About Learn To invest

 Mr. Bidyut Biswas has exercised due diligence in checking the correctness and authenticity of the information contained herein, so far as it relates to current and historical information, but does not guarantee its accuracy or completeness. The opinions expressed are based on our current research as of the date appearing in the material and may be subject to change from time to time without notice.
Mr. Bidyut Biswas does not accept any liability arising from the use of this document or the information contained herein. The recipients of this material should rely on their own judgment and take their own professional advice before acting on this information.
Mr. Bidyut Biswas shall not be in any way responsible for any loss or damage that may arise to any person/s from any inadvertent error in the information contained, views and opinions expressed in this publication.
Mr. Bidyut Biswas or its associates, including relatives-
do not hold any financial interest in the Company.
do not have any actual/beneficial ownership of more than 1% in the company.
do not have any other material conflict of interest.
Mr. Bidyut Biswas or its associates are not affiliated with any other intermediaries or have received any brokerage or commission from any third party.
Mr. Bidyut Biswas or its associates have not received any compensation from the Company covered by Research Analyst during the past twelve months.
Mr. Bidyut Biswas or its associates have not managed or co-managed public offering of securities of the Company during the past twelve months.
Mr. Bidyut Biswas or its associates has not served as an officer, director or employee of the Company and has not been engaged in the market making activity of the Company.
Mr. Bidyut Biswas have ensured that the facts mentioned in the research report are taken from the reliable source and information. However, the investors are advised to independently evaluate the market conditions/ risks involved before making the investment decision. 

Bidyut Biswas is registered with SEBI with INH000014368 as the SEBI registration number & BSE Enlistment No: 5987 . The registered office address of Bidyut Biswas is Ward No 20 Rakhal Das Sarkar Street Near Durga Mandir, Amla Para Purulia 1 Puruliya, Durgapur, West Bengal, 723101
The content and data available in the material prepared by the company and on the website of the company, including but not limited to index value, return numbers and rationale are for information and illustration purposes only. Charts and performance numbers do not include the impact of transaction fee and other related costs. Past performance does not guarantee future returns and performances of the portfolios are subject to market risk. Data used for calculation of historical returns and other information is provided by exchange approved third party vendors and has neither been audited nor validated by the Company.
Information present in the material prepared by the company and on the website of the company shall not be considered as a recommendation or solicitation of an investment. Investors are responsible for their investment decisions and are responsible to validate all the information used to make the investment decision. Investor should understand that his/her investment decision is based on personal investment needs and risk tolerance, and information present in the material prepared by the company and on the website of the company is one among many other things that should be considered while making an investment decision.

Investments in the securities market are subject to market risks. Read all the related documents carefully before investing.
Registration granted by SEBI, membership of BASL (in case of IAs) and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

Information present in the material prepared by the company and on the website of the company shall not be considered as a recommendation or solicitation of an investment. Investors are responsible for their investment decisions and are responsible to validate all the information used to make the investment decision. Investor should understand that his/her investment decision is based on personal investment needs and risk tolerance, and information present in the material prepared by the company and on the website of the company is one among many other things that should be considered while making an investment decision.

The investor is requested to take into consideration all the risk factors before actually trading in derivative contracts.
We and our associates, officers, directors, and employees, Research Analyst (including relatives) worldwide may: (a) from time to time, have long or short positions in, and buy or sell the securities thereof, of company (ies) forming part of the products or reports created by the company or (b) may have other potential/material conflict of interest with respect to any company(ies) in various products or reports created by the company. Any such positions of conflict of interest will be appropriately disclosed and dealt with in accordance with applicable law. [to be modified depending upon actual circumstances].
The Company does not provide any promise or assurance of favorable view for a particular industry or sector or business group in any manner. The investor is requested to take into consideration all the risk factors including their financial condition, suitability to risk return profile and take professional advice before investing.
The analysts for various products or reports created by the company certify that all of the information /material therein accurately reflect his or her personal views about the subject company or companies and its or their securities, and no part of his or her compensation was, is or will be, directly or indirectly related to company(ies) in various products or reports created by the company. No part of this material may be duplicated in any form and/or redistributed without the prior written consent of the Company.

