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Disclosure Document

Annexure C: Disclosures

A. Descriptions about “Investment Adviser”

History, Present business and Background

Investment Adviser is registered with SEBI as Investment Adviser with Registration No. INA000020280. The individual got its registration on 04-June-2025 and is engaged in advisory services.

The focus of Investment Adviser is to provide investment advice to the clients. Adviser aligns its interests with those of the client and seeks to provide the best suited advice based on clients risk profile. Investment Adviser first tries to understand the client's return expectations, risk taking ability & goals, which in turn helps to arrive at an asset allocation suitable for the client. Investment Adviser conducts frequent portfolio reviews and suggests any corrective action/s if required.

Terms and conditions of Advisory Services

Terms and conditions of advisory services are detailed in the client agreement. Please refer to the same for details. The Most Important Terms and Conditions (MITC) form part of that agreement.

Disciplinary history

  1. No penalties / directions have been issued by SEBI under the SEBI Act or Regulations made there under against the Investment Adviser relating to Investment Advisory services.
  2. There are no pending material litigations or legal proceedings, findings of inspections or investigations for which action has been taken or initiated by any regulatory authority against the Investment Adviser or its Directors, or employees.

Affiliations with other intermediaries

Investment Adviser has no affiliation with any other SEBI registered intermediaries.

B. Disclosures with respect to Investment Adviser’s own holding position in financial products / securities

Investment Adviser may hold position in the financial products/ securities advised in its personal portfolio. Details of the same may be referred through the disclosures made at the time of advice.

C. Disclosures with respect to any 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 investment advisory services.

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 investment advisory services. Such conflict of interest shall be disclosed to the client as and when they arise.

D. Disclosure of all material facts relating to the key features of the products or securities

Particularly performance track record, warnings, disclaimers etc.

Clients are requested to go through the detailed key features, performance track record of the product, or security including warnings, disclaimers etc before investing as and when provided by the Investment Adviser. Such product materials may also be available to www.sebi.gov.in or www.nseindia.com or respective issuers website.

E. Drawing client’s attention to warnings, disclaimers in documents, advertising materials relating to investment products

Investment Adviser draws the client’s attention to the warnings, disclaimers in documents, advertising materials relating to an investment product/s which are being recommended to the client/s. A brief regarding the risk associated with the investment products are available in client agreement, same may be referred before investing in advised product or securities.

F. Disclosure on Non-SEBI Product

Any Investment advice given by the Investment adviser on the products or services which are outside the regulatory purview of the Board, no recourse from the Board shall be available to clients for any grievance arising therefrom.

G. AI Tools

Investment Adviser is using Artificial Intelligence (AI) tools in the course of its advisory practice. However, the use of AI is limited to research, data analysis, and administrative tasks such as document preparation and report generation. AI tools are not used to generate, formulate, or determine investment advice provided to clients. All investment advice is based on the independent professional judgment of the Investment Adviser, taking into account the client's risk profile, financial goals, and suitability assessment as required under SEBI (Investment Advisers) Regulations, 2013.