Agreement
Mr.HARSH VARDHAN (Proprietor STOCK OCEAN) SEBI Registered Research Analyst No. INH000011006
Service Agreement
THIS RESEARCH ANALYST SERVICES AGREEMENT (the “Agreement”) BETWEEN Client and (Proprietor STOCK OCEAN), a registered research analyst with SEBI Registration No. INH000011006
Registered Office – 103 Shiv Sunder Apartment, 42 – A PWD COLONY JODHPUR, Rajasthan 342001
Principle Place of Business – A-B 2nd FLOOR NIRMAL TOWER, 1st Chopasani Road, JODHPUR , 342001 (hereinafter referred to as the “RESEARCH ANALYST” which expression shall unless excluded by or repugnant to the context, be deemed to include its administrators and permitted assigns) of the FIRST PART And Client (hereinafter referred to as the “CLIENT ” which expression shall unless it be repugnant to the context or be deemed to mean and include, its administrators & permitted assigns) of the SECOND PART;
Both RESEARCH ANALYST and the CLIENT shall also hereinafter individually refer to as Party & collectively as Parties. Whereas the CLIENT is desirous of availing the stock recommendation services in respect of the research analysis of the financial products from the Research Analyst on the terms & conditions as described hereinafter.
APPOINTMENT OF THE Research Analyst
In accordance with the applicable laws, the client hereby appoints, entirely at his / her / its risk, the Research Analyst to provide the required services in accordance with the terms and conditions of the agreement as mandated under SEBI/HO/MIRSD/-POD-2/P/CIR/2023/90 (Research Analyst) Regulations, 2014.
CONSENT OF THE CLIENT
“I / We have read and understood the terms and conditions of Financial Products Such as (Equity, Derivatives, Commodities) services provided by the Research Analyst, Disclosure document along with the fee structure and mechanism for charging and payment of a fee.” “Based on our written request to the Research Analyst, an opportunity was provided by the Research Analyst to ask questions and interact with ‘person(s) associated with the investment Recommendations”.
DECLARATION FROM THE Research Analyst
Research Analyst shall neither render any stock recommendations nor charge any fee until the client has signed this agreement.
Research Analyst Harsh Vardhan (Proprietor of Stock Ocean) does not give recommendations in Mutual Fund AMFI (ARN-260923)(E488237) And Insurance Sector (GC CODE HCG231056191201) to avoid interest of conflict.
We declare that we will keep clients of Research Analyst separate from Mutual Fund and Insurance.
The Research Analyst shall not manage funds and securities on behalf of the client, and it shall only receive such sums of money from the client as are necessary to discharge the client’s liability towards fees owed to the Research Analyst.
Research Analyst shall not, in the course of performing its services to the client, hold out any investment Recommendations implying any assured returns or minimum returns or target return or percentage accuracy or service provision till achievement of target returns or any other nomenclature that gives the impression to the client that the stock recommendations is risk-free and/or not susceptible to market risks and or that it can generate returns with any level of assurance.
Research Analyst shall charge fees from a client under any one mode i.e. (A) or (B) on a Monthly basis or annual basis. The change of mode shall be affected only after 12 months of onboarding/last change of mode.
If agreed by the client, Research Analyst may charge fees in advance. However, such an advance shall not exceed fees for 2 quarters or Subject to Client Discretion.
In the event of premature termination of the Research Analyst services in terms of the agreement, the client shall be refunded the fees for the unexpired period.
However, Research Analyst may retain a maximum breakage fee of not greater than a one-quarter fee. Research Analysis Services holds its fee structure as per service delivered.
FEES APPLICABLE TO THE CLIENT AND BILLING
Details of Fees to be charged are the following:
Product / Service subscribed: Product/ Service Subscribed Index Option Number of Calls 01-02 Calls per day Type Intraday Only Delivery Via SMS
The quantum and manner of payment of fees for investment Recommendations rendered. Amount (Quantum) Mode of Payment(In Words of Rupees Rupees Only) NEFT/ RTGS/IMPS/UPI
Fee modalities and periodicity, by attaching a detailed fee schedule to the agreement; Fees accepted strictly by account payee crossed cheques / demand draft or by way of direct credit into my bank account through NEFT/ RTGS/IMPS/UPI.
