Your Trusted Research Partner
for Smart Investments

As per Annexure B of SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 dated 8th January 2025.

Availing the research services

By accepting delivery of the research service, the client confirms that he/she has elected to subscribe 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.

Obligations on RA

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

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.

Standard terms of service

The consent of client shall be taken on the following understanding:

“I / We 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/We are subscribing to the research services for our own benefits and consumption, and any reliance placed on the research report provided by research analyst shall be as per our own judgement and assessment of the conclusions contained in the research report.

I/We understand that –

• Any investment made based on the recommendations in the research report are 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 the investments made based on the recommendations in the research report.”

Declaration of the RA

• It is duly registered with SEBI as an RA pursuant to the SEBI (Research Analysts) Regulations, 2014 and its registration number is INH100007639;
• 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 lakhs per annum per family of client;
• The recommendations provided by RA do not provide any assurance of returns.

Additionally, if RA is an individual: 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.

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. Such fees and statutory charges shall be payable through the specified manner and mode(s)/ mechanism(s).

Risk factors

Investments in the securities market are subject to market risks, including price volatility, liquidity, sector-specific and macro-economic risks. Derivatives such as index options involve leverage and may result in losses exceeding the premium or margin deployed. Past performance is not indicative of future results.

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.

Termination of service and refund of fees

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 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 — Saurabh Shukla, miruniservresearch@gmail.com.

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 his client may be resolved through arbitration or through any other modes or mechanism as specified by SEBI from time to time.

Additional clauses

All additional voluntary clauses added by the RA should not be in contravention with rules/ regulations/ circulars of SEBI. Any changes in such voluntary clauses/document(s) shall be preceded by a notice of 15 days.

Mandatory notice

Clients shall be requested to go through Do’s and Don’ts while dealing with RA 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.

Optional Centralised Fee Collection Mechanism (CeFCoM)

RA shall provide the guidance to their clients on an optional ‘Centralised Fee Collection Mechanism for IA and RA’ (CeFCoM) available to them for payment of fees to RA.

Forming part of the Terms and Conditions for providing research services (Annexure A).

Research services only — RA cannot trade for you

These terms and conditions, and consent thereon are for the research services provided by the Research Analyst (RA) and RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client. Thus, the clients are advised not to permit RA to execute any trade on their behalf.

Fee limits

The fee charged by RA to the client will be subject to the maximum of 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 Rs 1,51,000/- 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.

Advance fees and refunds

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 unexpired period.

Modes of payment

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 Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognized RAASB).

Conflict of interest

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 endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.

No assured or guaranteed returns

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.

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.

Market risk

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.

The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.

Keep your details updated & never share OTPs

Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.

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.

The information incorporates the minimum mandatory provisions contained in SEBI circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 dated January 08, 2025 and relevant amendments to the SEBI (Research Analysts) Regulations, 2014.

Your acknowledgement

You further agree and acknowledge that:

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

Only the SEBI regulations/guidelines shall prevail. Only the Research Analyst is giving the research, which will be available on RIGI, TRADEBOX or company-owned software.

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

• 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.

General

• 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):

• 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.
• Email to designated email ID of RAASB.

2. Smart ODR

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 (smartodr.in) for its resolution through online conciliation or arbitration.

Physical complaints

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

1. Always deal with SEBI registered Research Analyst.
2. Ensure that the Research Analyst has a valid registration certificate.
3. Check for SEBI registration number. Please refer to the list of all SEBI registered Research Analysts available on the SEBI website.
4. Always pay attention towards disclosures made in the research reports before investing.
5. 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)
6. Before buying/ selling securities or applying in public offer, check for the research recommendation provided by your Research Analyst.
7. Ask all relevant questions and clear your doubts with your Research Analyst before acting on recommendation.
8. Seek clarifications and guidance on research recommendations from your Research Analyst, especially if it involves complex and high risk financial products and services.
9. 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.
10. Always be aware that you have the right to provide feedback to your Research Analyst in respect of the services received.
11. Always be aware that you will not be bound by any clause, prescribed by the research analyst, which is contravening any regulatory provisions.
12. Inform SEBI about Research Analyst offering assured or guaranteed returns.

Don’ts

1. Do not provide funds for investment to the Research Analyst.
2. Don’t fall prey to luring advertisements or market rumors.
3. Do not get attracted to limited period discount or other incentive, gifts, etc. offered by Research Analyst.
4. Do not share login credential and password of your trading, demat or bank accounts with the Research Analyst.

Annexure B — Investor Complaint Data

Formats for investors complaints data to be disclosed monthly by RAs on their website/mobile application.

Data for the month ending – August 2025

^ Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.

Trend of monthly disposal of complaints

Trend of annual disposal of complaints

* Inclusive of complaints of previous months/years resolved in the current month/year. # Inclusive of complaints pending as on the last day of the month/year.

