Important Documents

Nirav Desai — SEBI Certified Research Analyst — Reg No. INH000004440

Disclaimer and Disclosures

Please review these disclaimers and disclosures carefully. These are to be read along with Terms and Conditions as well as general and individual contracts entered into with clients.
Nirav Desai is a SEBI registered Research Analyst (SEBI Registration Number INH000004440), duly qualified and having long practical experience. Recommendations are given on the basis of bonafide analysis and judgment using a judicious mix of technical and fundamental analysis and long experience of having followed and analysed markets and scrips over a considerable period. Software, experience and skills are used in arriving at decisions.
Recommendations given herein are not personalised to individual clients or group of clients. Each client shall carefully assess their goals and objectives in context of their stage in life and capacity to take investment and/or trading decisions and their capacity and inclination to take risks and handle uncertainty in the stock market, preferably with the help of a duly registered investment adviser.
Stock markets generally and options/futures markets in particular are prone to higher than normal earnings or losses or even stagnation for long periods of time. Markets are known to be subject to sharp volatility which often cannot necessarily be explained with rational analysis. That apart, unexpected developments in the local, national or international markets, including political and other developments, may significantly affect the markets. The investor is well advised to self-assess his capacity to take risks balancing with expected rewards and placing them in context with the state of life and financial status they belong to. Under no circumstances whatsoever shall we be responsible for any loss suffered by any person.
Recommendations have a short shelf life and are generally expected to be valid at the time they are made. In particular, recommendations on options/futures have even shorter validity and market changes may affect the recommendations further. Unless reaffirmed by a fresh recommendation, the recommendation should not be considered valid beyond the time when it has been made, irrespective of whether the price or markets have moved in a particular direction or not.
Individual shares, bonds, futures, options, etc. may have differing volumes and depths and this may affect their movements and spreads. Further, large amount of orders may also affect, at least in the short term, the movement of prices which may be divorced from their fundamentals. Investors and traders shall have, and apply, at least basic knowledge and skills to track fundamental parameters.
Clients should carefully and diligently undergo the training offered by us before beginning trades. It is also strongly advised that, for a sufficient period of time, they may carry out shadow trading/investments to help develop application skills. In any case, initially, they may invest amounts that are small relative to their risk taking capacity.
Many categories of shares and bonds and in particular all options and futures require close monitoring and hence clients may need to devote sufficient time and focus in monitoring the movements in markets.
While recommendations in equity shares, bonds, etc. which are made for long term may have coverage of a broader spectrum of relevant factors, recommendations in futures and options may be made more on basis of narrower technical analysis based on short term factors.
Clients shall take into account income-tax, stamp duty, security transaction tax and other levies and factors in respect of their trading and investment decisions by taking advice from a competent tax/legal advisor. Tax and other implications may vary from person to person.
These disclaimers and disclosures are subject to periodic revisions with or without notice and clients are requested to regularly review them, particularly if an indication is given of their having been updated. Changes are deemed to have been read by the clients the moment they are made/published herein.
Subject to the SEBI (Research Analysts) Regulations, 2014 (as amended from time to time) and other applicable law, the Research Analysts may engage in such activity of consultancy, trading, or otherwise as they may deem appropriate.
We do not carry out any analysis of individual circumstances of specific clients. Background information taken of clients (prospective or actual) may be for data analysis and related purposes only and no conclusion is possible to be drawn that recommendations are tailored generally for any category of clients or to any individual client. By sharing their data, rights are given to us to make such further analysis or share with such third parties as may be deemed fit for rendering better and a variety of services to clients or otherwise. Third party advisors/service or product providers may contact clients for providing their products or services. We do not in any manner confirm their suitability to any group of clients or to individual clients or otherwise endorse any such parties. Clients are advised to take their own decisions, taking such external advice as may be deemed appropriate in such circumstances.
While the recommendations made by us are generic and not specific to the circumstances of individual clients or group of clients, it is also made clear that the recommendations may be considered or used by no other person other than the client to whom they are provided.

Updated on 22nd December 2022. [Placeholder — confirm current revision date with Nirav before launch.]

I, Nirav Dilip Desai, SEBI registered research analyst, author hereby certify that all of the views expressed in this research report accurately reflect my views about the subject issuer(s) or securities. I also certify that no part of my compensation was, is, or will be directly or indirectly related to the specific recommendation(s) or view(s) in this report.

