SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 | February 17, 2025 Immediate Effect

Issued under Regulation 24(6) of SEBI (Research Analysts) Regulations, 2014 · Standardised by Industry Standards Forum (ISF) in consultation with RAASB & SEBI

Most Important Terms & Conditions

Forming part of the Terms and Conditions for providing Research Services

Research Analyst

Ashutosh Soni

SEBI Reg. No.

INH000025869

Regulated By

SEBI / RAASB (BSE Ltd.)

Effective Date

February 17, 2025

Mandatory Disclosure — Please Read Carefully These Most Important Terms and Conditions (MITC) have been standardised by the Industry Standards Forum (ISF) in consultation with RAASB and SEBI, and are mandatorily incorporated into the Terms and Conditions of Research Services as required by SEBI Circular dated February 17, 2025. Client consent to these MITC is required before availing any research service.

These terms and conditions govern the research services provided by Ashutosh Soni (SEBI Registered Research Analyst, INH000025869). By subscribing to or using any research service on this platform, the client acknowledges having read, understood, and consented to each of the following Most Important Terms and Conditions as mandated by SEBI.

Section A — Nature of Services & Trading Restriction

Research Services Only — No Trade Execution

These terms and conditions, and the consent provided hereon, are exclusively for research services provided by the Research Analyst (RA). The RA cannot execute or carry out any trade (purchase or sell transaction) on behalf of the client under any circumstance. Critical

Clients are strictly advised not to permit the RA to execute any trade on their behalf. If any person claims to trade on behalf of the RA, clients must immediately report such activity to SEBI / RAASB.

Section B — Fee Structure & Payment

Fee Limit — Individual & HUF Clients

The fee charged by the RA to the client shall be subject to the maximum amount prescribed by SEBI / RAASB from time to time. This fee ceiling is applicable only for Individual and HUF Clients.

2.1 Current Fee Limit: ₹1,51,000/- per annum per family of the client, for all research services of the RA.

2.2 Statutory Charges Excluded: The fee limit does not include applicable statutory charges (such as GST).

2.3 Non-Individual / Accredited Investors: The fee limits do not apply to non-individual clients or accredited investors — fees for such clients are mutually agreed upon by written contract.

Advance Fee & Refund on Premature Termination

The RA may collect fees in advance only if agreed upon by the client. Such advance shall not exceed one quarter (3 months) as currently stipulated by SEBI. Refundable

In case of premature termination of research services by either the client or the RA, the client shall be entitled to a refund of proportionate fees for the unexpired period. No penalty or breakage fee shall be charged for such termination.

Permitted Modes of Payment — Cash Not Allowed

Fees to the RA may be paid through any of the following specified modes:

Cheque · Online Bank Transfer (NEFT / RTGS / IMPS) · UPI · and other modes as specified by SEBI / RAASB.

Prohibited Cash payment is strictly not allowed under any circumstance.

Optional Clients may optionally make payments through the Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited (currently recognised RAASB) for additional safety and transparency.

Section C — Conflict of Interest & Prohibited Schemes

Conflict of Interest Disclosure & Mitigation

The RA is required to abide by all applicable SEBI and RAASB regulations, circulars, and directions relating to the disclosure and mitigation of any actual or potential conflict of interest.

The RA shall endeavour to promptly inform the client of any conflict of interest that may affect the research services being rendered. Full disclosure shall be made in the relevant research report wherever applicable.

Guaranteed / Fixed Returns Schemes — Strictly Prohibited

Prohibited by Law Any assured, guaranteed, or fixed returns schemes, or any other schemes of a similar nature, are prohibited by law.

No scheme of this nature shall be offered to any client by the RA at any time. If any person associated with this platform offers such schemes, clients must immediately report the same to SEBI / RAASB.

Section D — Risk Disclosures & Limitations

No Guarantee of Returns, Profits, or Accuracy

The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of research services. All opinions, projections, and estimates provided by the RA are based on the analysis of available data under certain assumptions, as of the date of preparation or publication of the research report.

Research reports reflect the analyst's independent opinion at a specific point in time. Market conditions, corporate events, and economic factors may change subsequent to publication, affecting the validity of any recommendation.

Market Risk — Client's Own Judgement & No Recourse for Losses

Any investment made based on recommendations in research reports is subject to market risks. Recommendations do not provide any assurance of returns. Important

There is no recourse to claim any losses incurred on investments made based on research recommendations. Any reliance placed on a research report provided by the RA shall be as per the client's own judgement and independent assessment of the conclusions contained in the report.

Clients are strongly advised to consider their own risk appetite, financial position, and investment objectives before making any investment decision.

SEBI Registration Does Not Guarantee Performance

SEBI Registration (INH000025869), enlistment with RAASB, and NISM certification of the RA do not guarantee the performance of the RA or assure any returns to the client.

These regulatory credentials signify that the RA has met prescribed eligibility, qualification, and compliance requirements. They are not an endorsement of any specific research recommendation or a warranty of profitable outcomes.

Section E — Grievance Redressal

Grievance Redressal & Escalation Matrix

In case of any grievance related to research services, clients must follow the below escalation matrix in the prescribed sequence:

Contact the Research Analyst directly using the contact details provided on the website (email, phone, or registered address). The RA shall endeavour to resolve the grievance within 10 working days of receipt.

If resolution is unsatisfactory, lodge the grievance on SEBI's SCORES (Securities and Exchange Board of India Complaint Redress System) platform. scores.sebi.gov.in

Online Dispute Resolution (ODR) — The client may also consider seeking resolution through SEBI's Smart ODR portal for mediation and conciliation. smartodr.in

Section F — Client Obligations & Security

Client Obligation — Keep Contact Details Updated

Clients are required to keep their contact details — including registered email address and mobile number(s) — updated with the RA at all times.

Prompt communication of any change in contact details ensures that research reports, compliance communications, MITC updates, and any regulatory notices are received without interruption. Failure to maintain updated contact details may affect the delivery of services.

Critical Security The RA shall never ask for the client's login credentials, OTPs, passwords, or any access information related to the client's:

Trading Account · Demat Account · Bank Account · Any financial or personal platform

Never share such information with anyone — including the RA, any staff member, or any person claiming to represent the RA. If any such request is made, it must be treated as fraudulent activity and reported immediately to the RA and to SEBI / RAASB.

This MITC document forms a mandatory part of the Terms and Conditions of Research Services as required under Regulation 24(6) of SEBI (Research Analysts) Regulations, 2014. SEBI Registration does not guarantee the quality of research services or any returns. Investments in securities markets are subject to market risks. Read all related documents carefully before investing.