Disclosures & Investor Charter

1. Research Analyst — registration & regulatory details

The following are the registration and identification details of the Research Analyst behind MindForge Capital, as required under the SEBI (Research Analysts) Regulations, 2014 and applicable circulars.

2. Standard disclaimer

3. Investor Charter — vision & mission

Vision. To follow the highest standards of transparency, integrity, and fair dealing in providing systematic, rules-based research so that investors can take informed decisions with a clear understanding of the process, the assumptions, and the risks involved.

Mission. To publish factor-based research and model portfolios that are objective, disclosed in full, and free of assured-return or guaranteed-profit claims; to keep investors informed of all conflicts of interest; and to redress investor grievances promptly and fairly.

4. Services provided to investors

• Publication of independent, rules-based equity research and model portfolios (across the strategies listed on this website), rebalanced on a stated schedule.
• Educational tools — the Stock Scanner, the Integrity Score, the Factor Report, the Fee Calculator and the FII/DII activity report — provided for information and learning only.
• Disclosure of the methodology, factors, lookback windows, sector caps, and assumptions behind each strategy so subscribers understand what they are following.

We do not offer portfolio management, discretionary trading, fund handling, guaranteed returns, or personalised (one-to-one) investment advice tailored to your individual financial situation.

5. Rights of investors

• Right to receive research and disclosures that are fair, unbiased, and free of misleading or guaranteed-return claims.
• Right to full disclosure of any conflict of interest, holding, or compensation that could affect the objectivity of the research.
• Right to privacy and confidentiality of personal information, used only for the stated purpose.
• Right to a transparent fee structure with no hidden charges.
• Right to have grievances acknowledged and redressed within the stated timelines, and to escalate to SEBI (SCORES) and the ODR portal if unresolved.

6. Do's and Don'ts for investors

7. Investor grievance redressal & escalation matrix

If you have a complaint, please follow the escalation levels below. We aim to acknowledge every grievance within 1 working day and resolve it within 21 calendar days of receipt.

1. Level 1 — Research Analyst
   Write to Sagar Shekhawath (Principal / Compliance Officer) at sagar.shekhawath@mindforgecapital.com with your name, the nature of the grievance, and any reference details.
   Acknowledgement: within 1 working day · Resolution: within 21 calendar days.
2. Level 2 — SEBI SCORES
   If not resolved satisfactorily, lodge a complaint on SEBI's SCORES portal: scores.sebi.gov.in. SCORES is SEBI's centralised online complaint-redressal system for the securities market.
   SEBI SCORES — SEBI Complaints Redress System.
3. Level 3 — Online Dispute Resolution (Smart ODR)
   If you remain dissatisfied after the above, you may initiate dispute resolution through the SEBI-recognised ODR portal: smartodr.in, which provides online conciliation and arbitration.
   Smart ODR — Online Dispute Resolution in the Indian securities market.

8. Complaints disclosure

Disclosure of investor complaints, as required by SEBI. Figures are maintained and updated monthly by the Research Analyst.

Data as on: July 2026. Nil complaints for the current reporting period. This table is updated on or before the 7th of each month.

9. Research Analyst disclosures

Disclosures under Regulation 24 of the SEBI (Research Analysts) Regulations, 2014, with respect to the research published on this website:

• The Research Analyst and MindForge Capital do not offer any assured, guaranteed, or risk-free returns.
• Compensation is received solely as a flat subscription fee for research access; the Research Analyst does not receive any commission, brokerage, or performance-linked payment from any company, broker, or third party in connection with the securities covered.
• The Research Analyst may personally hold positions in securities that appear in the model portfolios; where a material financial interest exists, it is disclosed. The Research Analyst has not received any compensation from the subject companies in the past twelve months.
• The Research Analyst is not engaged in market-making, investment banking, or brokerage for the subject companies, and does not hold any directorship in them.
• Research is prepared on an objective, rules-based basis; the analyst's compensation is not tied to any specific recommendation or view.

10. Advertisement & performance-claim standards

In line with SEBI's advertisement code for Research Analysts, this website does not carry any assured-return, guaranteed-profit, or "risk-free" claims; does not use superlatives that cannot be substantiated; and presents past or backtested performance only with the required caveats. Backtested and hypothetical results have inherent limitations, do not reflect actual trading, and are not a promise of future performance.

11. Backtest methodology & known limitations

Every performance figure on this website is backtested and hypothetical — a simulation of what a rules-based model would have selected in the past. No client money was managed over these periods and no orders were placed. This section sets out how those numbers are produced and, more importantly, where they are known to be optimistic. It is published so the figures can be read with the same caveats we apply to them internally.

How the simulation works

The two equity strategies. LargeMidcap and SmallMicro each rank a fixed universe of listed stocks on a published factor model, take the top 10 and top 15 respectively, subject to a cap of two per industry, hold them for one month, then re-rank and rebalance. Returns are equal-weighted across holdings and are net of an assumed one-way transaction cost — 10 bps for LargeMidcap and 20 bps for SmallMicro, applied to turnover.

MultiAsset works differently, and its simulation charges no costs at all. It rotates across eight ETFs rather than ranking a stock universe, so there is no per-sector cap, and its weights come from each ETF's composite score rather than an equal split. It rebalances every month like the other two — but unlike them, its backtest applies no transaction cost whatsoever. Monthly rotation across eight funds is real turnover, and charging nothing for it makes MultiAsset's published figures more optimistic than the equity strategies' on this axis, not less. We state it rather than average it into a range.