1. Introduction

1.1 Parties

• Research Analyst (hereinafter “RA,” “We,” “Our,” or “Us”) — registered with the Securities and Exchange Board of India (“SEBI”) under Registration No. INH100007639, Name: SAURABH SHUKLA, MIR UNISERV.
• Client or User (“You,” “Your,” or “Client”) — the individual or entity subscribing to or availing research services, who must meet the eligibility requirements set forth herein and under Indian law.

2. Purpose

2.1

• These Terms & Conditions (“T&C”) govern the Client’s, from time to time, use or subscription of Our research services (“Services”), including any Digital Platforms, or technology solutions that We or our service provider(s) provide.

2.2 Compliance with SEBI Circular

• This document incorporates the minimum mandatory provisions contained in the SEBI circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 dated January 08, 2025 (“the Circular”) and relevant amendments to the SEBI (Research Analysts) Regulations, 2014 (“RA Regulations”).
• In case of conflict between these T&C and any applicable regulations/guidelines issued by SEBI, the SEBI regulations/guidelines shall prevail.

3. Definitions

• “Client” or “User”: Any person or entity that registers with the RA and agrees to these T&C to avail the Services.
• “Services”: Includes (a) research reports, data, model portfolios, or analyses pertaining to Indian-listed securities; (b) any online or offline advisory/research support; (c) any communications related thereto.
• “Digital Platform”: Includes websites, mobile or web applications, or other technology platforms (including third-party service providers) used for delivering the Services.
• “KYC”: Know Your Customer — verification process mandated by SEBI (and other applicable laws) to establish the identity of Clients.

4. Scope of Services

4.1 Research-Only / No Execution

• You hereby agree and acknowledge that the RA provides research and analysis only and We do not execute trades on behalf of Clients, hold Clients’ funds, or provide any assured returns.

4.2 Model Portfolios

• Where offered, Our model portfolios are recommendations for basket(s) of securities with weightages. You hereby agree and acknowledge that such recommendations are for informational purposes only and do not guarantee performance or returns.
• We shall ensure compliance with the SEBI’s model portfolio guidelines, as outlined in Annexure-A of the Circular.

4.3 Use of Artificial Intelligence (AI)

• In an event we use AI tools (in whole or part) to generate or support research outputs, We shall remain solely responsible for the quality, accuracy, security, and confidentiality of data.
• We shall disclose the extent of AI usage to the Client when providing Services (or whenever material changes occur).

4.4 No Guarantee of Returns

• You hereby agree and acknowledge that all investments carry market risk. Any past performance is not indicative of future returns, and the RA does not assure or promise any specific gain or outcome.

5. Eligibility

5.1 Legal Capacity

• Only individuals aged 18 years or older (and otherwise competent to contract) or legally incorporated entities may register.
• If You are a minor or otherwise incapacitated to enter into a contract, You are not permitted to use or subscribe to the Services.

5.2 KYC Compliance

• You hereby agree and acknowledge that You shall provide accurate and complete information for the purpose of KYC.
• RA shall verify and/or store such KYC in accordance with SEBI regulations.
• The RA may terminate or suspend Services if KYC requirements are not met as per the applicable regulations or if the information provided is incomplete, false, or misleading.

6. Registration & Accounts

6.1 Registration Process

• To access Our paid Services, Clients shall complete the registration form, provide all mandatory details, and accept these T&C.
• The RA reserves the right to reject or cancel registration if any of the information provided by You is incorrect or if the Client is ineligible to avail the Services under applicable law.

6.2 Security of Credentials

• You agree and acknowledge that You shall keep Your login information (including but not limited to username, password) confidential. You shall be liable for any unauthorized use of your account resulting from negligence or sharing of Your credentials.
• You shall notify Us immediately if You suspect any breach of Your account security.

6.3 Use of Services

• You shall not reproduce, distribute, copy, sell, or otherwise exploit Our research content without express written consent from the RA.
• Any unauthorized use of Our Services shall constitute grounds for termination of Services and may lead to legal action against You.

7. Fees & Payment

7.1 Maximum Fee for Individual/HUF Clients

• As per Regulation 15A of the RA Regulations and the Circular, We may charge fees up to INR 1,51,000 (Rupees One Lakh Fifty-One Thousand) per annum per “family of client” (for individual and HUF clients).
• You hereby agree that this amount excludes any statutory taxes and charges.
• We may revise fees in line with the Cost Inflation Index or as specified by SEBI and/or Research Analyst Administration and Supervisory Body (“RAASB”) every three years.

7.2 Fees for Non-Individual or Accredited Investors

• For corporates, institutions, or accredited investors, fees may be negotiated bilaterally without the above limit, subject to fairness and reasonableness.

7.3 Billing & Mode of Payment

• Fees may be charged quarterly in advance or in another mutually agreed schedule, subject to the one-quarter advance limit mandated by SEBI.
• We may offer or guide you regarding the Centralised Fee Collection Mechanism (CeFCoM) as an optional method of fee payment if made available by SEBI.

