Regulatory information

ANNEXURE D

INVESTOR CHARTER IN RESPECT OF RAs

A. Vision and Mission Statements for investors

• Vision Invest with knowledge & safety.
• Mission Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

B. Details of business transacted by the Research Analyst with respect to the investors

• To publish research report based on the research activities of the RA
• To provide an independent unbiased view on securities.
• To offer unbiased recommendation, disclosing the financial interests in recommended securities.
• To provide research recommendation, based on analysis of publicly available information and known observations.
• To conduct audit annually
• To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Research Analysts.
• To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to the research services has taken place.

C. Details of services provided to investors (No Indicative Timelines)

• Onboarding of Clients
• Sharing of terms and conditions of research services
• Completing KYC of fee paying clients
• Disclosure to Clients:
• To disclose, information that is material for the client to make an informed decision, including details of its business activity, disciplinary history, the terms and conditions of research services, details of associates, risks and conflicts of interest, if any
• To disclose the extent of use of Artificial Intelligence tools in providing research services
• To disclose, while distributing a third party research report, any material conflict of interest of such third party research provider or provide web address that directs a recipient to the relevant disclosures
• To disclose any conflict of interest of the activities of providing research services with other activities of the research analyst.
• To distribute research reports and recommendations to the clients without discrimination.
• To maintain confidentiality w.r.t publication of the research report until made available in the public domain.
• To respect data privacy rights of clients and take measures to protect unauthorized use of their confidential information
• To disclose the timelines for the services provided by the research analyst to clients and ensure adherence to the said timelines
• To provide clear guidance and adequate caution notice to clients when providing recommendations for dealing in complex and high-risk financial products/services
• To treat all clients with honesty and integrity
• To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations or a client has provided specific consent to share such information.

D. Details of grievance redressal mechanism and how to access it

1. Investor can lodge complaint/grievance against Research Analyst in the following ways:

Mode of filing the complaint with research analyst

In case of any grievance / complaint, an investor may approach the concerned Research Analyst who shall strive to redress the grievance immediately, but not

later than 21 days of the receipt of the grievance.

Mode of filing the complaint on SCORES or with Research Analyst Administration and Supervisory Body (RAASB)

i. SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner) (https://scores.sebi.gov.in)

Two level review for complaint/grievance against Research Analyst:

• First review done by designated body (RAASB)
• Second review done by SEBI

ii. Email to designated email ID of RAASB

2. If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.

With regard to physical complaints, investors may send their complaints to:

Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (E), Mumbai - 400 051

E. Rights of investors

• Right to Privacy and Confidentiality
• Right to Transparent Practices
• Right to fair and Equitable Treatment
• Right to Adequate Information
• Right to Initial and Continuing Disclosure -Right to receive information about all the statutory and regulatory disclosures
• Right to Fair & True Advertisement
• Right to Awareness about Service Parameters and Turnaround Times
• Right to be informed of the timelines for each service
• Right to be Heard and Satisfactory Grievance Redressal
• Right to have timely redressal
• Right to Exit from Financial product or service in accordance with the terms and conditions agreed with the research analyst
• Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
• Additional Rights to vulnerable consumers - Right to get access to services in a suitable manner even if differently abled
• Right to provide feedback on the financial products and services used
• Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from the investors (Responsibilities of investors)

• Do’s

i. Always deal with SEBI registered Research Analyst.

ii. Ensure that the Research Analyst has a valid registration certificate.

iii. Check for SEBI registration number. Please refer to the list of all SEBI registered Research Analyst which is available on SEBI website in the following link: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=14)

iv. Always pay attention towards disclosures made in the research reports before investing.

v. Pay your Research Analyst through banking channels only and maintain duly signed receipts mentioning the details of your payments. You may make payment of fees through Centralized Fee Collection Mechanism (CeFCoM) of RAASB if research analyst has opted for the mechanism. (Applicable for fee paying clients only)

vi. Before buying/ selling securities or applying in public offer, check for the research recommendation provided by your Research Analyst.

vii. Ask all relevant questions and clear your doubts with your Research Analyst before acting on recommendation.

viii. Seek clarifications and guidance on research recommendations from your Research Analyst, especially if it involves complex and high risk financial products and services.

ix. Always be aware that you have the right to stop availing the service of a Research Analyst as per the terms of service agreed between you and your Research Analyst.

x. Always be aware that you have the right to provide feedback to your Research Analyst in respect of the services received.

xi. Always be aware that you will not be bound by any clause, prescribed by the research analyst, which is contravening any regulatory provisions.

xii. Inform SEBI about Research Analyst offering assured or guaranteed returns.