Contact Details: Name: BIDYUT BISWAS, Support Telephone: +91-7584933039, Support Email: Learntinvest@gmail.com
Compliance Office Details: Name: BIDYUT BISWAS Email: Info@LearnTinvest.com & bidbiswasofficial@gmail.com Contact: +91-7584933039
Grievance Office Details: Name: BIDYUT BISWAS Email: Info@LearnTinvest.com & bidbiswasofficial@gmail.com, Contact: +91-7584933039
 

Annexure A

Most Important Terms and Conditions (MITC)

[Forming part of the Terms and Conditions for providing research services]

1. These terms and conditions, and consent thereon are for the research services provided by the Research Analyst (RA) and RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of, the client. Thus, the clients are advised not to permit RA to execute any trade on their behalf.

2. The fee charged by RA to the client will be subject to the maximum of amount prescribed by SEBI/ Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for Individual and HUF Clients).

Note:

2.1. The current fee limit is Rs 1,51,000/- per annum per family of client for all research

services of the RA.

2.2. The fee limit does not include statutory charges.

2.3. The fee limits do not apply to a non-individual client / accredited investor.

3. RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one quarter. In case of pre-mature termination of the RA services by either the client or the RA, the client shall be entitled to seek refund of proportionate fees only for unexpired period.

4. Fees to RA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognized RAASB).

5. The RA is required to abide by the applicable regulations/ circulars/ directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.

6. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the RA.

7. The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA’s research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of

preparation/publication of research report.

8. Any investment 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 any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the client’s own judgement and assessment of the conclusions contained in the research report.

9. The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.

10. For any grievances,

Step 1: the client should first contact the RA using the details on its website or following

contact details:

(RA to provide details as per ‘Grievance Redressal / Escalation Matrix’)

Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through

SEBI’s SCORES platform at www.scores.sebi.gov.in

Step 3: The client may also consider the Online Dispute Resolution (ODR) through the

Smart ODR portal at https://smartodr.in

11. Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.

12. The RA shall never ask for the client’s login credentials and OTPs for the client’s Trading Account Demat Account and Bank Account. Never share such information with anyone including RA.

 PMLA (ANTI MONEY LAUNDERING) POLICY

Introduction:
This policy is framed and adopted as a requirement by SEBI under the Prevention of Money Laundering Act, 2002 (“PMLA”). The policy provides a framework with respect to anti money laundering measures to be taken by Bidyut Biswas (Individual), as a SEBI registered Research Analyst vide Registration Number INH000014368

Objective of the PMLA Policy:
The objective of the PMLA policy are as follows:
1. To prevent Bidyut Biswas from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities.
2. Create awareness and provide clarity on KYC standards and AML measures.
3. To have a proper Client Due Diligence (CDD) process before registering clients.
4. To monitor and report suspicious transactions.
5. To monitor / maintain records of all cash transactions done by the client of the value of more than Rs.10 lacs.

I. Client Due Diligence (CDD) Process:
As a part of Client Due Diligence process Bidyut Biswas will do the following:
1. Maintain a record of Know Your Customer (KYC) documents (i.e valid identity proof and address proof) obtained from all the client at the time of on boarding the clients.
2. In order to verify the genuineness of the clients, to speak with the clients before proceeding with any advisory services.
3. The records between the client and Bidyut Biswas to be maintained in proper order.