7.4 Refund Policy

• In case of premature termination of Services, We shall refund fees for the unexpired subscription period on a pro rata basis.
• No “breakage” fee or penalty shall be imposed.
• Partial-month subscriptions are generally not refunded except at RA’s sole discretion or as required by SEBI.
• If the RA’s SEBI registration is suspended for more than 60 days or cancelled, We shall refund any unutilized fees from that effective date onward.

7.5 Renewal Price

• The fee mentioned under Annexure A of this T&C (along with the details of Your chosen plan and RA details) is the maximum price for renewal. The RA may reduce the renewal fee at its sole discretion without prior notice to the Client.

8. Mandatory Terms & Conditions (as per Circular Annexure-B)

Below are the minimum mandatory T&C required by the Circular. These provisions are integral to Our agreement with You:

8.1 Availing the Services

• By subscribing to or otherwise using Our Services, You hereby acknowledge and confirm that You do so at Your sole discretion.
• Our Services are rendered in accordance with the applicable SEBI (Research Analysts) Regulations, 2014 as well as all other applicable laws.

8.2 Obligations on RA

• Both RA and Client agree to be bound by the SEBI Act, SEBI (RA) Regulations, and all rules/regulations/circulars in force from time to time.

8.3 Client Information & KYC

• You shall furnish all required details for KYC in the form mandated by SEBI/RAASB.
• We will collect, store, verify, and update KYC records as per SEBI norms.

8.4 Standard Terms of Service

• By giving consent (online/offline) to these T&C, You have read and understood the terms and conditions applicable to RA as defined under regulation 2(1)(u) of SEBI (Research Analyst) Regulations, 2014, including the fee structure.
• You hereby agree and acknowledge that You are subscribing to the Services for Your own benefits and consumption, and any reliance placed on the research report provided by Us shall be as per Your own judgement and assessment of the conclusions contained in the research report.
• You further agree and acknowledge that: (a) Any investment made based on the recommendations in the research report are subject to market risk; (b) Recommendations in the research report do not provide any assurance of returns; and (c) There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report.
• We agree and acknowledge that: (a) We are duly registered with SEBI as an RA pursuant to the SEBI (Research Analysts) Regulations, 2014 and Our registration number is INH100007639; (b) We have the registration and qualifications required to render the Services contemplated under the RA Regulations, and the same are valid and subsisting; (c) Our Services 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; and (d) We are 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.

8.5 Consideration & Mode of Payment

• You shall pay the agreed fees plus any statutory charges via permissible methods.
• We shall not render any research services until Your consent is received and initial fees are paid (as applicable).

8.6 Risk Factors

• You hereby acknowledge that investing in securities is subject to market risk, including but not limited to volatility and potential loss of principal and any past performance is no indicator of future performance and no returns are guaranteed.

8.7 Conflict of Interest

• We shall disclose any conflicts of interest as mandated by SEBI and take steps to mitigate or avoid them.
• Full disclosures, if required, will be provided in each research report or at the time of giving a recommendation.

8.8 Termination of Service & Refund of Fees

• If Our registration is suspended or canceled by SEBI, We shall refund any residual amount for the unexpired subscription period.
• We may also suspend/terminate services in an event You breach these T&C or as otherwise allowed by law.

8.9 Grievance Redressal & Dispute Resolution

• For any grievances (e.g., non-receipt of a research report, missing pages, or other deficiencies), please email Our designated Grievance Officer at miruniservresearch@gmail.com within 7 business days of the issue.
• We shall resolve the grievances within 7 (seven) business working days or such timelines as may be specified by SEBI under the RA Regulations from time to time.
• If unresolved, You may escalate the complaint to SEBI via the SCORES portal or use any other dispute resolution mechanism specified by SEBI (e.g., arbitration).

8.10 Additional Clauses

• Any additional voluntary clauses in this T&C shall not conflict with SEBI regulations/circulars.
• Any changes to such voluntary clauses shall be preceded by 15 days’ notice.

8.11 Mandatory Notice

• Clients shall refer to the Do’s and Don’ts while dealing with the Services 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.

8.12 Most Important Terms & Conditions (MITC)

• We shall also disclose MITC (as standardized by the Industry Standards Forum, in consultation with SEBI/RAASB).
• The MITC explicitly informs Clients that the RA cannot execute trades on behalf of Clients.

8.13 Optional Centralised Fee Collection Mechanism (CeFCoM)

• If and when available, We will inform you of the optional Centralised Fee Collection Mechanism for IA and RA (“CeFCoM”) to facilitate fee payment.

9. Representations & Warranties

9.1 RA’s Declarations

• The RA declares that it is duly registered under the SEBI (Research Analysts) Regulations, 2014.
• The RA, including its Principal Officer (if applicable), meets or exceeds the qualification and certification requirements mandated by SEBI or National Institute of Securities Markets (“NISM”).
• The RA’s services do not conflict with or violate any law or regulation to which it is subject.