Cash deposits are not accepted for any of the service provided.
Illustration(s) on how the fee will be determined; 1. Fixed fee mode based on selected product
Whether payment to be made in advance; 1. Fees are payable in advance at the time of onboarding, in case the product is having a validity of fewer than 6 months. 2. Fees of two-quarters payable in advance at the time of onboarding, in case the product is having a validity of more than 6 months, the next payment will fall due on completion of 6 months
type of documents evidencing receipt of payment of fee; -Payment Receipt.
EXAMPLE-
Periodicity of billing with clear date and service period. S. No. Periodicity of billing with clear date Service Package Service Period 1 10th May 2022 Index Option 0 Days The payment of fees shall be through any mode which shows traceability of funds. Such modes may include account payee crossed cheque/ Demand Drafts or by way of direct credit to the bank accounts through NEFT/ RTGS/ IMPS/ UPI or any other mode specified by SEBI from time to time.
However, the fees shall not be in cash. Research Analyst shall receive fee by giving recommendations in equity, derivatives and commodities in bank account associated with HARSH VARDHAN PROPRIETOR OF STOCK OCEAN from the client only and not from any person other than the client being Recommended, in respect of the underlying securities or investment products for which the Recommendations is or to be provided.
SCOPE OF SERVICE
A research analyst studies companies and industries, analyses raw data, and makes forecasts or recommendations about whether to buy, hold or sell securities. Research Analyst analyses information to provide recommendations about investments in securities to the clients.
Research Analyst may provide some or all the following services to the Client:
Assist in assessing the risk profile. Develop investment recommendations based on goals & risk profile and assist in implementing these recommendations. Provide recommendations with respect to the investment in equity and commodities and other financial assets excluding Mutual Funds and Insurance, as needed, and assist in implementing recommendations. Provide recommendations in any other areas of financial products in which research analyst or Client identifies a need.
DUTIES & FUNCTIONS OF THE RESEARCH ANALYST
Research Analyst shall provide Recommendations Services on FINANCIAL PRODUCTS to the Client during the term of this Agreement on investment in all financial/investment products except Mutual Funds and Insurance under all regulated authorities as is permitted under applicable laws and regulations governing research analyst & the financial industry. The services rendered by the research analyst are non-binding, non-recourse advisory in nature and the final decision on the type of instruments; the proportion of exposure and tenure of the investments shall be taken by the Client at its discretion.
The Research Analyst shall act in a fiduciary capacity as one of the Analyst to the Client will be providing all back-end support services. The Research Analyst shall act in a bonafide manner for the benefit and the interest of the Client. The Research Analyst shall be in compliance with the SEBI (Research Analyst) Regulations, 2014 and its amendments, rules, circulars, and notifications.
The RESEARCH ANALYST shall be in compliance with the eligibility criteria as specified under the RESEARCH ANALYST Regulations at all times. Pursuant to the SEBI (RESEARCH ANALYST) REGULATIONS, 2014 guidelines with respect to Risk Profiling and Suitability Assessment, RESEARCH ANALYST shall conduct proper risk profiling and risk assessment for each of the clients. As per risk analysis, risk capacity, risk aversion & client requirement, the RESEARCH ANALYST needs to ensure that correct product/service as per client risk tolerance capacity is being offered, which is suitable for client. RESEARCH ANALYST shall provide reports to clients on potential and current investments if requested.
RESEARCH ANALYST shall maintain client-wise KYC, Recommendations, risk assessment, analysis reports of investment Recommendations and suitability, terms and conditions document, rationale of Recommendations, related books of accounts and a register containing list of clients along with dated investment Recommendations in compliance with the SEBI (RESEARCH ANALYST) Regulations, 2014. RESEARCH ANALYST shall get annual compliance audit conducted as per the SEBI (RESEARCH ANALYST) Regulations, 2014.
RESEARCH ANALYST undertakes to abide by the Code of Conduct as specified in the Third Schedule of the SEBI (RESEARCH ANALYST) Regulations, 2014.
RESEARCH ANALYST shall not receive any consideration in any form, if the client desires to avail the services of intermediary recommended by RESEARCH ANALYST.
