Disclosure

Disclaimer: Registration granted by SEBI/BSE Ltd. And certification from NISM in no way guarantees performance of the intermediary or provide any assurance to investors.

Refer circular: SEBI Circular no. SEBI/HO/MIRSD-PoD-2/P/CIR/2023/52 April 6, 2023

1. Complaint Data to be displayed by RAs
   Data for the month ending August 2025:

   Sr. No	Received from	Pending at the end of last month	Received	Resolved *	Total Pending #	Pending complaints > 3months	Average Resolution
   1	Directly from Investors	-	-	-	-	-	-
   2	SEBI (SCORES)	-	-	-	-	-	-
   3	Other Sources (if any)	-	-	-	-	-	-
   	Grand Total	-	-	-	-	-	-

   Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.

2. Trend of monthly disposal of complaints
   

   Sr. No.	Month	Carried forward from previous month	Received	Resolved*	Pending#
   1	September 2024	-	-	-	-
   2	October 2024	-	-	-	-
   3	November 2024	-	-	-	-
   4	December 2024	-	-	-	-
   5	January 2025	-	-	-	-
   6	February 2025	-	-	-	-
   7	March 2025	-	-	-	-
   8	April 2025	-	-	-	-
   9	May 2025	-	-	-	-
   10	June 2025	-	-	-	-
   11	July 2025	-	-	-	-
   12	August 2025	-	-	-	-
   	Grand Total	-	-	-	-

    
   *Inclusive of complaints of previous months resolved in the current month.
   #Inclusive of complaints pending as on the last day of the month.

In case the investor/client is not satisfied with the redressal of the Research Analyst or otherwise, the investor/client may lodge the complaint with SEBI’s web-based complaints redressal system SCORES at https://scores.gov.in/scores/Welcome.html.

Your attention is drawn to the SEBI circular no. SEBI/HO/OIAE/OIAE_IAD1/P/CIR/2023/145 dated July 31, 2023 (updated as on August 4, 2023), on “Online Resolution of Disputes in the Indian Securities Market”.

A copy of the said SEBI circular is here –

https://www.sebi.gov.in/legal/mastercirculars/dec-2023/master-circular-for-online-resolution-of-disputes-in-the-indiansecurities market_80236.html

A common Online Dispute Resolution Portal (“ODR Portal”) which harnesses online conciliation and online arbitration for resolution of disputes arising in the Indian Securities Market has been established.

SMART ODR Portal (Securities Market Approach for Resolution through ODR Portal) can be accessed via the following link – https://smartodr.in/login. You are requested to take note of the contents of the SEBI circular.

Thank you for your continued support.

1. Vision and Mission Statements for investors.

   1. Vision: Invest with knowledge & safety.
   2. Mission: Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

2. Details of business transacted by the Research Analyst with respect to the investors.

   1. To publish research report based on the research activities of the RA
   2. To provide an independent unbiased view on securities.
   3. To offer unbiased recommendation, disclosing the financial interests in recommended securities.
   4. To provide research recommendation, based on analysis of publicly available information and known observations.
   5.  To conduct audit annually
   6.  To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Research Analysts.
   7. To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to the research services has taken place.

3. Details of services provided to investors (No Indicative Timelines)

   1. Onboarding of Clients:
      1. Sharing of terms and conditions of research services
      2. Completing KYC of fee paying clients
   2. Disclosure to Clients:
      1. To disclose, information that is material for the client to make an informed decision, including details of its business activity, disciplinary history, the terms and conditions of research services, details of associates, risks and conflicts of interest, if any
      2. To disclose the extent of use of Artificial Intelligence tools in providing research services
      3. To disclose, while distributing a third party research report, any material conflict of interest of such third party research provider or provide web address that directs a recipient to the relevant disclosures o To disclose any conflict of interest of the activities of providing research services with other activities of the research analyst.
   3. To distribute research reports and recommendations to the clients without discrimination.
   4. To maintain confidentiality w.r.t publication of the research report until made available in the public domain.
   5. To respect data privacy rights of clients and take measures to protect unauthorized use of their confidential information
   6. To disclose the timelines for the services provided by the research analyst to clients and ensure adherence to the said timelines
   7. To provide clear guidance and adequate caution notice to clients when providing recommendations for dealing in complex and high-risk financial products/services
   8. To treat all clients with honesty and integrity
   9. To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations or a client has provided specific consent to share such information.

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

   1. Investor can lodge complaint/grievance against Research Analyst in the following ways:

      Mode of filing the complaint with research analyst

      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.

      Mode of filing the complaint on SCORES or with Research Analyst Administration and Supervisory Body (RAASB)

      1. SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://scores.sebi.gov.in)

         Two level review for complaint/grievance against Research Analyst:

         1. First review done by designated body (RAASB)
         2. Second review done by SEBI
      2. Email to designated email ID of RAASB
   2. If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.

