Conflict of Interest Policy

In accordance with Regulation 19 of SEBI (Research Analysts) Regulations, 2014, the following disclosures are made:

• Research reports are prepared independently and free from any material conflict of interest at the time of publication.
• The research analyst, associates, and relatives have no financial interest, including ownership of 1% or more of securities, in the subject company unless explicitly disclosed in each research report.
• Compensation of the research analyst is not linked to specific recommendations, views expressed, or results of research reports.
• The research analyst has not received any compensation or other benefits from the subject company or any third party in connection with the research report during the past twelve months, unless specifically disclosed.
• The research analyst does not serve as an officer, director, or employee of the subject company.
• The research analyst has not been engaged in market-making activity for the subject company.

Risk Disclosures

• Investments in the securities market are subject to market risks. Please read all related documents carefully before investing.
• Past performance is not indicative of future results. No assured, guaranteed, or fixed returns are offered under any circumstances.
• Research reports and recommendations are based on publicly available information and the independent judgment of the research analyst.
• Research reports should not be construed as personal investment advice, solicitation, or an offer to buy or sell any securities.
• Investors are advised to exercise their own judgment and consult qualified financial advisers before making any investment decisions.
• The research analyst shall not be responsible for any investment decision taken by the client based on the research report.
• All opinions, estimates, and projections contained in research reports are subject to change without prior notice.

Compliance Audit

An annual compliance audit is conducted in accordance with Regulation 25(3) of the SEBI (Research Analysts) Regulations, 2014 by a member of the Institute of Chartered Accountants of India (ICAI) or the Institute of Company Secretaries of India (ICSI). The audit report is submitted to the Research Analyst Administration and Supervisory Body (RAASB) / SEBI within the prescribed timelines.

Financial Year	Status	Remarks
2023–2024	Done	No Remarks
2024–2025	Done	The Research Analyst has not complied with the SHE Box Portal requirement during FY 2024–25.

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Use of Artificial Intelligence (AI) Tools

We may use automated tools and AI-assisted systems to enhance research analysis, operational efficiency, and service quality. However, all final recommendations, reports, and investment opinions are reviewed and approved by a SEBI-registered Research Analyst before being communicated to clients.

This Privacy & Data Protection Policy is maintained in compliance with the Code of Conduct prescribed under the Fourth Schedule of the SEBI (Research Analysts) Regulations, 2014, which mandates the protection of client privacy and confidentiality.

Information We Collect

We may collect the following information from our clients:

• Personal information provided during the Know Your Client (KYC) process, including name, address, PAN, contact details, and financial information as required under SEBI KYC norms and the Prevention of Money Laundering Act, 2002.
• Communication records including emails, telephone call recordings, SMS messages, and other correspondence as mandated under Regulation 25 of the SEBI (Research Analysts) Regulations, 2014. These records are retained for a minimum period of five (5) years.

How We Use Your Information

Your information is used solely for legitimate business and regulatory purposes, including:

• Providing research services and delivering research reports in accordance with the agreed Terms & Conditions.
• Complying with regulatory requirements, including KYC norms, Anti-Money Laundering (AML) obligations, and reporting requirements prescribed by SEBI and RAASB.
• Communicating research recommendations, service updates, account-related information, and other important notifications.

Data Protection Measures

• All client information is treated as strictly confidential and is not shared with any third party unless required by applicable law or with the client's explicit consent.
• Appropriate technical, administrative, and organizational safeguards are implemented to protect client data against unauthorized access, misuse, alteration, disclosure, or destruction.
• Client data is stored within the legal boundaries of India in accordance with applicable SEBI advisories relating to SaaS-based technology solutions.

Your Rights

As our valued client, you have the following rights:

• Right to Access: You may request access to the personal information we maintain about you.
• Right to Correction: You may request correction or updating of inaccurate or incomplete personal information.
• Right to Confidentiality: Information shared with us will remain confidential and will only be disclosed where required by law or for the purpose of fulfilling our legal and regulatory obligations.

The following Terms & Conditions govern the provision of research services in accordance with Regulation 24(6) of the SEBI (Research Analysts) Regulations, 2014. By availing our research services, the client acknowledges, understands, and agrees to the following terms.