• Don’ts

i. Do not provide funds for investment to the Research Analyst.

ii. Don’t fall prey to luring advertisements or market rumors.

iii. Do not get attracted to limited period discount or other incentive, gifts, etc. offered by Research Analyst.

iv. Do not share login credential and password of your trading, demat or bank accounts with the Research Analyst.

Trend of monthly disposal of complaints (FY 2026-27)

Trend of annual disposal of complaints

Parties to these Terms and Conditions

• Research Analyst: Tushar Gerg, a SEBI Registered Research Analyst, holding Registration No. INH000027654, with its registered office located at A-302, Plumeria Garden Estate, Omicron Sector 3, Noida, Uttar Pradesh, 201308, hereinafter referred to as the "Research Analyst" or “RA”;

• Client: The individual or entity subscribing to or availing research services provided by the Research Analyst, hereinafter referred to as the "Client."

Availing The Services

The Client hereby accepts the research services and confirms to avail the research services on its own discretion provided by the Research Analyst (“RA”), and the Research Analyst agrees to provide such services in accordance with the terms and conditions set forth underneath.

Obligations on RA and Client

The client and the Research Analyst shall be bound by all applicable regulations, rules, circulars, and amendments issued by SEBI, including the SEBI (Research Analysts) Regulations, 2014 and all the other notifications of the Government, if any from time to time.

Client Information and KYC

The client is bound, upon acceptance of services, to submit all requisite documents as requested by the research analyst and help the RA to complete the KYC process.

“The client hereby gives consent to the research analyst to fetch his KYC documents from the KYC Registration Agency (KRA).”

Standard Terms of Service

The Client acknowledges and gives his consent to be bound by the terms set forth herewith, as well as any applicable amendments or updates provided by the Research Analyst.

The client hereby agrees:

• I have read and understood the terms and conditions applicable to a research analyst as defined under regulation 2(1)(u) of the SEBI (Research Analyst) Regulations, 2014, including the fee structure.

• I am subscribing to the research services for my own benefit and consumption, and any reliance placed on the research report provided by the Research Analyst shall be based on my own judgment and assessment of the conclusions contained in the research report.

I understand that:

• Any investment made based on the recommendations in the research report is subject to market risk.
• Recommendations in the research report do not provide any assurance of returns.
• There is no recourse to claim any losses incurred on investments made based on the recommendations in the research report.

Declaration by Research Analyst

The Research Analyst further declares that,

• It is duly registered with SEBI as an RA having Registration No.: INH000027654, Date of Registration: June 01, 2026.
• It has registration and qualifications required to render the services contemplated under the RA Regulations, and the same are valid and subsisting.
• The services provided by the RA do not conflict with or violate any provision of law, rule, 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 the RA is ₹1.51 lakhs per annum per family of clients.
• The recommendations provided by the RA do not provide any assurance of returns.
• It is registered as a part-time RA. Its other business, analytics consulting for companies, is unrelated to securities, does not involve handling money or funds of any client, and does not involve investment advice or recommendations. It is not engaged in any additional professional or business activities, on a whole-time basis or in an executive capacity, that may interfere with or influence the independence of the research report and/or recommendations.
• It shall maintain an arm's-length relationship between its activity as RA and its other activities, and keep its research services clearly segregated from all its other activities at all stages of client engagement.

Consideration And Mode of Payment

• The client shall duly pay the fees to the RA of the invoice raised or for any agreed amount either written/oral within 2 days.
• The Client agrees to make all payments via: UPI/Netbanking/Payment Gateway or any other verified banking channel. Client shall not pay any fees in cash.
• The Client hereby agrees to pay the fees in the Bank account of Research Analyst only. The RA shall not be liable for any payment made to third party account.

