Terms & Conditions

1. Availing the Research Services

By accepting delivery of the research service, the Client confirms that he/she has elected to subscribe to the research service of the RA at his/her sole discretion. RA confirms that research services shall be rendered in accordance with the applicable provisions of the RA Regulations.

2. Obligations on RA

RA and Client shall be bound by the SEBI Act and all applicable rules and regulations of SEBI, including the RA Regulations and relevant notifications of the Government, as may be in force from time to time.

3. Client Information and KYC

The Client shall furnish all such details in full as may be required by the RA in its standard form with supporting details, if required, as may be made mandatory by RAASB/SEBI from time to time.

RA shall collect, store, upload and check KYC records of the clients with KYC Registration Agency (KRA) as specified by SEBI from time to time.

4. Standard Terms of Service

The consent of Client is taken on the following understanding:

Declaration of the RA that:

• It is duly registered with SEBI as an RA pursuant to the SEBI (Research Analysts) Regulations, 2014. Registration No: INH000016816; Registration Date: 24 June 2024.
• It has registration and qualifications required to render the services contemplated under the RA Regulations, and the same are valid and subsisting.
• Research analyst services provided by it do not conflict with or violate any provision of law, rule or regulation, contract, or other instrument to which it is a party or to which any of its property is or may be subject.
• The maximum fee that may be charged by RA is ₹1,51,000 (Rupees One Lakh Fifty-One Thousand) per annum per family of client.
• The recommendations provided by RA do not provide any assurance of returns.

Additionally, as an individual RA, declaration that:

• It is not engaged in any additional professional or business activities, on a whole-time basis or in an executive capacity, which interfere with/influence or have the potential to interfere with/influence the independence of research report and/or recommendations contained therein.

5. Consideration and Mode of Payment

The Client shall duly pay to RA the agreed fees for the services that RA renders to the Client and statutory charges, as applicable. Fees are payable in advance before commencement of any service period.

Payment must be made through legitimate banking channels only — NEFT, RTGS, UPI, or other approved digital payment modes. Cash payments are not accepted. Optionally, clients may make payments through the Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognised RAASB).

Fee receipts and invoices will be provided for all payments. Fees are exclusive of applicable taxes (GST), which shall be charged additionally at prevailing rates.

Current Fee Structure

• Equity Elite: Pricing on inquiry
• Trading Pulse: Pricing on inquiry
• Model Portfolio: Pricing on inquiry
• Algo Trading Strategies: Pricing on inquiry

6. Risk Factors

Investment in securities is subject to market risks. The following standard risks are associated with investment in securities based on research recommendations:

• Market risk — the value of investments may decrease due to market movements, economic conditions, or other factors outside the control of the RA.
• Liquidity risk — certain securities may not be readily sold at desired prices.
• Sector/concentration risk — recommendations may focus on specific sectors, leading to concentrated exposure.
• Research risk — recommendations are based on analysis of publicly available information and independent assessment; they may not account for all material information or future events.
• No guaranteed returns — research recommendations do not assure profits or protect against losses. There is no recourse to claim losses arising from acting on research recommendations.

Registration granted by SEBI and certification from NISM in no way guarantee the performance of the RA or assure any returns to investors.

7. Conflict of Interest

The RA shall adhere to the applicable regulations/circulars/directions specified by SEBI from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest.

Disclosures: Vishal Trehan, as an individual RA, confirms that there is no material undisclosed conflict of interest in the research reports or recommendations provided. The RA will promptly inform clients of any conflict of interest that may arise and affect the services being rendered. The RA does not deal in securities that the research analyst follows, except as permitted under the RA Regulations.

8. Termination of Service and Refund of Fees

Either party may terminate this Agreement by providing written notice. In such cases, a pro-rata refund of unused subscription fees shall be provided for the unexpired period.

The RA may suspend or terminate rendering of research services to the Client on account of suspension/cancellation of registration of RA by SEBI and shall refund the residual amount to the Client.

In case of suspension of the certificate of registration of the RA for more than 60 (sixty) days or cancellation of RA registration, RA shall refund the fees on a pro-rata basis for the period from the effective date of cancellation/suspension to the end of the subscription period.