9.2 Client’s Declarations

• You represent that You are legally entitled to enter this Agreement and that Your KYC details are true and correct.
• You understand the nature of market risks and volatility inherent in securities investments.

10. Confidentiality & Data Protection

10.1 Privacy of Client Data

• We respect Your privacy and will not share or disclose Your personal data except as required by law or to fulfill regulatory obligations (e.g., KYC checks).
• However, We may share aggregated or anonymized data for research or compliance purposes, without revealing individual identities.

10.2 Security of Client Data

• While we endeavor to protect data transmissions, we cannot guarantee the complete security of data over the internet.
• You acknowledge that data transfers may be unencrypted and may pass over multiple networks.

11. Limitation of Liability

11.1 No Assured Returns

• We shall not be liable for any direct, indirect, incidental, or consequential losses, including lost profits, due to Your reliance on Our research reports or model portfolios.

11.2 Force Majeure

• The RA is not liable for failures or delays in performance arising from events beyond its control, including natural disasters, power outages, or disruptions in telecommunication systems.

11.3 Third-Party Data

• We rely on third-party market data providers. We do not audit or guarantee the correctness of such data, and shall not be held liable for inaccuracies.

12. Indemnification

You agree to indemnify and hold harmless the RA, its officers, employees, and affiliates from any and all claims, damages, losses, or liabilities arising out of:

• Your breach of these T&C or violation of law.
• Unauthorized or improper use of Your account.
• Third-party claims related to Your actions or inactions.

13. Suspension & Termination

13.1 Suspension

• We reserve the right to suspend Your account or access to Services with or without notice if You breach these T&C or if required by SEBI/regulators.

13.2 Termination

• We may terminate this Agreement immediately upon: (i) violation of T&C by You; (ii) directions from SEBI or any competent regulatory authority; (iii) non-payment of fees (beyond the grace period, if any).
• Refunds (if any) shall be governed by Section 7.4 above.

14. Miscellaneous

14.1 Amendments

• We may modify or update these T&C in accordance with SEBI regulations. Notice of material changes will be posted on Our website/app or emailed to You. Continued use of the Services indicates Your acceptance of updated T&C.

14.2 Severability

• If any provision is held invalid by a competent authority, the remaining provisions shall continue in effect.

14.3 Governing Law & Jurisdiction

• These T&C shall be governed by and construed in accordance with the laws of India, and any disputes shall be subject to the exclusive jurisdiction of the courts/tribunals in Mumbai or as directed by SEBI.

14.4 No Agency

• Nothing in these T&C shall be deemed to constitute a partnership, agency, or joint venture between the RA and the Client.

14.5 Disclaimer

• Registration granted by SEBI and certification from NISM in no way guarantee the performance of the intermediary or provide any assurance of returns to investors.
• Investing in stocks/ETFs is subject to market risks. Read all related documents carefully before investing. Consult a qualified financial advisor to understand suitability.

We highly esteem our customers and are dedicated to delivering top-notch services. It is important for our clients to understand that we do not provide a 100% guarantee on our calls and, therefore, cannot facilitate any refunds for subscriptions, irrespective of an individual client’s performance. Once a service has been subscribed to and payment has been processed, it is non-cancellable and non-refundable under any circumstances. In the event that a client is dissatisfied with our services, they may contact us for guidance on future calls, and we will exert our best efforts to enhance satisfaction. However, requests for service cancellation or refunds will not be entertained, as we have transparently communicated the associated risks, including potential loss of capital and gains, to all clients prior to subscribing to our services.

We strongly advise our visitors and prospective clients to:

• Thoroughly review all information regarding our services and the support provided.
• Familiarize themselves with our Terms and Conditions.
• Review our Privacy Policy and Refund Policy.
• Acknowledge that no refunds are possible under any circumstances.

We urge individuals to make payments only after carefully reading and understanding all terms, disclaimers, and the refund policy.

MIR UNISERV (SEBI Registered Research Analyst) respects and values the Right to Privacy of individuals. We are esteemed by the relationship and by becoming our clients you have a promise from our side that we shall remain loyal to all our clients and non-clients whose information resides with us. This Privacy Policy of MIR UNISERV applies to the current clients as well as former clients.