    

   With regard to physical complaints, investors may send their complaints 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 – 400 051

5. Rights of investors

   1. Right to Privacy and Confidentiality
   2. Right to Transparent Practices
   3. Right to fair and Equitable Treatment
   4. Right to Adequate Information
   5. Right to Initial and Continuing Disclosure-Right to receive information about all the statutory and regulatory disclosures
   6. Right to Fair & True Advertisement
   7. Right to Awareness about Service Parameters and Turnaround Times
   8. Right to be informed of the timelines for each service
   9. Right to be Heard and Satisfactory Grievance Redressal
   10. Right to have timely redressal
   11. Right to exit from Financial product or service in accordance with the terms and conditions agreed with the research analyst
   12. Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
   13. Additional Rights to vulnerable consumers
   14. Right to get access to services in a suitable manner even if differently abled
   15. Right to provide feedback on the financial products and services used
   16. Right against coercive, unfair, and one-sided clauses in financial agreement

6. Expectations from the investors (Responsibilities of investors).

   1. Do’s

      1. Always deal with SEBI registered Research Analyst.
      2. Ensure that the Research Analyst has a valid registration certificate.
      3. Check for SEBI registration number.
      4. Please refer to the list of all SEBI registered Research Analyst which is available on SEBI website in the following link:

         https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi =yes&intmId=14

      5. Always pay attention towards disclosures made in the research reports before investing.
      6. Pay your Research Analyst through banking channels only and maintain duly signed receipts mentioning the details of your payments. You may make payment of fees through Centralized Fee Collection Mechanism (CeFCoM) of RAASB if research analyst has opted for the mechanism. (Applicable for fee paying clients only)
      7.  Before buying/ selling securities or applying in public offer, check for the research recommendation provided by your Research Analyst.
      8. Ask all relevant questions and clear your doubts with your Research Analyst before acting on recommendation.
      9. Seek clarifications and guidance on research recommendations from your Research Analyst, especially if it involves complex and high-risk financial products and services.
      10. Always be aware that you have the right to stop availing the service of a Research Analyst as per the terms of service agreed between you and your Research Analyst.
      11. Always be aware that you have the right to provide feedback to your Research Analyst in respect of the services received.
      12.  Always be aware that you will not be bound by any clause, prescribed by the research analyst, which is contravening any regulatory provisions.
      13. Inform SEBI about Research Analyst offering assured or guaranteed returns.

   2. Don’ts

      1. Do not provide funds for investment to the Research Analyst.
      2. Don’t fall prey to luring advertisements or market rumors.
      3. Do not get attracted to limited period discount or other incentive, gifts, etc. offered by Research Analyst.
      4. Do not share login credential and password of your trading, demat or bank accounts with the Research Analyst.

