SEBI Disclosures

The following disclosures are provided in accordance with SEBI (Investment Advisers) Regulations, 2013 and SEBI/HO/IMD/DF1/CIR/P/2020/182 (dated September 23, 2020). This website also follows the SEBI Advertisement Code for Investment Advisers.

Material Disclosures for Investors and Prospects

Disclosure Document

The particulars given in this Disclosure Document have been prepared in accordance with SEBI (Investment Advisers) Regulations, 2013.

The purpose of this Document is to provide essential information about the Investment Advisory Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging an Investment Adviser before investing.

For this Disclosure Document, the Investment Adviser is Sheo Narayan ("Investment Adviser").

History, Present Business and Background

The Investment Adviser is registered with SEBI as Investment Adviser with Registration No. INA000022844 and has been engaged in advisory services since then.

The focus of the Investment Adviser is to provide investment advice to clients. The Adviser aligns its interests with those of the client and seeks to provide the best suited advice based on clients' risk profile. The Investment Adviser first tries to understand the client's return expectations, risk taking ability & goals, which in turn helps to arrive at an asset allocation suitable for the client. Frequent portfolio reviews are also done and suggestions for any corrective actions, if required, are given.

Terms and Conditions of Advisory Services

Terms and conditions of advisory services are detailed in the client agreement. Please refer to the same for details.

Disciplinary History

No penalties / directions have been issued by SEBI under the SEBI Act or Regulations made there under against the Investment Adviser relating to Investment Advisory services.

There are no pending material litigations or legal proceedings, findings of inspections or investigations for which action has been taken or initiated by any regulatory authority against the Investment Adviser or its Directors, or employees.

Affiliations with Other Intermediaries

The Investment Adviser has no affiliation with any other SEBI registered intermediaries.

Disclosures with Respect to Investment Adviser's Own Holding Position in Financial Products/Securities

The Investment Adviser may hold position in the financial products/securities advised in its personal portfolio. Details of the same may be referred through the disclosures made at the time of advice.

Disclosures with Respect to Conflicts of Interest

There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of investment advisory services. Such conflicts of interest shall be disclosed to the client as and when they arise.

Disclosure of Material Facts Relating to Key Features of Products/Securities

Clients are requested to go through the detailed key features, performance track record of the product, or security including warnings, disclaimers etc. before investing as and when provided by the Investment Adviser. Such product materials may also be available at www.sebi.gov.in or www.nseindia.com or respective issuers' website.

Drawing Client's Attention to Warnings and Disclaimers

Investment Adviser draws the client's attention to the warnings, disclaimers in documents, advertising materials relating to an investment product/s which are being recommended to the client/s. A brief regarding the risk associated with the investment products are available in the client agreement; same may be referred before investing in advised product or securities.

Investor Charter in respect of Investment Adviser (IA)

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 Investment Adviser with Respect to Investors

• To enter into an agreement with the client providing all details including fee details, aspects of Conflict-of-interest disclosure and maintaining confidentiality of information.
• To do a proper and unbiased risk-profiling and suitability assessment of the client.
• To conduct audit annually.
• To disclose the status of complaints on its website.
• To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI Office details (i.e. Head office/regional/local Office) on its website.
• To employ only qualified and certified employees.
• To deal with clients only from official number.
• To maintain records of interactions, with all clients including prospective clients (prior to on boarding), where any conversation related to advice has taken place.
• To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers.
• Not to discriminate in terms of services provided, among clients opting for same/similar products/services offered by the investment adviser.

C. Details of Services Provided to Investors

Onboarding of Clients

• Sharing of agreement copy.
• Completing KYC of clients.

Disclosure to Clients

• To provide full disclosure about its business, affiliations, compensation in the agreement.
• To not access client's accounts or holdings for offering advice.
• To disclose the risk profile to the client.
• To disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser.
• To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services.

• To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.
• To treat all advisory clients with honesty and integrity.
• To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser.
• To provide clear guidance and adequate caution notice to clients when providing investment advice for dealing in complex and high-risk financial products/services.
• 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.
• To disclose the timelines for the various services provided by the investment adviser to clients and ensure adherence to the said timelines.

D. Details of Grievance Redressal Mechanism and How to Access It

In case of any grievance/complaint, an investor should approach the concerned Investment Adviser and shall ensure that the grievance is resolved within 21 days.

1. Mode of filing the complaint on SCORES or with IAASB:
   • SCORES 2.0 – a web based centralized grievance redressal system of SEBI: https://scores.sebi.gov.in
     Two level review for complaint/grievance against investment adviser:
     • First review by designated body (IAASB)
     • Second review by SEBI.
   • Email to designated email ID of IAASB.
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: https://smartodr.in/login
3. 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

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 (including 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 Suitability of the Financial Products
• Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser
• Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
• Additional Rights to vulnerable consumers – Right to get access to services in a suitable manner even if differently abled
• Right to provide feedback on the financial products and services used
• Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from the Investors (Responsibilities of Investors)

DOs

1. Always deal with SEBI registered Investment Advisers.
2. Ensure that the Investment Adviser has a valid registration certificate.
3. Check for SEBI registration number. Refer to the list of all SEBI registered Investment Advisers available on SEBI website: SEBI IA Registry
4. Pay only advisory fees to your Investment Adviser. Make payments through banking channels only and maintain duly signed receipts. You may also use Centralised Fee Collection Mechanism (CeFCoM) of IAASB if the investment adviser has opted for the mechanism.
5. Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
6. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
7. Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
8. Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
9. Be vigilant in your transactions.
10. Approach the appropriate authorities for redressal of your doubts/grievances.
11. Inform SEBI about Investment Advisers offering assured or guaranteed returns.
12. Always be aware that you have the right to exit the service of an Investment Adviser.
13. Always be aware that you have the right to seek clarifications and clear guidance on advice.
14. Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
15. Always be aware that you will not be bound by any clause, prescribed by the investment adviser, which is contravening any regulatory provisions.

DON'Ts

1. Don't fall for stock tips offered under the pretext of investment advice.
2. Do not provide funds for investment to the Investment Adviser.
3. Don't fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don't let greed overcome rational investment decisions.
4. Don't fall prey to luring advertisements or market rumors.
5. Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
6. Don't take decisions just because of repeated messages and calls by Investment Advisers.
7. Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
8. Don't rush into making investments that do not match your risk-taking appetite and investment goals.
9. Do not share login credentials and password of your trading and demat accounts with the Investment Adviser.

Grievance Redressal

You as my client, can follow below steps for your grievance redressal:

• Please first raise your grievance with us at connect [at] ishavasu [dot] com. Alternatively, call on +91 768 088 9888. We aim to resolve your grievance within 21 business days of receiving it.

• In case you are not satisfied with our response you can lodge your grievance with SEBI at http://scores.sebi.gov.in website. SCORES may also be accessed through the SCORES mobile application available on Google Play.

• You may also access the Online Dispute Resolution Portal ("ODR Portal") for resolution through online conciliation or arbitration at https://smartodr.in/login.

Escalation Matrix for Complaints