Additional Disclosures of Interest

The Research Analyst or relatives of the Research Analyst does not have any financial interest in the company(ies) covered in this report.
The Research Analyst or relatives of the Research Analyst collectively do not hold more than 1% of the securities of the company(ies) covered in this report as of the end of the month immediately preceding the distribution of the research report.
The Research Analyst, his relatives, do not have any other material conflict of interest at the time of publication of this research report.
The Research Analyst have not received compensation for investment banking or merchant banking or brokerage services or for any other products or services from the company(ies) covered in this report, in the past twelve months.
The Research Analyst have not managed or co-managed in the previous twelve months, a private or public offering of securities for the company(ies) covered in this report.
The research analyst have not received compensation or other benefits from the company(ies) covered in this report or from any third party, in connection with the research report.
The Research Analyst has not been engaged in market making activity for the company(ies) covered in the Research report.

Key Details / Contact Details / Compliance Officer / Grievance Officer
Field	Details
Name	NIRAV DILIP DESAI
Mobile	9820627454
Email ID	ndstockstimulator@gmail.com

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

"The securities quoted are for illustration only and are not recommendatory."

"Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors."

Reference to any report, analysis, or service as free, unless it actually is free and without condition or obligation.

A. Vision and Mission Statements for investors

Vision: Invest with knowledge & safety.
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.

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

To publish research report based on the research activities of the RA
To provide an independent unbiased view on securities
To offer unbiased recommendation, disclosing the financial interests in recommended securities
To provide research recommendation, based on analysis of publicly available information and known observations
To conduct audit annually
To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Research Analysts
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

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

Onboarding of clients — sharing of terms and conditions of research services, completing KYC of fee-paying clients
Disclosure to clients — material information for informed decisions, including business activity, disciplinary history, terms and conditions, associates, risks and conflicts of interest; extent of use of Artificial Intelligence tools in providing research services; conflicts of interest when distributing third-party research reports; conflicts between research services and other activities of the RA
To distribute research reports and recommendations to clients without discrimination
To maintain confidentiality with respect to publication of the research report until made available in the public domain
To respect data privacy rights of clients and take measures to protect unauthorized use of their confidential information
To disclose the timelines for the services provided and ensure adherence to those timelines
To provide clear guidance and adequate caution notice to clients when providing recommendations for complex and high-risk financial products/services
To treat all clients with honesty and integrity
To ensure confidentiality of information shared by clients unless required for legal obligations or with specific client consent

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

Investors can lodge a complaint/grievance against the Research Analyst directly — the RA will strive to redress the grievance immediately, but not later than 21 days from receipt.
SCORES 2.0, SEBI's web-based centralised grievance redressal system (scores.sebi.gov.in) — two-level review: first by the designated body (RAASB), then by SEBI.
If unsatisfied with the resolution, investors may file the complaint/grievance on the SMARTODR platform for resolution through online conciliation or arbitration.

Physical complaints may be sent 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.

Escalation Matrix

Who to contact, in order, if a complaint isn't resolved at the previous level
Level	Contact for redressal	Details	Typical timeline
1	Research Analyst — Nirav Dilip Desai	ndstockstimulator@gmail.com · 9820627454	Within 21 days of receipt
2	Compliance Officer — Nirav Dilip Desai	Same contact details as above (RA is also the designated Compliance Officer)	Within 21 days of receipt
3	SEBI SCORES 2.0	scores.sebi.gov.in — reviewed first by RAASB, then by SEBI	Per SCORES-prescribed timelines
4	Online Dispute Resolution	smartodr.in — online conciliation or arbitration if SCORES resolution is unsatisfactory	Per SMART ODR-prescribed timelines
5	SEBI — Office of Investor Assistance and Education	SEBI Bhavan, Plot No. C4-A, 'G' Block, Bandra-Kurla Complex, Bandra (E), Mumbai – 400051 (physical complaints)	—

File a complaint on SEBI SCORES → | Start Online Dispute Resolution (SMART ODR) →