INVESTMENT OBJECTIVE AND GUIDELINES
Research Analyst (RA) would provide recommendations with respect to investment in equity & derivatives & commodities.
RESEARCH ANALYST undertakes to recommend direct implementation of Recommendations i.e. Demat Accounts or as the case may be. RESEARCH ANALYST shall provide recommendations based on the risk profiling conducted for the client, total budgeted investment amount of the client and time period for deployment as informed by the client.
RESEARCH ANALYST shall communicate the tax related aspects pertaining to recommendations and as applicable on the RESEARCH ANALYST fee, if any.
RISK FACTORS Investments in securities are subject to market risks and there is no assurance or guarantee that the objective of the investments will be achieved; Past performance of the Research Analyst does not indicate its future performance. The performance of the investments/products may be affected by changes in Government policies, general levels of interest rates and risks associated with trading volumes, liquidity and settlement systems in equity and debt markets. Investments in the products which the Clients have opted are subject to wide range of risks which inter alia also include but not limited to economic slowdown, volatility & illiquidity of the stocks, poor corporate performance, economic policies, changes of Government and its policies, acts of God, acts of war, civil disturbance, sovereign action and /or such other acts/ circumstance beyond the control of Research Analyst or any of its Associates. The names of the products/nature of investments do not in any manner indicate their prospects or returns.
The performance in equity may be adversely affected by the performance of individual companies, changes in the market place and industry specific and macro-economic factors.
Investments in debt instruments and other fixed income securities are subject to default risk, liquidity risk and interest rate risk. Interest rate risk results from changes in demand and supply for money and other macroeconomic factors and creates price changes in the value of the debt instruments. Under NO Conditions the Research Analyst OR any member associated with the Firm can be held personally or cumulatively responsible for any financial loss directly or indirectly incurred in the stock market.
The Research Analyst has the responsibility to give the best research and recommendations with the intention of generating returns to the client subject to inherent risk of the stock market.
There is no assurance or guarantee of returns or capital safety of the client due to unavoidable market volatility or unpredictable high irrational moves.
The client accepts the nature of business risk and capital risk involved in the stock market & cannot held responsible to RA OR it’s Employees of the firm for any unprecedent loss of returns or capital involved in trading & Investment Activities.
VALIDITY OF RECOMMENDATION SERVICES
The validity of this agreement starts from the date of signing and will continue to be in force till any of the parties terminate it by giving 1 months’ notice period or as per tenure mentioned & agreed upon.
TERMINATION
This Agreement may be terminated under the following circumstances, namely- (a) Voluntary / mandatory termination by the Research Analyst. (b) Voluntary / mandatory termination by the client. (c) Suspension/Cancellation of registration of Research Analyst by SEBI. (d) Any other action taken by other regulatory body/ Government authority. In case of a voluntary termination of the agreement, the client would be required to give a 30 days prior written notice while the Research Analyst would be required to give a 30 days prior written notice. In case of suspension of the certificate of registration of the RA, the client may terminate the agreement.
IMPLICATIONS OF AMENDMENTS AND TERMINATION
Notwithstanding any such termination, all rights, liabilities and obligations of the parties arising out of or in respect of transactions entered into prior to the termination of this relationship shall continue to subsist and vest in/be binding on the respective parties or his/its respective heirs, executors, administrators, legal representatives or successors, as the case may be; In case the clients are not satisfied with the services being provided by the RESEARCH ANALYST and want to terminate/ stop Investment recommendations services or the RESEARCH ANALYST is unable to provide services, either party shall have a right to terminate SERVICES AND business relationship at any time subject to refund of fee after deducting one quarters fee & taxes in case termination is initiated by the clients and refund of the proportionate post Gst of recommendation fee in case termination is initiated by RESEARCH ANALYST. The RESEARCH ANALYST would transition support, if requested, to the client in the event of termination.
RELATIONSHIP WITH RELATED PARTIES:
Research Analyst is carrying on its activities independently, at an arms-length basis from all other activities RESEARCH ANALYST does not have any conflict of interest of the stock recommendation activities with its relationship with related parties, such conflict of interest shall be disclosed to the client as and when they arise.