Risk Factors

The Client understands that the services provided by the Research Analyst involve inherent risks, and the Client agrees to bear full responsibility for any financial or other consequences arising from the use of these services.

Investment in the market is subject to market risk, and is also subject to the following:

• Trading in equities, derivatives, and other securities are subject to market risks and there is no assurance or guarantee of returns.
• Past performance does not indicate future performance.
• Research recommendations may not always be profitable, as actual market movements may differ from anticipated trends.
• The Research Analyst is not responsible or liable for any losses resulting from research recommendations.
• Investment in securities market are subject to market risks. Read all the related documents carefully before investing.
• Registration granted by SEBI, enlistment with BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

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. Some of disclosures are as follows:

1. The Research Analyst or any of its officer/employee does not trade in securities which are subject matter of recommendation.

2. There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of Research Analyst services. Such conflict of interest shall be disclosed to the client as and when they arise.

3. Research Analyst or its employee or its associates have not received any compensation from the company which is subject matter of recommendation.

Client is advised to refer the detailed disclosure provided on our website.

Termination of Service and Refund of Fees

The Agreement may be terminated by the client, if the Research Analyst fails to provide the research recommendations. However, the client cannot terminate the agreement solely based on not achieving the desired returns or incurring the losses from trading on the recommendations or the client discontinues the services without a valid reason, or in case of force majeure.

The RA may suspend or terminate rendering of research services to 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 certificate of registration of the RA for more than 60 (sixty) days or cancellation of the RA registration, RA shall refund the fees, on a pro rata basis for the period from the effective date of cancellation/ suspension to end of the subscription period.

Grievance Redressal

In the event of grievances related to non-receipt of the research report, missing content, or deficiencies in services, the Client may raise a grievance. The Research Analyst will ensure Redressal within 7 (seven) business working days of such complaint.

The client is required to follow the following procedure for any grievance:

• Step 1: The client should first contact the RA at the contact details mentioned below:

Contact No.: +91 9997976746

Mail ID: tushar0708@gmail.com

• Step 2: In case, if the client is unsatisfied, he can lodge a complaint with the SEBI through SEBI’s SCORES platform at www.scores.sebi.gov.in.

• Step 3: The client can also consider to seek resolution through the Online Dispute Resolution (ODR) mechanism through SMART ODR Portal:

https://smartodr.in.

DISCLAIMER: The client is strictly required to follow the procedure as mentioned above, otherwise the RA shall not be liable delay in resolution of the grievance.

NOTE: Clients are advised to read the Do's and Don’ts for dealing with the Research Analyst, as mentioned in SEBI Master Circular for Research Analysts dated February 06, 2026, or any updates provided by SEBI in the future.

The clients are requested to go through all the Disclaimers, Disclosures, Refund Policy and information as mentioned on its website.

Optional Centralised Fee Collection Mechanism

There is an optional ‘Centralized Fee Collection Mechanism for Investment Advisors and Research Analysts’ (CeFCoM) for fee payments. The Research Analyst has presently not opted for the same and once the Research Analyst gets registered for it, then thereafter said mechanism will be available for the client.

Confidentiality

Client shall not share any confidential information with third party without prior consent from the RA which has come to its knowledge.

Dispute

No suit, prosecution or other legal proceeding shall lie against the Research Analyst for any damage caused or likely to be caused by anything which is done in good faith or intended to be done under the provisions of the Securities and Exchange Board of India (Research Analyst) Regulations, 2014.

Any Disputes between the parties shall be resolved through arbitration or other methods mutually agreed upon, in accordance with applicable legal and regulatory guidelines.

Severability

If any provision of this Terms and Conditions is found to be invalid, illegal, or unenforceable, the remaining provisions will remain in full effect, provided the essential purpose of the Terms and Conditions is not undermined.

Force majeure

Neither party shall be held liable for failure or delay in performance under this Terms and Conditions due to circumstances beyond their reasonable control, including but not limited to natural disasters, government actions, or other unforeseen events.

The client agrees to abide with the terms and conditions of the research services.