ASPINWALL AND COMPANY
Return on Capital Employed (ROCE)

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.

C. Details of services provided to investors
• Onboarding of Clients
• Disclosure to Clients
o To distribute research reports and recommendations to the clients without discrimination.
o To maintain confidentiality w.r.t publication of the research report until made available in the public domain.

D. Details of grievance redressal mechanism and how to access it
In case of any grievance / complaint, an investor should approach the concerned research analyst and shall ensure that the grievance is resolved within 30 days.
If the investor’s complaint is not redressed satisfactorily, one may lodge a complaint with SEBI on SEBI’s SCORES portal which is a centralized web-based complaints redressal system. SEBI takes up the complaints registered via SCORES with the concerned intermediary for timely redressal. SCORES facilitates tracking the status of the complaint.
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. Expectations from the investors (Responsibilities of investors)
Do’s
i. Always deal with SEBI registered Research Analyst.
ii. Ensure that the Research Analyst has a valid registration certificate.
iii. Check for SEBI registration number.
iv. Please refer to the list of all SEBI registered Research Analysts which is available on SEBI website in the following link:
https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=14
v. Always pay attention towards disclosures made in the research reports before investing.
vi. Pay your Research Analyst through banking channels only and maintain duly signed receipts mentioning the details of your payments.
vii. Before buying securities or applying in public offer, check for the research recommendation provided by your research Analyst.
viii. Ask all relevant questions and clear your doubts with your Research Analyst before acting on the recommendation.
ix. Inform SEBI about Research Analyst offering assured or guaranteed returns.

Don’ts
I. Do not provide funds for investment to the Research Analyst.
II. Don’t fall prey to luring advertisements or market rumours.
III. Do not get attracted to limited period discount or other incentive, gifts, etc. offered by Research Analyst.
IV. Do not share login credentials and password of your trading and demat accounts with the Research Analyst.

Client’s queries / complaints may arise due to lack of understanding or a deficiency of service experienced by clients. Deficiency of service may include lack of explanation, clarifications, understanding which escalates into shortfalls in the expected delivery standards, either due to inadequacy of facilities available or through the attitude of staff towards client.

1. Clients can seek clarification to their query and are further entitled to make a complaint in writing. An email may be sent to the Customer Support Team on support@smart-investing.in with the subject line "Complaint".

2. A letter may also be written with their query/complaint and posted at the below mentioned address:

Smart-Investing.in, #15A, 4th Floor, City Vista, Tower A,
Suite No.984, Fountain Road,
Kharadi, Pune - 411014

3. You may write to the research analyst at rohit@smart-investing.in if you do not receive a response within 10 business days of writing to the Customer Support Team. You can expect a reply within 10 business days of approaching research analyst.

4. In case you are not satisfied with our response, you can lodge your grievance with SEBI at http://scores.gov.in or you may also write to any of the offices of SEBI. SCORES may be accessed thorough SCORES mobile application as well, same can be downloaded from this link.

Data for the month ending Jan 2024