Windmill Capital Private Limited (hereinafter referred to as “the Company” or “WCPL”) is involved in research activities in Indian capital markets, as a SEBI-registered Research Analyst w.e.f. June 25, 2020. WCPL is registered as a Private Limited Company under the Companies Act, 2013, incorporated under the Bangalore ROC. The CIN number of the company is U74999KA2020PTC132398, and the date of incorporation is February 06, 2020. The registered office and the correspondence address of the Company is No 51, 3rd Floor, Le Parc Richmonde,, Richmond Road, Shanthala Nagar, Bangalore – 560025

The Company has neither been suspended nor debarred from doing business by any Stock Exchange / SEBI or any other authorities; nor has its certificate of registration been cancelled by SEBI at any point of time.

The Company is not engaged in merchant banking, investment banking or any brokerage services.

Unless otherwise stated, the percentage returns displayed on the website or any other marketing materials are Absolute Returns.

The Company has assumed some portfolios originally created by its holding company Smallcase Technologies Private Limited (STPL), a SEBI registered Research Analyst, whose registration was voluntarily surrendered to SEBI effective 18th November 2020. STPL had taken registration as a Research Analyst effective 18th June 2018 having registration number INH200005984. The Company retains and maintains these portfolios under the same name & methodology as used originally.

Reports or research material prepared by the company are not to be construed as an offer to buy /sell or the solicitation of an offer to buy / sell any security in any jurisdiction where such offer or solicitation would be illegal. Reports or research material prepared by the company do not constitute a personal recommendation or take into account the particular investment objectives, financial situations, risk profile and needs of individual clients.

While we endeavour to update the information / material on various products and reports created by us, on a reasonable basis, there may be regulatory, compliance or other reasons that prevent us from doing so.

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.

The Company does not provide any promise or assurance of favourable 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.

The Company’s holding company Smallcase Technologies Private Limited (STPL) is a shareholder in Zerodha Asset Management Private Limited (Zerodha AMC), which is the asset manager for Zerodha Mutual Fund. The Company’s research recommendations may include mutual funds and ETFs managed by Zerodha AMC. The Company states that its research recommendations are made independently and objectively based on their merits and suitability without any influence due to STPL being a shareholder in Zerodha AMC.

Details of our Associates/Affiliates:

Smallcase Technologies Private Limited (STPL; incorporated as a Private Limited Company under the Companies Act, 2013), (Holding 100% shares of the Company) bearing CIN: U74900KA2015PTC081722 with its registered office at No 51, 3rd Floor, Le ParcRichmonde Richmond Road, Shantala Nagar Bangalore, 560025. STPL holds a Mutual Fund Distributor registration (ARN 276729) granted by the Association of Mutual Funds in India (AMFI), which is valid from September 21, 2023 till September 20, 2026. STPL is also registered with AMFI as a ‘Category – I Execution Only Platform’ bearing registration number CAT-1 EOP -0004, which is valid from 21-Sep-2023 to 20-Sep-2026.

Telephone number: 080 71175775

E-mail address: help@smallcase.com

Anchorage Technologies Private Limited (ATPL; a wholly-owned subsidiary of STPL and incorporated as a Private Limited Company under the Companies Act, 2013) having CIN: U74220KA2021PTC142979 with its registered office at #51, 3rd Floor, Le Parc Richmonde, Richmond Road, Shanthala Nagar, Richmond Town, Bangalore - 560025. ATPL holds a Mutual Fund Distributor registration (ARN 253554) granted by the AMFI, which is valid from September 20, 2022 till September 19, 2025.

Telephone number: 080 71175775

E-mail address: support@tickertape.in

Essential Investment Managers Private Limited (EIMPL; a wholly-owned subsidiary of STPL and incorporated as a Private Limited Company under the Companies Act, 2013) is registered with SEBI as a non-individual Investment Adviser with INA000017912, as the SEBI registration number. The said registration is valid perpetually from April 24, 2023. EIMPL is also enlisted with BSE Limited as a member having membership ID 1981. The CIN number of EIMPL is U74999KA2021PTC145058 with its registered office address as: No 51, 3rd Floor, Le Parc Richmonde, Richmond Road, Shanthala Nagar, Bangalore – 560025

Telephone number: 080 29915553

E-mail address: support@essentialadviser.com

Nexum Finvest Private Limited (NFPL; a wholly-owned subsidiary of STPL and incorporated as a Private Limited Company under the Companies Act, 2013) bearing CIN U64990KA2023PTC172732 with its registered office address as: No 51, 3rd Floor, Le Parc Richmonde, Richmond Road, Shanthala Nagar, Bangalore – 560025

Telephone number: NA

E-mail address: help@nexumfinvest.in

Zerodha Asset Management Private Limited (ZAMPL; incorporated as a Private Limited Company under the Companies Act, 2013) bearing CIN: U67190KA2021PTC155726 with its registered office address as: INDIQUBE PENTA New No. 51 (Old No.14), Richmond Road, Bangalore - 560025. STPL is a shareholder in ZAMPL. ZAMPL is an asset manager to Zerodha Mutual Fund, a SEBI-registered mutual fund house bearing registration number MF/080/23/06, valid perpetually from Aug 11, 2023.

Telephone number: NA

E-mail address: support@zerodhafundhouse.com

Research Analyst Disclosures:

Research Analyst has served as an officer, director or employee of subject company(ies): No
We or our associates may have received compensation from the subject company(ies) in the past 12 months.
We or our associates have managed or co-managed public offering of securities for the subject company(ies) in the past 12 months: No
We or our associates have not received compensation for investment banking or merchant banking or brokerage services from the subject company(ies) in the past 12 months.
We or our associates may have received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company(ies) in the past 12 months.
We or our associates may have received compensation or other benefits from the subject company(ies) or third party in connection with the products or reports created by the company. Our associates may have financial interest in the subject company(ies).
Research Analyst or his/her relative's financial interest in the subject company(ies): No
The company has financial interest in the subject company(ies) at the end of the month immediately preceding the date of sharing of products or reports created by the company: No
Nature of financial interest is holding of equity shares or derivatives of the subject company - Our associates do not have actual/beneficial ownership of 1% or more securities of the subject company(ies) at the end of the month immediately preceding the date of sharing of products or reports created by the company.
The subject companies may have been a client during the twelve months preceding the development and/or publication of products or reports created by the company and has received any compensation for services rendered to such subject company.
Research Analyst or his/her relatives has actual/beneficial ownership of 1% or more securities of the subject company(ies) at the end of the month immediately preceding the date of sharing of products or reports created by the company.: No
The Company has actual/beneficial ownership of 1% or more securities of the subject company(ies) at the end of the month immediately preceding the date of sharing of products or reports created by the company: No
The employees of the Company are permitted to transact in Exchange Traded Funds (ETF’s) without any restrictions upto a specified limit in accordance with Company Policy. Intra-day transactions in ETF’s are however, not permitted.

Details of the Board of Directors / Key Managerial Personnel:

Mr. Anugrah Shrivastava (DIN 07044041) holds an M.Sc. in Economics from IIT, Kharagpur.
Mr. Vasanth Sanoor Kamath (DIN 07214307) holds an M.Sc. in Economics from IIT, Kharagpur.
Mr. Naveen K R (DIN 10384003) holds an M.B.A. in Finance from the NUS Business School. Mr Naveen K R is also the Principal Officer of the Company.

Support - Contact us at support@windmill.capital for any queries and assistance.

All grievances should be addressed to our grievance officer Mr Mayank Bansal using compliance@windmill.capital

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