• By registering your mobile number on our website, you agree to be contacted by our personnel or to receive SMS’s and it shall be treated as ‘opt in’ in case the contact number you have registered with us is subscribed in DND registry (Do Not Disturb). By registering for our services, you also agree to comply with our Privacy Policy and Terms & Conditions. Please be aware that you may receive calls related to service promotions and any sort of contests and polls organized by us. In case there are any changes in your contact information that we retain, please bring this to our knowledge either by call or email.
• Your information, whether public or private, will not be sold, rented, exchanged, transferred or given to any company / establishment / individual for any reason, without your consent for the same.
• By using our site, you consent to our privacy policy.
• Your information will be used ONLY for providing the services to you for which you have subscribed to us, for which you have shared your respective information.
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• This information/document has been prepared by MIR UNISERV Ltd. (MIR UNISERV) and is intended for use only by the person or entity to which it is addressed to. This Document may contain confidential and/or privileged material and is not for any type of circulation and any review, retransmission, or any other use is strictly prohibited. This information/ document is subject to changes without prior notice. Recommendation in reports based on technical and derivatives analysis is based on studying charts of a stock’s price movement, trading volume, outstanding positions, as opposed to focusing on a company’s fundamentals and as such, may not match with a report on a company’s fundamentals. However, this would only apply for information/document focused on technical and derivatives research and shall not apply to reports/documents/ information focused on fundamental research.
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• The information contained herein is obtained from publicly available data or other sources believed to be reliable and MIR UNISERV has not independently verified the accuracy and completeness of the said data and hence it should not be relied upon as such. While we would endeavor to update the information herein on reasonable basis, MIR UNISERV, its subsidiaries and associated companies, their directors and employees (“MIR UNISERV and affiliates”) are under no obligation to update or keep the information current. Also, there may be regulatory, compliance, or other reasons that may prevent MIR UNISERV and affiliates from doing so. This document is prepared for assistance only and is not intended to be and must not alone be taken as the basis for an investment decision. Recipients of this report should also be aware that past performance is not necessarily a guide to future performance and value of investments can go down as well. The user assumes the entire risk of any use made of this information. Each recipient of this document should make such investigations as it deems necessary to arrive at an independent evaluation of an investment in the securities of companies referred to in this document (including the merits and risks involved) and should consult its own advisors to determine the merits and risks of such an investment. The investment discussed or views expressed may not be suitable for all investors. We do not undertake to advise you as to any change of our views. Affiliates of MIR UNISERV may have issued other recommendations/ reports that are inconsistent with and reach different conclusions from the information presented in this recommendations/report.
• This information/recommendation/report is not directed or intended for distribution to, or use by, any person or entity who is a citizen or resident of or located in any locality, state, country or other jurisdiction, where such distribution, publication, availability or use would be contrary to law, regulation or which would subject MIR UNISERV and affiliates to any registration or licensing requirement within such jurisdiction. The securities described herein may or may not be eligible for sale in all jurisdictions or to certain category of investors. Persons in whose possession this document may come are required to inform themselves of and to observe such restriction.
• The analyst certifies that the analyst might have dealt or traded directly or indirectly in securities of the company and that all the views expressed in this document accurately reflect his or her personal views about the subject company or companies and its or their securities and do not necessarily reflect those of MIR UNISERV. The analyst and MIR UNISERV further certifies that either he or his relatives or MIR UNISERV associates might have direct or indirect financial interest or might have actual or beneficial ownership of 1% or more in the securities of the company at the end of the month immediately preceding the date of publication of the research report. The analyst and MIR UNISERV encourages independence in research report/ material preparation and strives to minimize conflict in preparation of research report. The analyst and MIR UNISERV does not have any material conflict of interest or has not served as officer, director or employee or engaged in market making activity of the company. The analyst and MIR UNISERV has not been a part of the team which has managed or co-managed the public offerings of the company, and no part of the analyst’s compensation was, is or will be, directly or indirectly related to specific recommendations or views expressed in this document. MIR UNISERV Ltd or its associates or analysts have not received any compensation for investment banking, merchant banking, brokerage services or any compensation or other benefits from the subject company or from third party in the past twelve months in connection with the research report.
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• Forward-looking statements (if any) are provided to allow potential investors the opportunity to understand management’s beliefs and opinions in respect of the future so that they may use such beliefs and opinions as one factor in evaluating an investment. These statements are not a guarantee of future performance and undue reliance should not be placed on them. Such forward-looking statements necessarily involve known and unknown risks and uncertainties, which may cause actual performance and financial results in future periods to differ materially from any projections of future performance or result expressed or implied by such forward-looking statements. MIR UNISERV/its affiliates undertakes no obligation to update forward-looking statements if circumstances or management’s estimates or opinions should change except as required by applicable securities laws. The reader/investors are cautioned not to place undue reliance on forward-looking statements and use their independent judgement before taking any investment decision.
• Investment in securities market are subject to market risks, read all the related documents carefully before investing. The securities quoted are for illustration only and are not recommendatory. Registration granted by SEBI, and certification from NISM in no way guarantee the performance of the intermediary or provide any assurance of returns to investors.

Registration and Contact Details

Name of Research Analyst – MIR UNISERV, Research Analyst Registration No.: INH100007639.
Registered Office: X-1/153, Krishna Puram, Opp. Prism Cement Office, Kanpur-208007, U.P. Tel No. 8800208773.
Other registrations of Mir Uniserv: NIL
Compliance Officer: SAURABH SHUKLA; Tel: 8800208773; email id: miruniservresearch@gmail.com
For any complaints/grievances, email us at miruniservresearch@gmail.com

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Disclaimer

Registration granted by SEBI, and certification from NISM in no way guarantee performance of the Research Analyst or provide any assurance of returns to investors.