Research Analyst ENGAGED IN OTHER ACTIVITIES RESEARCH ANALYST maintains an arms-length relationship between its activities as an RESEARCH ANALYST and other activities and shall ensure that this arm’s length relationship would be maintained throughout the tenure of service. RESEARCH ANALYST shall not provide any distribution services. Family of an individual RESEARCH ANALYST shall not provide distribution services to the client Recommended by the RESEARCH ANALYST, for securities and investment products. RESEARCH ANALYST shall not provide investment advisory services, for securities and investment products, to a client who is receiving distribution services from other family members;
REPRESENTATION TO CLIENT RESEARCH ANALYST
shall ensure that it will take all consents and permissions from the client prior to undertaking any actions in relation to the securities or investment product Recommended by the RESEARCH ANALYST.
NO RIGHT TO SEEK POWER OF ATTORNEY The RESEARCH ANALYST shall not seek any power of attorney or authorizations from its clients for implementation of RECOMMENDATIONS.
NO CONFLICT-OF-INTEREST
RESEARCH ANALYST does not have any conflict of interest of the any recommendation activities, such conflict of interest shall be disclosed to the client as and when they arise. RESEARCH ANALYST shall not derive any direct or indirect benefit out of the client’s securities/investment products.
MAINTENANCE OF ACCOUNTS AND CONFIDENTIALITY RESEARCH ANALYST shall be responsible for maintenance of client accounts and data as mandated under the SEBI (RESEARCH ANALYST ) Regulations, 2014. RESEARCH ANALYST shall not divulge any confidential information about its client, which has come to its knowledge, without taking prior permission of its client, except where such disclosures are required to be made in compliance with any law for the time being in force.
LIABILITY OF RESEARCH ANALYST shall not incur any personal or cumulative liability by reason of any loss, which a client may suffer by reason or any depletion in the value of the assets under Recommendations, which may result by reason of fluctuation in asset value, or by reason of non-performance or under-performance of the securities/funds or any other market conditions.
REPRESENTATIONS AND COVENANTS Research Analyst – Mr. HARSH VARDHAN, Email id – vardhanharsh548@gmail.com
Certification Qualification MBA (Finance). 1. NISM-XV RESEARCH ANALYST Certification Proprietor is RESEARCH ANALYST registered with SEBI as RESEARCH ANALYST with Registration No. INH000011006.
SETTLEMENT OF DISPUTES AND PROVISION FOR ARBITRATION
No suit, prosecution or another legal proceeding shall lie against the RESEARCH ANALYST for any damage caused or likely to be caused by anything which is done in good faith or intended to be done under the provisions of the Securities and Exchange Board of India (RESEARCH ANALYST ) Regulations, 2014.
This Agreement is subject to the rules and regulations as are or may be framed/ issued by the Central Government, the Reserve Bank of India (RBI), SEBI, and/or any other competent authority, from time to time. All disputes, differences, claims, and questions whatsoever arising from this Agreement between the Client and RESEARCH ANALYST and/or their respective representatives touching these presents shall be in accordance with and subject to the provisions of The Arbitration and Conciliation Act, 1996, or any statutory modification or re-enactment thereof for the time being in force. Such arbitration proceedings shall be held at Indore and the language of the arbitration will be English.
ADHERENCE TO GRIEVANCE REDRESSAL TIMELINES RESEARCH ANALYST shall be responsible for resolving the grievances within the timelines specified under SEBI circulars.
SEVERABILITY
If any provision of this Agreement shall be held or made invalid by a court decision, statute, rule, or otherwise, the remainder of this Agreement shall not be affected thereby.
FORCE MAJEURE
The RESEARCH ANALYST shall not be liable for delays or errors occurring by reason of circumstances beyond its control, including but not limited to acts of civil or military authority, national emergencies, work stoppages, fire, flood, catastrophe, acts of God, insurrection, war, riot, or failure of communication or power supply. In the event of equipment breakdowns beyond its control, the RESEARCH ANALYST shall take reasonable steps to minimize service interruptions but shall have no liability with respect thereto.
