Disclosures

Last updated 21 September 2026 · Version 2026-09

Disclosures under Regulation 19, Regulation 20 and Schedule III of the SEBI (Research Analysts) Regulations, 2014, and the SEBI Master Circular for Research Analysts. These apply to all research published by Sugam Kashyap; report-specific disclosures appear on each report.

Business activity

Sugam Kashyap is an individual Research Analyst offering research services on listed Indian equities. The Research Analyst is not a broker, investment adviser, portfolio manager or distributor and does not receive any compensation from the subject companies.

Disciplinary history

No penalty, disciplinary action, order or enquiry has been initiated by SEBI or any other regulatory or statutory authority against the Research Analyst.

Financial interest and conflicts

• The Research Analyst or his relatives may hold positions in securities covered in research. Such holdings, and any holding of 1% or more in a subject company, are disclosed on each report.
• The Research Analyst has not received any compensation from the subject company in the past twelve months, has not managed or co-managed a public offering for the subject company, and has no other material conflict of interest at the time of publication, except as disclosed on the report.
• The Research Analyst does not deal in securities contrary to his published recommendation for the period restricted under the regulations, except as permitted (for example, on account of financial hardship or a change in view, which is then disclosed).
• No part of the Research Analyst's compensation is linked to specific recommendations or views.
• The Research Analyst has not served as an officer, director or employee of any subject company.

Terms of service, fees and consent

Research services are offered only after the client has been provided the Terms and Conditions including the Most Important Terms and Conditions (MITC) and has given consent. Fees are within the limits prescribed by SEBI. KYC records, consent records and client communications are maintained for a minimum of five years.

Model portfolios

If any model portfolio or basket is recommended, it is issued as a research report and follows SEBI's model portfolio framework — stated methodology, label, horizon, rebalancing frequency and benchmark, with a research report for each constituent. [Remove if not offered.]

Complaints

Complaint data is published monthly on the Complaints Data page. Grievances may be escalated to SEBI SCORES and the SMART ODR portal.

Compliance audit

The annual compliance audit under Regulation 25(3) is conducted by a qualified professional; the status and any adverse observations are published on the Compliance Audit page.