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If MIR UNISERV takes action (by itself or through its associate companies) to enforce any of the provisions of this User Agreement, including collection of any amounts due hereunder, MIR UNISERV shall be entitled to recover from you (and you agree to pay), in addition to all sums to which it is entitled or any other relief, at law or in equity, reasonable and necessary attorney’s fees and any costs of any litigation.

This policy has been formed in the light of SEBI Circulars on Anti Money Laundering (AML) and Combating Financing of Terrorism (CFT) as amended – obligations of Intermediaries under the Prevention of Money Laundering Act, 2002 (‘Act’) and Rules framed there under after making necessary amendments in the existing Anti-Money Laundering Policy of the Firm.

In pursuance of above said circular and the provisions of the Act, the policy of the firm is to prohibit and actively prevent money laundering and any activity that facilitates money laundering or terrorist financing. Money Laundering (ML) is generally understood as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds or assets so that they appear to have been derived from legitimate origins or constitute legitimate assets.

1. Initiatives by MIR UNISERV

The basic purpose of the AML Policy is to establish a system for MIR UNISERV to participate in the international efforts against ML and to duly comply with the guidelines as detailed in the above circular of SEBI, as amended and other legal provisions and to ensure that MIR UNISERV is not used as a vehicle for ML. The AML framework of MIR UNISERV would meet the extant regulatory requirements.

2. Scope

This AML Policy establishes the standards of AML compliance and is applicable to all activities of MIR UNISERV.

3. Objectives of the Policy

• To establish a framework for adopting appropriate AML Procedures and controls in the operations / Business processes of MIR UNISERV.
• To put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws/laid down procedures.
• To comply with applicable laws and regulatory guidelines.
• To take necessary steps to ensure that the concerned staff are adequately trained in KYC/AML procedures.
• To assist law enforcement agencies in their effort to investigate and track money launderers.

4. Principal Officer – Designation and Duties

The company has designated the Company Secretary as the Principal Officer for due compliance of its AML measures. He will act as a central reference point in facilitating onward reporting of suspicious transactions and for playing an active role in the identification and assessment of potentially suspicious transactions. The duties of the Principal Officer will include monitoring the company’s compliance with AML obligation and overseeing maintenance of AML records, communication and training for employees. The Principal Officer will ensure filing of necessary reports with the Financial Intelligence Unit (FIU–IND). Principal Officer is authorized to issue additional circulars and advisories, to and seek information from the concerned officials for due compliance of AML measures from time to time.

The company has provided the FIU with contact information of the Principal Officer and will promptly notify FIU of any change in this information.

5. Customer Due Diligence

At the time of onboarding the firm will verify the identity records and current address(es) including permanent address(es) of the client, the nature of the business of the client and his financial status by scrupulously following the KYC norms.

Adequate information to satisfactorily establish the identity of each new client and the purpose of the intended nature of the relationship should be obtained. KYC norms shall be followed while establishing the client relationship and may further be followed while carrying out transactions for the client or when there is doubt regarding the veracity or adequacy of previously obtained client identification data.

Reliance would be placed on the documents as prescribed by the Securities and Exchange Board of India/Exchange for onboarding as applicable from time to time. Onboarding can only be completed after verifying the required documents. The concerned official of the company will put his signature with the stamp “verified with original” after due verification with the original documents on the copy there of.

Additionally following norms shall be observed:

• No account will be opened in a fictitious, benami name or anonymous basis.
• Adhering to parameters developed to enable classification of clients into low, medium, and high risk.
• Documentation requirement and other information may be collected in respect of different classes of clients depending on the perceived risk and having regard to the requirements of the Prevention of Money Laundering Act, 2002 and the guidelines issued by SEBI from time to time.
• The Firm shall consult the relevant authority, in case return of securities or money that may be from suspicious trades is desired.
• Any person other than the constituent can use the Firm services of the constituent only if he/she has been duly authorized by the constituents. In case of body corporate or other entities, can be operated only by the authorized persons supported by necessary documents. The transaction limits for the operation, required margin and the trading relations with the clients will be governed as per the Circular, Rules, Regulations and Bye laws of SEBI/Exchange and as per agreement(s) with the constituents. All payments should be received by cheque and all payments should be made through cheque/Payment gateways/IMPS/NEFT or 3rd party apps. Cash transactions are allowed as per the direction of the SEBI/Exchange and the firm shall comply with the same.
• Before opening services, the firm will ensure that the identity of the client does not match with any person having known criminal background or is not banned in any other manner, whether in terms of criminal or civil proceedings by any enforcement agency worldwide and may take declaration to this effect from the prospective client.