MISCELLANEOUS
Each party agrees to perform such further actions and execute such further agreements as are necessary to effectuate the purposes hereof Client shall go through the Disclosure Document and Disclaimer before subscribing to the services of the RESEARCH ANALYST to make an informed decision for engaging RESEARCH ANALYST before investing. The client shall complete the risk profiling questionnaire before subscribing to the product/services suitable to the client Agreed and Accepted
(Proprietor STOCK OCEAN) Mr. HARSH VARDHAN.
Example –
Moderate risk investor – This type of investor is able to accept investment loss occasionally and is willing to take the small risk associated with the market. The services recommended will be in equity cash segment.
High-risk investor – This type of investor is keen on opportunities to generate a high return and is able to accept substantial risk and can accept quite high investment loss. (They are traders in nature and look for speculative gains opportunities in stock markets and are exposed to derivatives F & O Trading.)
So, it is our responsibility to inform and explain each and everything to the client about the risk involved in trading and investment in stock markets, which can help substantial loss to the tune of erosion of capital involved. Our services are fee-based which does not include any commission or remuneration, referral fee, or any other payment from any third party or person. The main purpose of preparing this report is to complete the KYC, Risk Profiling, and ‘Client’s service provider agreement’.
The suitability of an investment for a particular person is the very heart of the investment process. This is a fundamental concept both from a legal perspective and in terms of putting investors’ money to work sensibly and prudently. As per Securities Exchange Board of India (SEBI), RESEARCH ANALYST Regulations 2014 regulations which gives details about the point which are mentioned in the suitability report being provided to the client
For Client PARTICULARS DETAILS NAME OF CLIENT … DATE OF BIRTH … RISK SCORE … RISK PROFILE High – Preferred Service Future, Option, Commodity SERVICE Index Option RISK NATURE High – Preferred Service Future, Option, Commodity Risk Bearing Capacity Service Details.
PARTICULARS DETAILS NAME OF SERVICE Index Option SUBJECT MATTER
The recommendation are based on fundamental and technical analysis.
FREQUENCY OF SERVICE In this service, we provide Intraday plus holding Recommendations MARKET NSE RISK NATURE High – Preferred Service Future, Option, Commodity Risk Past performance is not evidence for future success, but in every field, the benchmark is important for comparison.
Past performance indicates how the service is profitable for the client and prepares the benchmark for calculating profitability and accuracy. We have attached our track sheet record of the services which indicates the success ratio of the Service. The risk profile of Name Of Client indicates that he is a «High» Risk bearer client, in his investment, and the services we recommended for him match his Risk profile. The client is ready to bear all types of Risk. The client is satisfied with the Risk Profile Client is aware of the risk factor involved in the market and service. The client is agreed to all the Disclosures, Terms and conditions, and disclaimers that are mentioned on the website.
ASSESSMENT DONE BY HARSH VARDHAN PROPRIETOR OF STOCK OCEAN SEBI Registered Research Analyst Registration No. INH000011006 with Client (Proprietor STOCK OCEAN) Disclosure Document The particulars given in this Disclosure Document have been prepared in accordance with SEBI (RESEARCH ANALYST) Regulations, 2014. The purpose of the Document is to provide essential information about the stock recommendations Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging Research Analyst before investing.
Descriptions about “Research Analyst” History, Present business, and Background Research Analyst is registered with SEBI as RESEARCH ANALYST with Registration No. INH000011006. The firm got its registration on 06/12/2022 and is engaged in Research Analyst. The focus of an RESEARCH ANALYST is to provide Stock Recommendations to the clients. RESEARCH ANALYST aligns its interests with those of the client and seeks to provide the best-suited Recommendations based on the client’s risk profile. The RESEARCH ANALYST 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. The RESEARCH ANALYST conducts frequent stock, derivatives, commodities reviews and suggests any corrective action/s if required.
Terms and conditions of HARSH VARDHAN PROPRIETOR OF STOCK OCEAN are detailed in the client agreement.
Please refer to the same for details. Disciplinary history i. No penalties/directions have been issued by SEBI under the SEBI Act or Regulations made thereunder against the RESEARCH ANALYST relating to Stock Recommendations services. ii. 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 Research Analyst or its Directors, or employees. Affiliations with other intermediaries RESEARCH ANALYST has no affiliation with any other SEBI registered intermediaries. Disclosures with respect to Research Analyst own holding position in financial products/securities: Research Analyst may hold a position in the financial products/ securities Recommended in its personal portfolio. Details of the same may be referred to through the disclosures made at the time of Recommendations.