1. Negen Brokers Private Limited (“Negen Brokers”) is a is duly registered with the Securities and Exchange Board of India (“SEBI”) as a Research Analyst under the SEBI (Research Analysts) Regulations 2014, holding Registration Number INH000016773 and enlisted with BSE Limited, holding Research Analyst Enlistment Number 6210. Negen Brokers is a wholly owned subsidiary of Coheron Wealth Private Limited which is engaged in the business of acting as a mutual fund distributor with the Association of Mutual Funds in India (“AMFI”) and has empanelled itself with various asset management companies, for making client referrals to various financial products / service providers including but not limited to distribution of third-party portfolio management services / alternative investment fund products.
2. We hereby declare We have not been debarred from doing business by any Stock Exchange / SEBI or any other authorities; nor has our certificate of registration been cancelled by SEBI / BSE Limited at any point of time.
3. Negen Brokers or its Associates, may:
   1. from time to time, have long or short position in, and buy or sell the securities of the company mentioned in the Report or
   2. be engaged in any other in any other transaction involving such securities and earn brokerage or other compensation or act as a market maker in the financial instruments of the company discussed herein or act as an advisor or lender/borrower to such company or may have any other potential conflict of interests with respect to any recommendation and other related information and opinions
   3. have any financial interests in the subject company mentioned in this Report
   4. be engaged in market making activity for the subject company.
4. Negen Brokers does not have actual / beneficial ownership of 1% percent or more securities of the subject company, at the end of the month immediately preceding the date of publication of the Report. However, since Associates of Coheron Brokers are engaged in the financial services business, they might have in their normal course of business financial interests or actual / beneficial ownership of one percent or more in various companies including the subject company mentioned herein this Report
5. Negen Brokers or its associates might have managed or co-managed public offering of securities for the subject company in the past 12 (twelve) months and might have received compensation from the companies mentioned in the Report during the period preceding 12 (twelve) months from the date of this Report for services in respect of managing or co-managing public offerings/corporate finance, investment banking or merchant banking, brokerage services or other advisory services in a merger or specific transaction.
6. Compensation paid to Analysts of Negen Brokers is not based on any specific merchant banking, investment banking or brokerage service transaction.
7. Negen Brokers or its associates did not receive any compensation or any benefit from the subject company or third party in connection with preparation of this Report.
8. This Report is for the personal information of the authorized recipient(s) and is not for public distribution and should not be reproduced, transmitted or redistributed to any other person or in any form without Coheron Broker’s prior permission. The information provided in the Report is from publicly available data, which we believe, are reliable. While reasonable endeavours have been made to present reliable data in the Report so far as it relates to current and historical information, but Negen Brokers does not guarantee the accuracy or completeness of the data in the Report. Accordingly, Coheron Brokers or any of its Associates including directors and employees thereof shall not be in any way responsible or liable for any loss or damage that may arise to any person from any inadvertent error in the information contained, views and opinions expressed in this Report or in connection with the use of this Report.
9. Please ensure that you have read “Risk Disclosure Document for Capital Market and Derivatives Segments” as prescribed by SEBI before investing in Indian securities market.
10. The projections and forecasts described in this Report should be carefully evaluated as these:
    1. are based upon a number of estimates and assumptions and are inherently subject to significant uncertainties and contingencies.
    2. can be expected that some of the estimates on which these were based, will not materialize or will vary significantly from actual results, and such variances may increase over time.
    3. are not prepared with a view towards compliance with published guidelines or generally accepted accounting principles. No independent accountants have expressed an opinion or any other form of assurance on these.
    4. should not be regarded, by mere inclusion in this report, as a representation or warranty by or on behalf of Negen Brokers, the authors of this report, or any other person, that these or their underlying assumptions will be achieved.
11. This Report is for information purposes only and Negen Brokers or its associates accept no liabilities for any loss or damage of any kind arising out of the use of this report. Though disseminated to recipients simultaneously, not all recipients may receive this report at the same time. Negen Brokers will not treat recipients as clients by virtue of their receiving this report. It should not be construed as an offer to sell or solicitation of an offer to buy, purchase or subscribe to any securities this report shall not form the basis of or be relied upon in connection with any contract or commitment, whatsoever. This report does not solicit any action based on the material contained herein.
12. It does not constitute a personal recommendation and does not take into account the specific investment objectives, financial situation/circumstances and the particular needs of any specific person who may receive this document. The securities discussed in this Report may not be suitable for all the investors.
13. Negen Brokers does not provide legal, accounting or tax advice to its clients and you should independently evaluate the suitability of this Report, and all investors are strongly advised to seek professional consultation regarding any potential investment.
14. Certain transactions including those involving futures, options, and other derivatives as well as non-investment grade securities give rise to substantial risk and are not suitable for all investors. Foreign currency denominated securities are subject to fluctuations in exchange rates that could have an adverse effect on the value or price of or income derived from the investment.
15. The price, value and income of the investments referred to in this Report may fluctuate and investors may realize losses on any investments. Past performance is not a guide for future performance. Actual results may differ materially from those set forth in projections. Negen Brokers has reviewed the Report and, the current or historical information included here is believed to be reliable, the accuracy and completeness of which is not guaranteed. Coheron Brokers does not have any obligation to update the information discussed in this Report.
16. The opinions expressed in this report are subject to change without notice and Negen Brokers or its associates have no obligation to tell the clients when opinions or information in this report change. This Report has not been approved and will not or may not be reviewed or approved by any statutory or regulatory authority in India, United Kingdom or Singapore or by any Stock Exchange in India, United Kingdom or Singapore. This report may not be all inclusive and may not contain all the information that the recipient may consider material.
17. The securities described herein may not be eligible for sale in all jurisdictions or to all categories of investors. The countries in which the companies mentioned in this Report are organized may have restrictions on investments, voting rights or dealings in securities by nationals of other countries. Distributing /taking/sending/dispatching/transmitting this document in certain foreign jurisdictions may be restricted by law, and persons into whose possession this document comes should inform themselves about, and observe, any such restrictions. Failure to comply with this restriction may constitute a violation of laws in that jurisdiction.
18. The Disclosures and Disclaimers incorporated in this document is provided solely to enhance the transparency and should not be treated as endorsement of the views expressed in the report. Negen Brokers reserves the right to make modifications and alternations to this document as may be required from time to time without any prior notice. The views expressed are those of the analyst(s) and Negen Brokers may or may not subscribe to all the views expressed therein.