The benchmark is the real index. Every benchmark figure shown beside a strategy is measured from the actual index's actual path over the same dates as the strategy — so the benchmark's own CAGR, Sharpe and drawdown all describe the same window, and "months beating the benchmark" means what it says. Two constructions are worth naming: the Nifty LargeMidcap 250 is not published as a downloadable series, so it is reconstructed from the Nifty 100 and the Nifty Midcap 150 held at NSE's stated 50:50 large:mid allocation — a faithful rebuild of the published methodology, but a rebuild; and the SmallMicro strategy is benchmarked against the Nifty Smallcap 250 alone, because the Nifty Microcap 250 only launched in Jan 2024 and no long-run series exists for the combined index. The strategy's universe still spans Smallcap 250 + Microcap 250; its benchmark does not.

Every published return is after tax

What changed, and why. Every backtested CAGR, benchmark CAGR and alpha figure on this website is stated after tax. It was not always so. A monthly rebalance never holds a position for twelve months, so every gain these strategies book is a short-term capital gain, taxed at 20% under s.111A the month it is booked. The mutual funds and index funds a reader would compare them against are bought and held, so their investor pays 12.5% long-term under s.112A once, at exit, on gains above ₹1,25,000 — and pays nothing in between, which is the part that compounds. Publishing our gross figure beside their net one would have flattered these strategies by precisely that gap, so both sides are now shown after their own tax.

The method used, and it is the harsh one. Tax is charged on every month that books a profit, at 20%, with no set-off of losing months — and it is paid out of the portfolio, so its drag compounds. Indian law is kinder than this: gains and losses may be netted across the financial year and a net loss carried forward for eight years (s.74), which on these same curves produces materially higher post-tax figures. The harsher reading is published deliberately, because a performance claim should be the conservative one. The gentler figures are computed and retained internally.

What is not modelled. No surcharge, no cess, and no basic-exemption limit — the figures assume an investor whose other income already exceeds the threshold. Advance-tax instalment timing is simplified to the date each gain is booked. Our own subscription fee is not deducted from the strategy figures, while a fund's expense ratio is already inside its published return; where the two are compared like for like the subscription is named and netted out explicitly. Securities transaction tax, stamp duty and brokerage beyond the stated one-way transaction cost are not modelled.

MultiAsset is the exception worth naming. Its book holds gold, silver and debt ETFs alongside equity ETFs. Only the equity sleeves are s.111A instruments; short-term gains on the gold, silver and debt sleeves are taxed at the investor's slab rate, not 20%. A single 20% rate is applied across the whole book because per-sleeve tax needs per-sleeve realised gains the simulation does not record. For an investor in the 30% slab, MultiAsset's published post-tax figure is therefore optimistic.

Rupee illustrations assume a stated capital. Because the ₹1,25,000 long-term exemption is a fixed rupee amount, a comparison's outcome depends on how much is invested. The capital assumed for each strategy's tax arithmetic is printed beside the figures. None of this is tax advice; your own rate, slab, set-offs and holding period will differ, and you should take your own.

Known limitations — stated plainly

• Survivorship bias — the most material limitation, and it inflates the returns shown. Each strategy's universe is built from the companies that are listed today. Companies that were delisted, suspended, merged away or wound up during the backtest window are simply absent from that list, so the simulation never holds them and never takes their losses. The published returns are therefore higher than a bias-free simulation would produce, by an amount we cannot currently measure. Correcting it requires point-in-time index constituents and price history for dead companies — data we do not have. We disclose this rather than estimate a correction we cannot substantiate. Note this cuts one way only: the index a strategy is measured against carries its own failed constituents, while the strategy's universe does not.
• These figures were revised upward in July 2026, and here is exactly why. Until then the benchmark was not the index at all — it was a constant long-run CAGR taken from index factsheets and compounded smoothly across the window. Because the real indices returned less over this particular window than their long-run averages (the Nifty Smallcap 250 returned 16.9% a year over the backtest period, against the 19.1% constant previously shown), replacing the constant with the real index path increased the stated alpha. A first-period error in the CAGR calculation, corrected at the same time, also moved LargeMidcap up. We are stating this plainly because a performance figure that moves up deserves more explanation than one that moves down, not less.
• Costs are assumed, and are on the optimistic side. On the two equity strategies the transaction-cost assumption is a flat one-way rate applied to turnover. It does not separately model STT, exchange and regulatory charges, bid-ask spread, or market impact — which matter most in the small- and micro-cap names, where turnover is highest. On MultiAsset no cost is charged at all, so every basis point of its monthly eight-ETF rotation is free in the simulation and will not be in your broker.
• Stale prices in thin names. Illiquid stocks that do not trade every session carry their previous close forward, which understates measured volatility and can flatter any volatility-sensitive factor.
• Window lengths differ by strategy, and MultiAsset's is much shorter. LargeMidcap and SmallMicro are simulated over roughly five years (2021–2026). MultiAsset covers Feb 2023 – Aug 2026 — one of its constituent ETFs has no history before then — and both its figures are measured over that entire span: the benchmark is a buy-and-hold of the Nifty 50 from the first day, and the strategy's first 13 months, during which the model holds no positions while its 12-month momentum signals warm up, are counted at 0% return. This is the conservative construction — measuring only from the month the model is first invested would show a materially higher strategy CAGR against a materially lower benchmark. Roughly three and a half years is still a thinner evidence base than the equity strategies. Treat it accordingly.
• One historical window is not a forecast. These results describe a single, largely rising market. They are not a projection, not a promise, and give no assurance that the same rules will produce similar results in future.