II. Policy for Acceptance of Client:
Bidyut Biswas will ensure that-
a. No account shall be opened in fictitious name or on an anonymous basis.
b. No account will be opened if the fee for services is offered by the client in cash.
c. No account is opened where Bidyut Biswas is unable to apply appropriate CDD measures/ KYC policies. This shall apply to cases where the information provided to Bidyut Biswas is suspected to be non - genuine, or there is perceived non - cooperation of the client in providing full and complete information.
d. It will be ensured that the identity of the client does not match with any person having known criminal background or is not banned in any other manner or is included in the list of individuals and entities which are subject to various sanction measures such as freezing of assets/accounts, denial of financial services etc., as approved by the Security Council Committee established pursuant to various United Nations' Security Council Resolutions (UNSCRs) can be accessed at its website at http://www.un.org/sc/committees/1267/consolist.shtml.
e. Each client shall be classified in low or medium or high risk categories depending upon the risk perception. Such risk may be arrived considering various factors of risk perception of the client having regard to:-
- clients’ location (registered office address, correspondence addresses and other addresses if applicable),
- nature of business activity, trading turnover etc. and
- manner of making payment for transactions undertaken.
f. Clients of Special Category (CSC) require higher degree of due diligence and regular update of Know Your Client (KYC) profile.
Clients of Special Category (CSC) shall include:
i. Non - resident clients;
ii. High net-worth clients;
iii. Trust, Charities, Non-Governmental Organizations (NGOs)and organizations receiving donations;
iv. Companies having close family shareholdings or beneficial ownership;
v. Politically Exposed Persons (PEP);
vi. Companies offering foreign exchange offerings;
vii. Clients in high risk countries where existence / effectiveness of money laundering controls is suspect;
viii. Non face to face clients;
ix. Clients with dubious reputation as per public information available etc.

III. Suspicious Transactions
1. Bidyut Biswas will ensure that that appropriate steps are taken to enable suspicious transactions to be recognized based on the circumstances like-
a. Clients whose identity verification is difficult or client is not ready to cooperate.
b. Where the source of funds of the clients is not clear or not keeping with clients apparent standing/ business activity;
c. Substantial increases in business without apparent cause;
d. Clients based in high risk jurisdictions;
e. Clients transferring large sums of money to or from overseas locations with instructions for payment in cash;
f. Attempted transfer of investment proceeds to apparently unrelated third parties;
g. Unusual transactions by CSCs and businesses undertaken by offshore banks/financial services, businesses reported to be in the nature of export- import of small items.

2. In the event of any suspicious transaction, Bidyut Biswas will make a report based on the reference to the clients, transactions and the nature/ reason of suspicion. The report will be submitted to the Director, Financial Intelligence Unit-India.

3. In the event where the transactions are abandoned or aborted by clients on being asked to give some details or to provide documents, Bidyut Biswas will report all such attempted transactions in Suspicious Transaction Reports, even if not completed by clients, irrespective of the amount of the transaction.

IV. Monitoring of transactions:
The transactions shall be monitored in the following manner:
a. Special attention shall be paid to all complex unusually large transactions / patterns which appear to have no economic purpose.
b. Internal threshold limits for each class of client accounts shall be defined and special attention shall be paid to transactions which exceeds these limits.
c. The background including all documents/office records /memorandums/clarifications sought pertaining to such transactions and purpose thereof shall also be examined carefully and findings shall be recorded in writing.
d. Further the findings, records and related documents shall be made available to auditors and also to SEBI/stock exchanges/FIUIND/ other relevant Authorities, during audit, inspection or as and when required.
e. These records shall be preserved for a period of five years from the date of transaction with such client.
f. The following transactions shall be monitored at all times:
i. all cash transactions of the value of more than ten lakh rupees or its equivalent in foreign currency;
ii. all series of cash transactions integrally connected to each other which have been individually valued below rupees ten lakh or its equivalent in foreign currency where such series of transactions have taken place within a month and the monthly aggregate exceeds an amount of ten lakh rupees or its equivalent in foreign currency;
iii. all cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine or where any forgery of a valuable security or a document has taken place facilitating the transactions;
iv. all suspicious transactions whether or not made in cash and by way of cheques, pay orders, travellers cheques, demand drafts, loan and advances, money transfer or remittances in favour of own clients or non-clients from India or abroad and to third party beneficiaries in India or abroad, credits or debits into or from any non-monetary accounts such as d-mat account.
g. Periodic review of the existing account shall be conducted to ensure that no existing accounts are linked to any of the entity or individual included in the list by Security Council Committee. Any resemblance found to be reported to SEBI and FIU-IND.

