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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 in the past twelve months, unless 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

• Investment in securities market are subject to market risks. Read all the related documents carefully before investing.
• Past performance is not indicative of future results. No assured, guaranteed, or fixed returns are offered under any circumstances.
• Recommendations and research reports are based on publicly available information and analyst judgment. They do not constitute personal investment advice, solicitation, or an offer to buy or sell any securities.
• Investors should exercise independent judgment and, where appropriate, consult their own financial advisers before acting on any recommendation contained in the research reports.
• 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 notice.

Compliance Audit

An annual compliance audit is conducted in terms of Regulation 25(3) of 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 RAASB/SEBI within the prescribed timelines.

Status: Compliant — No adverse findings

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This policy is maintained in compliance with the Code of Conduct prescribed under the Fourth Schedule of SEBI (Research Analysts) Regulations, 2014, which mandates the right to privacy and confidentiality of clients.

Information We Collect

• 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 recordings, SMS messages, and other correspondence as mandated under Regulation 25 of RA Regulations for a minimum period of five years.

How We Use Your Information

• To provide research services and deliver research reports as agreed upon in the terms and conditions.
• To comply with regulatory requirements including KYC norms, AML obligations, and periodic reporting to SEBI and RAASB.
• To communicate service-related information, research recommendations, and updates.

Data Protection Measures

• All client data is kept confidential and is not shared with any third party unless required by law or with the specific consent of the client.
• Adequate technical and organizational measures are implemented to protect client data against unauthorized access, alteration, or destruction.
• Client data is stored within the legal boundaries of India in compliance with SEBI advisory on SaaS-based solutions.

Your Rights

• Right to access your personal information held by us.
• Right to request correction of any inaccurate information.
• Right to confidentiality — information shared by clients is kept confidential unless required to be provided in furtherance of discharging legal obligations.

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

Nature of Services

• Research services include the preparation and publication of research reports containing analysis, recommendations, and opinions on securities.
• The terms and conditions and the consent thereon are for the research services provided by the RA. The RA cannot execute or carry out any trade (purchase/sell transaction) on behalf of the client.
• Research reports and recommendations are for informational purposes only and do not constitute personal investment advice.

Fees & Payment

• Fees are charged as per the limits specified by SEBI under Regulation 15A of RA Regulations. All applicable fees are disclosed to the client prior to commencement of services.
• Fees may be paid through cheque, online bank transfer, UPI, or other banking channels. Cash payment is not permitted.
• Advance fee shall not exceed one quarter. In case of premature termination by either the client or the RA, proportionate refund for the unexpired period is available.
• Clients may optionally use the Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (RAASB) for transparent fee payment.

Client Obligations

• The client shall keep contact details including email and mobile number updated with the RA at all times.
• The client shall not share the research reports received with any third party without the consent of the RA.
• Any investment made based on recommendations in research reports is subject to market risks. The client acknowledges that there is no recourse to claim any losses incurred on investments made based on the research reports.

Limitations

• The RA shall never ask for the client's login credentials or OTPs for trading, demat, or bank accounts. The client must never share such information with anyone including the RA.
• Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law and are not offered.
• The client will not be bound by any clause prescribed by the RA which contravenes any regulatory provision.

This policy is framed in accordance with 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 tenure of the subscription by providing a written request (via email or letter) to the Research Analyst.
• Upon receipt of the cancellation request, the RA shall process the cancellation within 7 business days and confirm the same to the client.
• The client will not be bound by any clause that restricts the right to cancel or that contravenes any regulatory provision.

Cancellation by Research Analyst

• The RA reserves the right to discontinue services to a client with reasonable notice, provided the reasons are communicated to the client in writing.
• In the event of cancellation by the RA, the client shall be entitled to a proportionate refund for the unexpired period.

Refund Policy

• In case of premature termination of research services by either the client or the RA, the client shall be entitled to seek a refund of proportionate fees only for the unexpired period of the subscription.
• Advance fee collected shall not exceed one quarter (as per SEBI regulations). Any advance fee for the unexpired period post-cancellation shall be refunded.
• Refunds shall be processed within 15 business days from the date of acceptance of the cancellation request.
• Refunds shall be made through the same payment mode used for the original transaction or through banking channels (cheque, bank transfer, UPI). No cash refunds shall be processed.

Non-Refundable Charges

• Any fees for the period during which services were actively rendered prior to the cancellation request shall not be refundable.
• One-time onboarding or KYC processing charges, if any, are non-refundable.

Dispute Resolution

• Any disputes regarding refunds shall first be addressed to the Grievance Officer of the RA.
• If unresolved, the client may escalate the matter to SEBI SCORES (scores.sebi.gov.in) or the Online Dispute Resolution portal (smartodr.in).

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 will be kept confidential and not shared without consent or legal obligation.
• Right to Transparent Practices — Clear and complete disclosure of all terms, fees, conditions, and methodology of research services.
• Right to Fair and Equitable Treatment — Non-discriminatory distribution of research reports and fair treatment regardless of client category.
• Right to Adequate Information — Access to all relevant information necessary for making informed investment decisions.
• Right to Initial and Continuing Disclosure — All statutory and regulatory disclosures including conflict of interest, financial interest, and compensation disclosures.
• Right to Fair and True Advertisement — No misleading claims, assured returns, or superlative terms in any communication.
• Right to Awareness about Service Parameters and Turnaround Times — Timelines for each service and research report delivery communicated clearly.
• Right to be Heard and Satisfactory Grievance Redressal — Timely acknowledgment and resolution of complaints within prescribed timelines.

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 analyst judgment. They do not constitute personal investment advice, solicitation, or an offer to buy or sell any securities.
• The RA does not guarantee any assured, guaranteed, or fixed returns. Research reports do not assure profitability of any recommendation.
• Investors should exercise independent judgment and consult their own 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 (GST, etc.).
• Advance Fee: The RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI — presently one quarter (3 months).
• Refund on Termination: In case of premature termination of RA services by either the client or the RA, the client shall be entitled to seek a refund of proportionate fees only for the unexpired period.
• Payment Modes: Fees may be paid through cheque, online bank transfer, UPI, or other specified electronic modes. Cash payment is not allowed.
• CeFCoM: Optionally, the client can make payments through the Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (RAASB).

Conflict of Interest & Disclosures

• The RA is required to abide by applicable SEBI regulations, circulars, and directions regarding disclosure and mitigation of any actual or potential conflict of interest.
• The RA will promptly inform the client of any conflict of interest that may affect the services being rendered.
• The RA and its associates shall not trade in securities they follow or recommend: 30 days before and 5 days after issuing a research report, and shall not trade contrary to their own recommendations.

Client Rights & Grievance

• The client has the right to terminate the RA's services at any time as per the agreed terms of service.
• In case of any grievance, the client should first approach the RA directly. If not resolved within 30 days, the complaint may be escalated to SEBI SCORES (scores.sebi.gov.in), and thereafter to the Online Dispute Resolution platform (smartodr.in).
• The RA shall not impose any clause that 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 and understood the risk disclosures and the terms governing the research services.
• The RA shall not be responsible for any investment decision taken by the client based on the 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 through verified electronic modes only.

UPI payment QR code for —

• Cash payment is strictly not allowed per SEBI regulations.
• Accepted modes: Cheque, Online Bank Transfer, UPI, NEFT/RTGS.
• Optional: Centralised Fee Collection Mechanism (CeFCoM) via BSE Limited (RAASB).
• Advance fee shall not exceed one quarter. Proportionate refund available for premature termination.