Disclosures with respect to any 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 stock recommendations services.
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 stock recommendations services.
Such conflict of interest shall be disclosed to the client as and when they arise.
Disclosure of all material facts relating to the key features of the products or securities, particularly, performance track record, warnings, disclaimers etc.
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 Research Analyst.
Such product materials may also be available at www.moneycontrol.com, Investing.com, www.sebi.gov.in or www.nseindia.com, or the respective issuer’s website. Drawing client’s attention to warnings, disclaimers in documents, and advertising materials relating to investment products. The Research Analyst draws the client’s attention to the warnings, disclaimers in documents, and advertising materials relating to an investment product that is being recommended to the client. A brief regarding the risk associated with the investment products is available in the client agreement, same may be referred to before investing in Recommended products or securities. Mr. HARSH VARDHAN
(Proprietor STOCK OCEAN) SEBI Registered Registration No. INH000011006 (Type of Registration- Individual, Validity of Registration- 5 December 2027).
For Client (Proprietor STOCK OCEAN) SEBI Registered Research Analyst No-INH000011006
Disclaimer
STOCK OCEAN DOES NOT provide any kind of free trial of services to any client.
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The information and views on the website & all the services we provide are believed to be reliable, but we do not accept any responsibility (or liability) for errors of fact or opinion. Users have the right to choose the product/s that suit them the most.
All investment in Financial Products is subject to market Risk.
There is no guarantee of return.
Investment in equity shares has its own risks. Sincere efforts have been made to present the right investment perspective. The information contained herein is based on analysis and on sources that we consider reliable. We, however, do not vouch for the consistency or the completeness thereof. This material is for personal information, and we are not responsible for any loss incurred due to it & take no responsibility whatsoever for any financial profits or loss which may arise from the recommendations above.
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Stock trading is inherently risky, and you agree to assume complete and full responsibility for the outcomes of all trading decisions that you make. All comments and posts made by STOCK OCEAN is for information purposes only and under no circumstances should be used for actual trading.
Under no circumstances should any person at this site make trading decisions based solely on the information discussed herein.
We are qualified Research Analyst, and we provide all the market-based information to keep our clients informed about the real-time changes happening in the financial market, complete information provided by us consist of factual information which helps you to understand the movement of the market through the investment Recommendations we provide. It is completely informative in nature.
You should strictly abide by the consultation provided by the qualified research analyst at Stock Ocean and trade only as per the stock recommendation provided by us. You agree not to make actual stock trades based on comments on the site, nor on any techniques presented or discussed on this site or any other form of information presentation. All information is for educational and informational use only. Unlike an actual performance record, simulated results do not represent actual trading. No representation is being made that any account will or is likely to achieve profits or losses similar to those shown.
HARSH VARDHAN PROPRIETOR OF STOCK OCEAN has a license to provide stock recommendations. Harsh Vardhan Proprietor of STOCK OCEAN is a registered research analyst. You understand and acknowledge that there is a very high degree of risk involved in trading securities. Past results of any trader published on this website are not an indicator of future returns by that trader and are not an indicator of future returns which be realized by you.
Any surfing and reading of the information is the acceptance of this disclaimer. All Rights Reserved (Proprietor HARSH VARDHAN) SEBI Registered Research Analyst Registration No. INH000011006 (Type of Registration- Individual, Validity of Registration- 5 December 2027)
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NOTE : Investment in stock or commodity market are subjected to market risk, before taking recommendation & any services with Stock Ocean, client should read disclaimer, terms and conditions, refund policy. Past Performance is not a Guarantee of Future Performance. Stock Ocean does not claim/give any assured returns, profit sharing, commitment and guaranteed plan. Please beware of fraudulent calls.
No. of Complaints | At the Beginning of Month | Received During The Month |
---|---|---|
1 | 0 | 0 |
Pending at the end of the Month | Reason for Pendency | Total Complaint Resolved |
0 | - | 1 |
Total Clients Served so far | Total Complaint Received so far | % of the complaints as per overall client base |
100 | 1 | 1 |