The RA reserves the right to suspend or terminate services without notice in cases of violation of these Terms, fraudulent activity, or regulatory non-compliance by the Client.

9. Grievance Redressal and Dispute Resolution

Any grievance related to (i) non-receipt of research report, or (ii) missing pages or inability to download the entire report, or (iii) any other deficiency in the research services provided by RA, shall be escalated promptly by the Client to the designated person:

• Name: Vishal Trehan
• Designation: Research Analyst & Compliance Officer
• Email: vishaltrehan_RA_INH000016816@outlook.com
• Phone: +91-9711490798
• Working Hours: Monday – Saturday, 10 AM – 6 PM

The RA shall be responsible to resolve grievances within 7 (seven) business working days or such timelines as may be specified by SEBI under the RA Regulations. RA shall redress grievances of the Client in a timely and transparent manner.

Any dispute between the RA and the Client may be resolved through arbitration or through any other modes or mechanism as specified by SEBI from time to time. Clients may also escalate unresolved grievances to:

• SEBI SCORES Portal: scores.sebi.gov.in
• SMARTODR (Online Dispute Resolution): smartodr.in

10. Additional Clauses

Mandatory Notice

Clients are requested to refer to the Do's and Don'ts while dealing with Research Analysts as specified in SEBI Master Circular No. SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated May 21, 2024, or as may be specified by SEBI from time to time. These are included in the Investor Charter.

Voluntary Clauses

All additional voluntary clauses in this Agreement shall not be in contravention of rules/regulations/circulars of SEBI. Any changes in such voluntary clauses/documents shall be preceded by a notice of 15 days.

Governing Law: This Agreement shall be governed by and construed in accordance with the laws of India. Any disputes shall be subject to the jurisdiction of courts in Gurgaon, Haryana.

Optional Centralised Fee Collection Mechanism (CeFCoM)

RA shall provide guidance to clients on the optional Centralised Fee Collection Mechanism for IA and RA (CeFCoM) available for payment of fees to RA, managed by BSE Limited (currently recognised RAASB).

Intellectual Property

All research reports, newsletters, strategy documents, videos, and other content provided by the RA are proprietary and protected by copyright. The Client may not reproduce, distribute, resell, or publicly share any research content without explicit written consent from the RA.

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Annexure A — Most Important Terms and Conditions (MITC)

1. These terms and conditions, and consent thereon, are for the research services provided by the Research Analyst (RA). The RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the Client. Clients are advised not to permit RA to execute any trade on their behalf.
2. The fee charged by RA to the Client will be subject to the maximum amount prescribed by SEBI/Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for Individual and HUF Clients). The current fee limit is ₹1,51,000/- (Rupees One Lakh Fifty-One Thousand) per annum per family of client for all research services of the RA. The fee limit does not include statutory charges. The fee limits do not apply to a non-individual client/accredited investor.
3. RA may charge fees in advance if agreed by the Client. Such advance shall not exceed the period stipulated by SEBI; presently it is one year. In case of pre-mature termination of the RA services by either the Client or the RA, the Client shall be entitled to seek refund of proportionate fees only for the unexpired period.
4. Fees to RA may be paid by the Client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally, the Client can make payments through Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognised RAASB).
5. The RA is required to abide by the applicable regulations/circulars/directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavour to promptly inform the Client of any conflict of interest that may affect the services being rendered to the Client.
6. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the Client by the RA.
7. The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA's research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of research report.
8. Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the Client's own judgement and assessment of the conclusions contained in the research report.
9. The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the Client.
10. For any grievances:
    • Step 1: Contact the RA at vishaltrehan_RA_INH000016816@outlook.com / +91-9711490798. Full Grievance Redressal / Escalation Matrix is available on the Regulatory Disclosures page.
    • Step 2: If the resolution is unsatisfactory, lodge grievances through SEBI's SCORES platform at scores.sebi.gov.in
    • Step 3: Consider Online Dispute Resolution (ODR) through the Smart ODR portal at smartodr.in
11. Clients are required to keep contact details, including email ID and mobile number/s, updated with the RA at all times.
12. The RA shall never ask for the Client's login credentials and OTPs for the Client's Trading Account, Demat Account, and Bank Account. Never share such information with anyone including RA.