V. Record Keeping and Retention of Records:
1. In case of suspicious transactions, Bidyut Biswas will -
a. ensure compliance with the record keeping requirements contained in the SEBI (Research Analyst) Regulations, 2014, PMLA and other relevant legislation.
b. maintain such records as are sufficient to permit trail of individual transactions (including the amount and types of currencies involved, if any) so as to provide, if necessary, evidence for prosecution of any criminal behaviour.
c. retain the following information for the accounts of the clients in order to maintain a satisfactory audit trail so that in case of any suspected drug related or other laundered money or terrorist property, the competent investigating authorities can trace through the audit trail for reconstructing a financial profile of the suspected account:
i. the beneficial owner of the account; and
ii. for selected transactions, the origin of funds, the form in which the funds were offered or withdrawn, e.g. cheques, demand drafts etc, the identity of the person undertaking the transaction, the destination of the funds and, the form of instruction and authority.
2. Record of the transactions shall be preserved and those transactions of a suspicious nature shall be reported to the Director, FIU-IND.
3. Record of information related to transactions, whether attempted or executed, which are reported to the Director, FIU‐IND and shall be maintained and preserved for a period of five years from the date of the transaction with the client. In situations where the records relate to on-going investigations or transactions which have been the subject of a suspicious transaction reporting, they shall be retained until it is confirmed that the case has been closed.

VI. Information to be maintained:
Following information in respect of all transactions referred to Clause V.f of this policy shall be maintained:
a. the nature of the transactions;
b. the amount of the transaction and the currency in which it is denominated;
c. the date on which the transaction was conducted; and
d. the parties to the transaction.

VII. Reporting to Financial Intelligence Unit-India:
In terms of the PML Rules, Bidyut Biswas will report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) at the following address:
Director,
FIU-IND, Financial Intelligence Unit-India,
6th Floor, Hotel Samrat, Chanakyapuri, New Delhi-110021.
Website: http://fiuindia.gov.in

VIII. Appointment of Principal Officer and Designated Director:

To ensure effective discharge of our legal obligations, to report suspicious transactions to the authorities and overall supervision and compliance, the following shall be the “Principal Officer” and “Designated Director” who would act as a central reference point for the identification and assessment of potentially suspicious transactions and in facilitating onward reporting of suspicious transactions to FIU:

i. Name: Bidyut Biswas
  Designation: Research Analyst
  Email Id: bidbiswasofficial@gmail.com & Info@LearnTinvest.com.
  Phone Number: +91 7584933039 & +91-9535760744

IX. Rights, Obligation and Responsibilities of Principal Officer:
a. The principal office shall have all time access to customer identification data and other CDD information.
b. The principal officer shall have complete independence and authority to access.
c. The principal officer shall ensure that the PMLA Policy framework is implemented effectively.
d. The principal officer shall ensure data generated on FIU on suspicious transaction is regularly and promptly downloaded to analyze, identify and report transactions of suspicious nature to FIU-IND directly.
e. The principal officer shall ensure that the records and information in relation to all client and transaction are available on timely basis to the competent authority.
f. The principal officer shall ensure that there is a prompt response to any request for information, including KYC related information and records maintained by Bidyut Biswas, made by the regulators, FIU-IND and other statutory authorities.
g. The principal officer shall ensure all concerned staff is regularly updated regarding any changes / additions / modifications in PMLA provisions.

X. Rights, Obligations and Responsibilities of Designated Director:
a. The Designated Director should ensure that all the records are maintained as mentioned in this Policy.
b. In case where the Designated Director fails to perform his duties, he shall be penalised and appropriate action may be taken against him.

XI. Employees’ Hiring/ Employee’s Training/ Investor Education:
Bidyut Biswas will-
a. have adequate screening procedures in place to ensure high standards when hiring employees.
b. have ongoing employee training programme so that the members of the staff are adequately trained in Anti-Money Laundering standards (AML) and Combating the Financial of Terrorism (CFT) procedures.  

XII. Review of Policy:
The policy shall be reviewed from time to time as and when required changes will be implemented as per the applicable rules, laws, acts and regulations.