Last updated: 10 August 2026
The publisher of The Microcap Minute Global is separately a registered distributor of Portfolio Management Services in India. That is a different activity from this publication, conducted with different people under different rules, and this page sets out the rules it is conducted under. The registration details follow at the foot of the page.
The Microcap Minute Global is not a distribution activity.
The newsletter is impersonal commentary of general and regular circulation, covering securities listed on exchanges outside India. It does not distribute, market, solicit or recommend any Portfolio Management Service, any scheme, or any product for which the publisher is a distributor. No portfolio manager pays for coverage in it, sponsors it, contributes to it, or has any say in what appears.
Nothing in the newsletter earns the publisher distribution commission. The companies that appear in an issue are selected by the tests published in our Methodology, applied to market data. Whether the publisher distributes anything, and to whom, has no bearing on that process at any stage.
For completeness, the newsletter does earn one thing besides subscriptions. The publication participates in the StockAnalysis.com affiliate programme and may earn a commission when a reader subscribes to that service through a link in an issue, at no cost to the reader. That arrangement is disclosed in full in the Disclaimer, it is with a data provider rather than with any portfolio manager, and it is not distribution commission. It is mentioned here so that this page is not read as claiming the newsletter has only one source of income.
So there are three income streams and they do not touch: subscriptions to the newsletter, the data affiliate arrangement disclosed in the Disclaimer, and any commission earned as a distributor, which is a separate activity with separate customers and is discussed only on this page.
Where distribution does take place, and only with the persons to whom it takes place, the Code of Conduct for PMS Distributors set by the Securities and Exchange Board of India applies in full. These are the commitments it creates.
The investor’s interest comes first, in all circumstances. Their interest and the suitability of a strategy to their financial needs are the starting point of every conversation, not a check applied at the end of one.
All commissions are disclosed. Any person to whom a Portfolio Management Service is distributed is told all material information about it, including every commission received for soliciting that strategy, before they commit to anything.
No returns are indicated or assured. Not in conversation, not in writing, not by implication, for any strategy, ever.
Commission never drives a recommendation. A higher commission on one strategy than another is not a reason to put anybody into it. No commission is rebated to an investor, and no gift or inducement of any kind is offered to attract one.
Every relationship is classified at the outset as either advisory or execution only, and that classification is disclosed to the person concerned rather than left implied.
Comparisons are made only against similar and comparable products, with complete facts. We do not make negative statements about any other portfolio manager or strategy.
Sales and promotional material follows SEBI’s requirements, including its rules on how performance may be presented. Where a strategy is discussed, the current performance report, risk factors, portfolio strategy and any deviations are provided as SEBI defines them, and assumptions are stated rather than buried.
Investor information is confidential. Details, dealings and transactions are not discussed with anyone who is not entitled to them.
High standards of ethics, integrity and fairness apply to every party, including investors, portfolio managers, advisers and other intermediaries.
The Code is published by SEBI as Annexure A3 to its Portfolio Managers framework and is public. APMI maintains the distributor register and may de-register a distributor for breaching the Code or for mis-selling.
Name: Ayush Agrawal
APMI Registration Number: APRN09522
Registered with: the Association of Portfolio Managers in India, the industry body recognised by SEBI for portfolio managers. Since 1 January 2025, any person or entity distributing Portfolio Management Services in India must be registered with APMI, under SEBI’s circular of 2 May 2024 on collective oversight of PMS distributors.
For PMS distribution queries only: ayush@ayushagrawal.in
Please use that address for anything to do with distribution, including complaints about it. It is a separate mailbox from the publication’s, and anything sent to it is dealt with separately from newsletter correspondence. Questions about the newsletter should go to hello@themicrocapminute.in, where the Grievance Officer named in our Customer Support policy will handle them.
A complaint about distribution may also be made directly to APMI, which maintains the register.
A distributor registration is not an advisory registration. It permits the holder to distribute portfolio management services. It does not make the holder an Investment Adviser, a Research Analyst, or a Portfolio Manager, and this publication does not act as any of those. Ayush Agrawal is not registered with SEBI as an Investment Adviser or as a Research Analyst.
This page solicits nothing. Nobody reading it is being offered a Portfolio Management Service, and no such service is described, named or promoted anywhere on this site or in the newsletter. If you want to know whether a distribution relationship would suit you, that is a separate conversation with a separate set of documents, and it begins at the address above rather than here.
Nothing on this page changes anything in the Disclaimer. The newsletter is not investment advice, is not a recommendation to buy or sell any security, and is not tailored to any person or their circumstances.