twelve months.
  3. Research Analyst has not received any compensation for investment banking or merchant banking or brokerage services from the subject Company in the past twelve months.
  4. Research Analyst has not received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past twelve months.
  5. Research Analyst has not received any compensation or other benefits from the subject Company or third party in connection with the research report.

General disclosure

  1. The Research Analyst has not served as an officer, director, or employee of the subject Company.
  2. The Research Analyst has not been engaged in a market-making activity for the subject Company.

Definitions of Terms Used

Sell below/buy Above: The customer should sell the security below the price mentioned in the recommendation and vice versa for buy above.

Target: The Price of security at which the customer has to book profit.

Stop Loss: The price of the security at which the customer has exit position and book loss.

Details about internal policies and procedures to effectively address conflict of interest

  1. Research Analyst has not received compensation from the subject Company in the past twelve months.
  2. Research Analyst has not managed or co-managed public offering of securities for the subject Company in the past twelve months.
  3. Research Analyst has not received any compensation for investment banking or merchant banking or brokerage services from the subject Company in the past twelve months.
  4. Research Analyst has not received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past twelve months.
  5. Research Analyst has not received any compensation or other benefits from the subject Company or third party in connection with the research report.

Policies and procedures for dealing in securities

The trading and dealing in securities by me will be governed by the following:
    1. I will not be, within 30 days before and 5 days after the publication of recommendations/calls or research reports.
    2. I will not deal in securities in a manner contrary to the recommendations given to the clients.
    3. Records will be kept for my personal trading or securities transactions. The documents will be maintained for audit purposes.

Policies for research and analysis

To effectively address conflict of interest and promote reliable research
  1. There will be selecting securities for recommendations. The process will be followed at all times to avoid any conflict of interest.
  2. I shall always have an adequate documentary basis, supported by research, for giving recommendations/calls.
  3. I shall promote reliable research that reflects unbiased views. The views and recommendations given by me will not be affected by any market news.
  4. The source used for doing research will be authentic. I will only use information from websites nseindia.com, bseindia.com, company website, annual reports, company presentations, quarterly results, etc., and not from any source which is not authentic.
  5. The recommendations should not be used to manipulate the market.
  6. I will not issue a research report or provide any recommendation/call that is not consistent with my views as a research analyst regarding a company.

Code of Conduct and Conflict of Interest Policy

  1. If there is any material conflict of interest at the time of giving recommendations adequate disclosures should be given to the clients.
  2. The reseal is segregated from other activities and there will be an arms-length relationship between the activities.
  3. The code of conduct will be strictly adhered to, at all times.

Disclosures

  1. We only provide advice. The decision to execute the recommendations is completely at your discretion.
  2. All investments in Stock Markets, Commodity Markets and other financial instruments traded here are subject to market risks and the Returns may go up or down depending upon the factors and forces affecting the securities market including the fluctuations in the interest rates.
  3. There can be no assurance that an objective will be achieved. The past performance of the calls given or managed by LotusFunds – Research Analyst and its affiliates is not necessarily indicative of future performance of the Calls.
  4. The Service is not guaranteeing or assuring any returns under any of the Services subscribed to herewith.
  5. The investments made in the Stock Markets, Commodity Markets and/or in any of financial instruments are subject to external risks. The floating rate investments are subject to risks pertaining to Interest rate movement, Spread Movement, Settlement and Liquidity.
  6. Investment in securities markets are subject to market risks. Read all the related documents carefully before investing.
  7. Registration granted by SEBI, and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.
  8. The information is only for consumption by the client and such material should not be redistributed.
  9. The securities quoted in the website are for illustration only and are not recommendatory.
  10. LotusFunds – Research Analyst will not be liable for any, direct or indirect, consequential or incidental damages or loss arising out of the use of the information given in the website or through SMS.
  11. LotusFunds – Research Analyst generates all its recommendations via science of Technical Analysis.
  12. LotusFunds – Research Analyst is a SEBI registered Research Analyst with “SEBI Registration No. INH000001238”
  13. LotusFunds – Research Analyst does not provide any execution based/PMS based services. We only provide investment advice to customers on a pre-paid subscription basis.
  14. LotusFunds – Research Analyst does not have affiliations with any intermediary and hence does receive any remuneration or compensation of any form from any other intermediary.
  15. LotusFunds – Research Analyst and/or its associates do not hold beneficial ownership of 1% or more in the recommendations given at the end of the month immediately preceding the date of the recommendation given.
  16. LotusFunds – Research Analyst and/or its associates may have investment positions in the stocks recommended.
  17. LotusFunds – Research Analyst and/or its associates do not have any financial interest in the subject company.
  18. Further LotusFunds – Research Analyst and/or its associates, do not have any material conflict of interest.
  19. LotusFunds – Research Analyst certifies that no part of the compensation was, is, or will be directly or indirectly related to the specific recommendation(s) or view(s) in the recommendations provided.
  20. Complete name of Research Analyst as registered with SEBI: Pradyut Patnaik
  21. Type of Registration – Individual/Proprietorship
  22. Validity of Registration: Valid until Cancelled or Suspended (Perpetual Validity)
  23. Complete Address with Telephone Numbers: LotusFunds – Research Analyst, #B-904, Tulsi Gagan, Sector 21, Kharghar, Navi Mumbai, Maharashtra. PIN: 410210. Phone Number – 9820053399.
  24. Contact Details of Principal Officer: E-mail ID pradyutpatnaik@gmail.com, Phone number – 9820053399
  25. Contact Details of Compliance Officer: Name: Pradyut Patnaik, E-mail ID: pradyutpatnaik@gmail.com, Phone number – 9820053399
  26. Contact Details of Grievances Team: Name: Pradyut Patnaik, E-mail ID: pradyutpatnaik@gmail.com, Phone number – 9820053399
  27. Corresponding SEBI address: Plot No.C4-A, ‘G’ Block Bandra-Kurla Complex, Bandra (East), Mumbai – 400051, Maharashtra Tel : +91-22-26449000 / 40459000 Fax : +91-22-26449019-22 / 40459019