On failure by prospective client to provide satisfactory evidence of identity, new services shall not be opened and the matter shall be reported to the higher authority.

• No services will be opened without acceptance of a copy of PAN Card as directed by SEBI/Exchange. The said PAN received will be verified from the Income Tax/NSDL website before the account is opened.
• Without diluting the above requirements, the personnel opening a new account may obtain other independent information to satisfactorily establish the identity of each new client and the purpose of the intended nature of the relationship.
• Records of all identification information shall be maintained for 5 years after the services have been closed unless some inquiry/investigation is pending at that time for which retention for further period is directed by an agency/authority.

Special care shall be taken while opening accounts of Clients of Special Category (CSC). Such clients include:

• Non-resident clients
• High net worth clients
• Trusts, Charities, NGOs and organizations receiving donations
• Companies having close family shareholdings or beneficial ownership
• Politically exposed persons (PEP) of foreign origin e.g. current/former heads of states, current/former senior high profile politicians, senior government/ judicial/ military, senior executives of state-owned corporations and connected persons (immediate family, close advisors and companies in which such individuals have interest or significant influence)
• Companies offering foreign exchange
• Clients in high risk countries (where existence / effectiveness of money laundering controls is suspected, where there is unusual banking secrecy, countries active in narcotics production, countries where corruption is highly prevalent, countries against which government sanctions are applied, countries reputed to be havens / sponsors of international terrorism, offshore financial centers, tax havens, countries where fraud is highly prevalent)
• Non-face to face clients
• Clients with dubious reputation as per public information available

The above mentioned list is only illustrative and the company exercises independent judgment to ascertain whether new clients should be classified as CSC or not.

• The Firm shall duly comply with the KYC / client identification procedures that may be specified by SEBI from time to time.
• The concerned officials should take extra caution in case of existing or potential Politically Exposed Persons (PEP). They may seek additional information and also take the help of publicly available information.
• No business relationships can be established with PEP without the permission of any administrative officer of the firm or the Compliance Officer. Where a customer has been accepted and the customer or beneficial owner is subsequently found to be, or subsequently becomes a PEP, the approval from the above said officials is required to continue the business.
• The Officials of the firm may track the financial soundness of the clients and shall take reasonable measures to verify source of funds of clients identified as PEP.

6. Maintenance of Records

The Principal Officer shall ensure the maintenance of the following records:

• All cash transactions of the value of more than rupees ten lakhs or its equivalent in foreign currency;
• All series of cash transactions integrally connected to each other which have been valued below rupees ten lakhs or its equivalent in foreign currency where such series of transactions have taken place within a month;
• All cash transactions where forged or counterfeit currency notes or bank notes have been used as genuine and where any forgery of a valuable security has taken place;
• All suspicious transactions – a transaction whether or not made in cash and including inter-alia, credits or debits into or from any non-monetary account such as demat account, security account etc. which, to a person acting in good faith gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or appears to be made in circumstances of unusual or unjustified complexity; or appears to have no economic rationale or bonafide purpose.

The records shall contain the nature of the transactions; the amount of the transaction and the currency in which it was denominated; the date on which the transaction was conducted; and the parties to the transaction.

The firm shall also endeavor to maintain such records as are sufficient to permit reconstruction of individual transactions (including the amounts and types of currencies involved, if any) so as to provide, if necessary, evidence to the investigating agencies for prosecution of criminal behavior. For this purpose the company shall retain the documents as to the beneficial owner of the account; the volume of the funds flowing through the account; and for selected transactions: the origin of the funds, the form in which the funds were offered or withdrawn (e.g. cash, cheques, etc.), the identity of the person undertaking the transaction, the destination of the funds, and the form of instruction and authority.

The Principal Officer shall ensure that all customer and transaction records and information are available on a timely basis to the competent investigating authorities. Where appropriate, he may consider retaining certain records, e.g. customer identification, account files, and business correspondence, for periods which may exceed that required under the SEBI Act, Rules and Regulations framed there-under, PMLA 2002, other relevant legislations, Rules and Regulations or Exchange bye-laws or circulars.

7. Retention of Records

The records of the identity of clients are maintained and preserved for a period of 5 years from the date of cessation of transactions between the client and the Company. In situations where the records relate to on-going investigations or transactions which have been the subject of a suspicious transaction reporting, they should be retained until it is confirmed that the case has been closed.

8. Monitoring Accounts for Suspicious Activity

The following kinds of activities are to be treated as red flags and reported to the Principal Officer:

• Clients whose identity verification seems difficult or clients appear not to cooperate;
• Where the source of the funds is not clear or not in keeping with clients’ apparent standing/business activity;
• Clients in high-risk jurisdictions or clients introduced by such clients or banks or affiliates based in high risk jurisdictions;
• Substantial increases in business without apparent cause;
• Unusually large cash deposits made by an individual or business;
• Clients transferring large sums of money from overseas locations with instructions for payment in cash;
• Transfer of investment proceeds to apparently unrelated third parties;
• Unusual transactions by CSCs and businesses undertaken by shell corporations, offshore banks/financial services, businesses reported to be in the nature of export/import of small items.