E. Rights of investors

Right to Privacy and Confidentiality
Right to Transparent Practices
Right to Fair and Equitable Treatment
Right to Adequate Information
Right to Initial and Continuing Disclosure — right to receive information about all statutory and regulatory disclosures
Right to Fair & True Advertisement
Right to Awareness about Service Parameters and Turnaround Times
Right to be informed of the timelines for each service
Right to be Heard and Satisfactory Grievance Redressal
Right to have timely redressal
Right to Exit from a financial product or service in accordance with agreed terms and conditions
Right to receive clear guidance and caution notice when dealing in complex and high-risk financial products and services
Additional rights for vulnerable consumers — right to access services in a suitable manner even if differently abled
Right to provide feedback on financial products and services used
Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from the investors (Responsibilities of investors)

Do's

Always deal with a SEBI registered Research Analyst.
Ensure that the Research Analyst has a valid registration certificate; check the SEBI registration number against SEBI's list of registered Research Analysts.
Always pay attention to disclosures made in research reports before investing.
Pay your Research Analyst through banking channels only and keep duly signed receipts. Fee payments may optionally be made through the Centralized Fee Collection Mechanism (CeFCoM) of RAASB, where the RA has opted for it (fee-paying clients only).
Before buying/selling securities or applying in a public offer, check the research recommendation provided by your Research Analyst.
Ask all relevant questions and clear doubts with your Research Analyst before acting on a recommendation, especially for complex or high-risk products.
Know that you have the right to stop availing the RA's services as per the agreed terms of service.
Know that you have the right to provide feedback on services received.
Know that you are not bound by any clause prescribed by the RA that contravenes any regulatory provision.
Inform SEBI if any Research Analyst offers assured or guaranteed returns.

Don'ts

Do not provide funds for investment to the Research Analyst.
Don't fall prey to luring advertisements or market rumors.
Do not get attracted to limited-period discounts or other incentives, gifts, etc. offered by the Research Analyst.
Do not share login credentials or passwords of your trading, demat or bank accounts with the Research Analyst.

Complaint Data

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Most Important Terms and Conditions (MITC)

These terms and conditions, and consent thereon, are for the research services provided by the Research Analyst (RA), and the RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client. Clients are advised not to permit the RA to execute any trade on their behalf.
The fee charged by the RA to the client will be subject to the maximum amount prescribed by SEBI/RAASB from time to time (applicable only for Individual and HUF clients). Current fee limit: ₹1,51,000 per annum per family of client, for all research services of the RA. The fee limit does not include statutory charges, and does not apply to non-individual clients or accredited investors.
The RA may charge fees in advance if agreed by the client — such advance shall not exceed the period stipulated by SEBI, presently one quarter. On pre-mature termination by either party, the client is entitled to a refund of proportionate fees for the unexpired period.
Fees to the RA may be paid via cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Clients can optionally pay through the Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited, the currently recognised RAASB.
The RA is required to abide by applicable SEBI/RAASB regulations, circulars and directions on disclosure and mitigation of any actual or potential conflict of interest, and will endeavour to promptly inform clients of any conflict that may affect services rendered.
Any assured/guaranteed/fixed-return schemes, or any scheme of similar nature, are prohibited by law. No such scheme will be offered to clients by the RA.
The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA's research services. All opinions, projections and estimates are based on analysis of available data under certain assumptions as of the date of preparation/publication of the research report.
Investments made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim losses incurred on investments made based on recommendations in the research report; reliance on the report is at the client's own judgement and assessment.
SEBI registration, enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
For any grievances — Step 1: contact the RA using the details on this website (see Contact page). Step 2: if unsatisfied, lodge a grievance through SEBI's SCORES platform at www.scores.sebi.gov.in. Step 3: consider Online Dispute Resolution through the Smart ODR portal at smartodr.in.
Clients are required to keep contact details, including email ID and mobile number/s, updated with the RA at all times.
The RA shall never ask for a client's login credentials or OTPs for their Trading, Demat or Bank Account. Never share such information with anyone, including the RA.

Annual audit filings, made available for investor reference:

Audit Report — placeholder, awaiting current-year PDF from Nirav
Annexure to Audit Report (RA) — placeholder
Client-level Segregation Report — placeholder

These will be uploaded as downloadable PDFs once supplied — same pattern as the current live site.

Disclosure & Disclaimer +