internal-policy


1. Research & Recommendation Policy (Internal)

Objective

We ensure all research is fair, unbiased, and based on credible data.

Research Process

  • We use publicly available data, company filings, and market information

  • We apply defined analysis methods before issuing any recommendation

  • We document the rationale behind each call

Recommendation Issuance

  • All recommendations are shared with proper disclosures

  • We clearly state risk factors

  • We avoid misleading or exaggerated claims

Review Mechanism

  • We review recommendations periodically

  • We update or withdraw calls based on new information

Compliance

We follow guidelines issued by Securities and Exchange Board of India.

2. Conflict of Interest Policy (Internal)

Objective

We identify and manage conflicts to protect client interests.

Personal Trading Rules

  • We disclose our holdings before issuing recommendations

  • We avoid trading in securities shortly before or after issuing calls

  • We maintain a minimum holding period as per internal standards

Restrictions

  • No front-running

  • No misuse of unpublished information

Disclosure

  • All conflicts are disclosed in research reports

  • Any financial interest is clearly mentioned

3. Code of Conduct (Internal)

Principles

  • We act with honesty and integrity

  • We follow all SEBI regulations

  • We treat all clients fairly

Prohibited Activities

  • No guaranteed return claims

  • No misleading advertisements

  • No insider trading

Professional Standards

  • Maintain confidentiality

  • Provide accurate information

  • Avoid conflicts of interest

4. Record Keeping Policy (Internal)

Objective

We maintain proper records for audit and compliance.

Records Maintained

  • Client KYC details

  • Research reports and recommendations

  • Communication with clients

  • Payment records

Retention Period

  • Minimum 5 years as per regulatory requirement

Storage

  • Records stored securely in digital or physical form

  • Access restricted to authorized persons

5. Grievance Redressal Policy (Public)

Objective

We address client complaints promptly and fairly.

How to Raise Complaint

You can contact us at:

  • Email: jyoti.bktraining@gmail.com

Resolution Timeline

  • Acknowledgement within 48 hours

  • Resolution within 7 to 15 working days

Escalation

If not satisfied, you can escalate to
Securities and Exchange Board of India via SCORES platform.

6. Privacy Policy (Public)

Data Collection

We collect:

  • Name, PAN, contact details

  • Payment information

Usage

We use data for:

  • Providing research services

  • Compliance with regulations

Data Protection

  • Data stored securely

  • Access limited to authorized use

Sharing

We do not share data except:

  • When required by law

  • When requested by regulators

7. Risk Profiling & Suitability Policy (Internal)

Objective

We match services with client risk profile.

Risk Categories

  • Low risk

  • Moderate risk

  • High risk

Assessment

  • Based on financial background and risk tolerance

Suitability

  • Recommendations aligned with client profile

  • Clients informed about risks before subscribing

8. Terms & Conditions (Public)

Services

We provide research and recommendation services only.

No Guarantee

  • No assured returns

  • Markets are subject to risk

Payment

  • Fees are charged in advance via UPI

  • Non-refundable unless stated otherwise

Liability

We are not responsible for losses incurred based on recommendations.

9. Disclaimer (Public, VERY IMPORTANT)

Standard RA Disclaimer

  • Registration granted by Securities and Exchange Board of India does not guarantee performance

  • Investments are subject to market risks

  • Past performance is not indicative of future results

Personal Responsibility

You are advised to consider your financial situation before investing.