Nature of Services

• Research services include the preparation and publication of research reports containing analysis, recommendations, and opinions relating to securities and financial markets.
• The Terms & Conditions and the client's consent apply solely to the research services provided by the Research Analyst (RA). The RA shall not execute or carry out any purchase or sale transaction on behalf of the client.
• Research reports, recommendations, opinions, and market views are provided solely for informational purposes and shall not be construed as personalized investment advice or portfolio management services.

Fees & Payment

• Fees are charged strictly in accordance with the limits prescribed by SEBI under Regulation 15A of the Research Analysts Regulations. All applicable fees are disclosed to the client before the commencement of services.
• Payments may be made through cheque, online bank transfer, UPI, NEFT/RTGS, or other approved banking channels. Cash payments are not accepted.
• The advance fee collected shall not exceed one quarter of the agreed service period. In the event of premature termination by either the client or the Research Analyst, a proportionate refund for the unexpired period shall be provided, wherever applicable.
• Clients may also choose to make payments through the Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (RAASB) for enhanced transparency and regulatory compliance.

Client Obligations

• The client shall keep all contact details, including email address and mobile number, updated with the Research Analyst at all times.
• The client shall not reproduce, distribute, publish, or share any research report or recommendation with any third party without obtaining prior written consent from the Research Analyst.
• All investments made based on research reports or recommendations are subject to market risks. The client acknowledges that investment decisions are made at their own discretion and no claim for losses arising from such decisions shall lie against the Research Analyst.

Limitations & Disclaimer

• The Research Analyst shall never ask for the client's trading account credentials, Demat account credentials, internet banking passwords, PINs, or One-Time Passwords (OTPs). Clients are advised not to share such confidential information with anyone.
• No assured, guaranteed, or fixed return schemes, profit-sharing arrangements, or similar offerings are permitted under applicable SEBI regulations and are not provided by the Research Analyst.
• No term or condition imposed by the Research Analyst shall override or contradict any provision of the SEBI (Research Analysts) Regulations, 2014, or any other applicable law.

This Refund & Cancellation Policy has been framed in accordance with the SEBI (Research Analysts) Regulations, 2014 and the guidelines issued by SEBI from time to time regarding fee collection by registered Research Analysts.

Cancellation by Client

• The client has the right to discontinue the research services at any time during the subscription period by submitting a written cancellation request through email or an official written communication to the Research Analyst.
• Upon receipt of the cancellation request, the Research Analyst (RA) shall process the request within 7 business days and communicate the confirmation to the client.
• The client shall not be bound by any clause that restricts the right to cancel or is inconsistent with the applicable provisions of the SEBI (Research Analysts) Regulations, 2014.

Cancellation by Research Analyst

• The Research Analyst reserves the right to discontinue research services by providing reasonable prior notice to the client, along with the reasons for such discontinuation.
• In the event of cancellation initiated by the Research Analyst, the client shall be entitled to a proportionate refund for the unexpired portion of the subscription period.

Refund Policy

• In the event of premature termination of research services by either the client or the Research Analyst, the client shall be eligible to receive a proportionate refund only for the unexpired period of the subscription.
• Advance fees collected shall not exceed one quarter of the agreed service period, in accordance with SEBI regulations.
• Any advance amount relating to the unexpired subscription period shall be refunded after adjustment of applicable charges, wherever necessary.
• Eligible refunds shall be processed within 15 business days from the date on which the cancellation request is accepted.
• Refunds shall be credited through the same payment mode used for the original transaction or through approved banking channels such as Cheque, NEFT/RTGS, Bank Transfer, or UPI. No cash refunds shall be processed.

Non-Refundable Charges

• Fees corresponding to the period during which research services were actively rendered before the cancellation request shall not be refundable.
• One-time onboarding charges, documentation fees, or KYC processing charges, wherever applicable, are non-refundable.

Dispute Resolution

In case of any dispute relating to cancellation or refund, the client should first approach the Grievance Officer of the Research Analyst for resolution.

If the grievance remains unresolved, the client may escalate the matter through the following SEBI-authorized grievance redressal mechanisms:

• SEBI SCORES (SEBI Complaints Redress System)
• Online Dispute Resolution (ODR) Portal (SMART ODR)

As prescribed by SEBI vide Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 dated June 02, 2025.