The above mentioned list is only illustrative and whether a particular transaction is suspicious or not will depend upon the background, details of the transactions and other facts and circumstances. When any functionary of the firm detects any red flag, he or she will cause it to be further investigated for his/her satisfaction or report the same to the Principal Officer for further investigation and necessary action.

9. Reporting to Financial Intelligence Unit – India

In terms of the PMLA rules, Principal Officer is required to report information relating to cash and suspicious transactions to the Director, Financial Intelligence Unit-India (FIU-IND) at: Director, FIU-IND, Financial Intelligence Unit-India, 6th Floor, Hotel Samrat, Chanakyapuri, New Delhi – 110 021. Website: fiuindia.gov.in

For Cash Transaction Reporting: Dealings in Cash, if any, requiring reporting to the FIU IND will be done in the CTR format and in the manner and at intervals as prescribed by the FIU IND.

Procedure for Suspicious Transactions Reporting: The staff at operating terminal shall be adequately trained with PMLA requirements and reporting suspicious transaction to Principal Officer. The Principal Officer will make a note of suspicious transactions that have not been explained to his satisfaction and thereafter report the same to the FIU IND within the required deadlines.

Where a client aborts/abandons a suspicious transaction on being asked some information by the company officials, the matter shall be reported to FIU in the STR irrespective of the amount by the Principal Officer. The Principal Officer will not base the decision on whether to file a STR solely on whether the transaction falls above a set threshold. The Principal Officer will file a STR and notify law enforcement of all transactions that raise an identifiable suspicion of criminal or terrorist corrupt activities.

The Company will not notify any person involved in the transaction that the transaction has been reported, except as permitted by the PML Act and Rules thereof. Utmost confidentiality shall be maintained in filing of CTR and STR to FIU-IND. The reports may be transmitted by speed/registered post/fax at the notified address.

No nil reporting needs to be made to FIU-IND in case there are no cash/suspicious transactions to be reported. The Company shall not put any restrictions on operations in the accounts where an STR has been made. The firm MIR UNISERV, officers and employees (permanent and temporary) shall be prohibited from disclosing (“tipping off”) the fact that a STR or related information is being reported or provided to the FIU-IND. It should be ensured that there is no tipping off to the client at any level. The company will create and maintain STRs and CTRs and relevant documentation on customer identity and verification and will maintain STRs and their accompanying documentation for such period as prescribed from time to time.

10. Internal Audit

Internal Audit shall ensure compliance with policies, procedures, and controls relating to prevention of money laundering and terrorist financing, including the testing of the system for detecting suspected money laundering transactions, evaluating and checking the adequacy of exception reports generated on large and/or irregular transactions, the quality of reporting of suspicious transactions and the level of awareness of front line staff of their responsibilities in this regard.

11. Employee Hiring / Employee Training / Investor Education

The firm has an on-going employee training under the leadership of the Principal Officer. The training includes, inter alia: how to identify red flags and signs of money laundering that arise during the course of the employees’ duties; what to do once the risk is identified; what are the employees’ roles in the company’s compliance efforts and how to perform them; the company’s record retention policy; and the disciplinary consequences for non-compliance with the Act. Means of the training may include educational pamphlets, videos, internet systems, in-person lectures, and explanatory memos.

The operations are reviewed periodically to see if certain employees, such as those in compliance, margin, and corporate security, require additional specialized training. The implementation of AML/CFT measures requires intermediaries to demand certain information from investors which may be of personal nature or which have hitherto never been called for. Such information can include documents evidencing source of funds/income tax returns/bank records etc. This can sometimes lead to raising of questions by the customer with regard to the motive and purpose of collecting such information. Therefore, the Principal Officer and other officials of the company will sensitize the customers about these requirements as the ones emanating from AML and CFT framework so as to educate the customer of the objectives of the AML/CFT programme.

12. Monitoring Employee Conduct and Accounts

MIR UNISERV subjects employee accounts to the same AML procedures as customer accounts, under the supervision of the Principal Officer. The Principal Officer’s account is reviewed by the Compliance Officer.

13. Confidential Reporting of AML Non-Compliance

Employees report any violations of the company’s AML compliance programme to the Principal Officer, unless the violations implicate the Principal Officer, in which case the employee shall report to SEBI. Such reports are confidential, and the employee suffers no victimization for making them.

14. Review

The firm conducts a periodic review of the policy. In case of amendment in statutory provisions/ regulations necessitating amendment, the relevant portions of policy shall be deemed to have been modified from the date of amendment in relevant statutory provisions. In such case the modified policy shall be placed for review by the compliance officer in regular course.

15. Communication

Principal Officer shall ensure that this policy is communicated to all management and relevant staff including Directors, Head of the Department(s), customers and all concerned.