Rights of Investors

• Right to Privacy and Confidentiality – Your personal and financial information shall remain confidential and will not be disclosed without your consent except where required under applicable law.
• Right to Transparent Practices – Complete disclosure of all applicable fees, terms & conditions, and research methodology.
• Right to Fair and Equitable Treatment – Every client shall receive fair, unbiased, and non-discriminatory research services irrespective of investment category.
• Right to Adequate Information – Access to all relevant information necessary for making informed investment decisions.
• Right to Initial and Continuing Disclosure – Timely disclosure of conflicts of interest, financial interests, and all statutory or regulatory disclosures.
• Right to Fair and True Advertisement – No misleading statements, assured returns, or exaggerated claims shall be made in any communication.
• Right to Awareness of Service Parameters & Turnaround Time – Clear communication regarding timelines for research services and report delivery.
• Right to Timely Grievance Redressal – Complaints shall be acknowledged and resolved within the timelines prescribed under SEBI regulations.

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As prescribed by SEBI vide Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 dated February 17, 2025, read with Regulation 24(6) of the SEBI (Research Analysts) Regulations, 2014. Standardized by the Industry Standards Forum (ISF) in consultation with RAASB and SEBI.

Service Scope & Restrictions

• The Research Analyst (RA) shall provide research services limited to independent research recommendations. The RA shall not execute buy/sell transactions on behalf of clients. Investors are advised not to permit the RA to execute trades.
• Research reports and recommendations are based on publicly available information and the independent judgment of the analyst. They do not constitute personalized investment advice, solicitation, or an offer to buy or sell any securities.
• The Research Analyst does not guarantee any assured, guaranteed, or fixed returns. Research reports do not assure the profitability of any recommendation.
• Investors should exercise their own independent judgment and consult qualified financial advisers before acting on any recommendation.

Fee Structure & Payment

• Fee Cap: The maximum annual fee chargeable to Individual or HUF clients is ₹1,51,000 per annum per family, excluding applicable statutory charges such as GST.
• Advance Fee: The Research Analyst may collect fees in advance, subject to mutual agreement with the client. Such advance shall not exceed the period prescribed by SEBI, presently one quarter (3 months).
• Refund on Termination: In the event of premature termination of services by either the client or the Research Analyst, the client shall be entitled to a proportionate refund for the unexpired period only.
• Payment Modes: Fees may be paid through cheque, bank transfer, UPI, NEFT/RTGS, or other approved electronic payment methods. Cash payments are not permitted.
• CeFCoM: Clients may optionally make payments through the Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (RAASB).

Conflict of Interest & Disclosures

• The Research Analyst shall comply with all applicable SEBI regulations, circulars, and directions relating to disclosure and mitigation of actual or potential conflicts of interest.
• The Research Analyst shall promptly inform the client of any conflict of interest that may affect the services being rendered.
• The Research Analyst and its associates shall not trade in securities covered by their research during the restricted period of 30 days prior to and 5 days after the issuance of a research report, and shall not trade contrary to their own recommendations.

Client Rights & Grievance Redressal

• The client has the right to terminate the Research Analyst's services at any time in accordance with the agreed Terms & Conditions.
• In case of any grievance, the client should first approach the Research Analyst directly. If the complaint remains unresolved within 30 days, it may be escalated to SEBI SCORES and thereafter to the Online Dispute Resolution (ODR) Platform.
• The Research Analyst shall not impose any contractual clause that is inconsistent with or contravenes SEBI regulatory provisions.

Risk Acknowledgment

• Investments in securities are subject to market risks. Past performance is not indicative of future results.
• The client acknowledges having read, understood, and accepted the applicable risk disclosures and the Terms & Conditions governing the research services.
• The Research Analyst shall not be responsible for any investment decision taken by the client based on any research report or recommendation.

Reference: SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 dated February 17, 2025.

As mandated by SEBI, all fee payments must be made only through verified banking and electronic payment modes. Cash payments are strictly prohibited.

Verified UPI Payment Details

Accepted Payment Modes

• Cheque
• Online Bank Transfer
• UPI
• NEFT / RTGS

Important Guidelines

• Cash payments are strictly prohibited in accordance with SEBI regulations.
• Clients may optionally make payments through the Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (RAASB).
• Advance fees collected shall not exceed one quarter of the agreed service period, in compliance with SEBI regulations.
• In case of premature termination of services by either the client or the Research Analyst, a proportionate refund shall be provided for the unexpired period, wherever applicable.

Please ensure that payments are made only to the above verified payment details. The Research Analyst shall not be responsible for payments made to any unauthorized account or UPI ID.