How this registration works, and what protects you

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.

A. Vision and Mission Statements for investors

As above.

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.

The Charter's own text prescribes 21 days. This firm's service standard is stricter — 7 (seven) business working days, published at § Grievances below and in the Terms — and that stricter number is never displaced by the 21-day figure above.

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

1. 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
2. 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

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 Analyst which is available on SEBI website in the following link: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=14

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.

The Research Analyst discloses to the client the terms and conditions of the research services offered including rights and obligations. Neither any research service is rendered nor any fee is charged until consent is received from the client on the terms and conditions.

1. 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.

2. 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.

3. Client Information and KYC

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

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

4. Standard Terms of Service

The consent of client 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 –

1. Any investment made based on the recommendations in the research report are subject to market risk.
2. Recommendations in the research report do not provide any assurance of returns.
3. 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 that:

1. It is duly registered with SEBI as an RA pursuant to the SEBI (Research Analysts) Regulations, 2014 and its registration details are: INH000029573, registered 10 August 2026;
2. It has registration and qualifications required to render the services contemplated under the RA Regulations, and the same are valid and subsisting;
3. 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;
4. The maximum fee that may be charged by RA is ₹1.51 lakhs per annum per family of client.
5. The recommendations provided by RA do not provide any assurance of returns.

Additionally, the RA being an individual, declaration that:

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

5. Consideration and mode of payment

The client shall duly pay to RA, the agreed fees for the services that RA renders to the client and statutory charges, as applicable. Such fees and statutory charges shall be payable through the specified manner and mode(s)/ mechanism(s).

6. Risk factors

Investment in securities is subject to market risk, including the possible loss of the amount invested. The following risks apply to the research services provided under these terms. They are not exhaustive.

• No assurance of outcome. A Buy, Hold or Sell view, a target price, a forecast or a scenario is a research opinion formed on the methodology and information available at the time of publication. It is not a promise, a guarantee or an assurance of any return, and it does not assure the preservation of capital.
• Scope of coverage. Research is provided on listed equity securities in the cash segment. No research, view or recommendation is provided on derivatives, commodities, currencies or any other instrument.
• Smaller and recently listed companies. Coverage may include small-cap, micro-cap, SME-platform and recently listed companies. Such companies typically carry thinner public disclosure, a shorter operating and reporting history, lower trading liquidity and wider bid-ask spreads. A position in them may not be capable of being entered or exited at or near the price analysed.
• Liquidity. Market conditions may make it difficult or impossible to transact in a security at a particular price or at all, irrespective of the research view.
• Forward-looking analysis. Forecasts, estimates, scenarios and target prices rest on stated assumptions. Those assumptions may not hold, and actual outcomes may differ materially from expectations.
• Valuation sensitivity. Valuation conclusions are sensitive to their inputs. A small change in an assumption can produce a materially different value.
• Event and special-situation risk. Announced corporate events — including mergers, demergers, buybacks, open offers, delistings and fundraisings — may be delayed, modified, rejected by a regulator or court, or abandoned. Initial public offerings and newly listed companies carry limited trading and disclosure history.
• Timing. A research view may prove correct over a longer period than a client is able or willing to hold a position, and may show a loss in the interim.
• Concentration. Acting on a single research report, or on research concerning a single security or sector, concentrates risk.
• Information risk. Research relies on information that is publicly available or that we are permitted to obtain and use. That information may be incomplete, delayed, restated or inaccurate at source.
• Regulatory and tax change. Changes in law, regulation, taxation or policy may affect a security, a sector or the value of a holding, and may occur after research is published.
• Past performance. Past performance is not indicative of future results.
• Not personalised. Research is prepared for the clients of the relevant research product and is not tailored to the objectives, financial situation, tax position or particular needs of any individual client. Clients should consider their own investment objectives, financial circumstances and risk tolerance, and take independent advice where appropriate, before acting on any research.

7. Conflict of interest

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

The following disclosures are made under this clause and are maintained under our conflict-of-interest policy, personal trading policy and information-barrier policy.

• Personal dealing. We do not deal, on our own account or through immediate relatives, in individual securities that are covered by our research or that are in or near our coverage universe. Regulation 16 prohibits dealing contrary to a recommendation, and prohibits dealing in a covered security in the 30 days before and the 5 days after the publication of a research report. We apply a standing separation that is wider than that prohibition, so that the question does not arise on a report-by-report basis.
• Holdings. Any financial interest held by the Research Analyst or his immediate relatives in a subject company, and any actual or beneficial ownership of securities of a subject company, is disclosed in each research report at the time of publication.
• No issuer-paid research. We do not accept any payment, fee, retainer or other consideration from any company that is the subject of our research, or from any person connected with it, in respect of that research or otherwise.
• No banking or market-making relationship. We have no investment banking, merchant banking or advisory relationship with any subject company, and we do not act as a market maker in any security.
• No brokerage or execution. We do not execute transactions, do not act as a broker or distributor, do not receive brokerage, commission or any trail or referral income from any person, and do not hold client funds or client securities at any time.
• Compensation. Our compensation comes solely from fees paid by clients for research services under these terms. No part of it is based on, or linked to, any specific recommendation or view.
• Report-level disclosure. Any actual or potential conflict of interest not covered above is disclosed in the research report to which it relates.

Our conflict-of-interest policy, personal trading policy and information-barrier policy are available to clients on request.

8. 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.

9. Grievance redressal and dispute resolution

Any grievance related to (i) non-receipt of research report or (ii) missing pages or inability to download the entire report, or (iii) any other deficiency in the research services provided by RA, shall be escalated promptly by the client to the person designated by RA in this behalf: Debotro Sinha, grievances@dear-finance.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, including through the Online Dispute Resolution portal at smartodr.in.

10. 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.

11. Mandatory notice

Clients are requested to go through the Do’s and Don’ts while dealing with an RA, as set out in the Investor Charter and 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.

12. Most Important Terms and Conditions (MITC)

Standardised by the Industry Standards Forum in consultation with SEBI and RAASB, and reproduced here as prescribed.

1. 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.
2. 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).
   1. The current fee limit is Rs 1,51,000/- per annum per family of client for all research services of the RA.
   2. The fee limit does not include statutory charges.
   3. The fee limits do not apply to a non-individual client / accredited investor.
3. RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one quarter. 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.
4. Fees to RA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognized RAASB).
5. The RA is required to abide by the applicable regulations/ circulars/ directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.
6. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the RA.
7. The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA’s research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of research report.
8. Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the client’s own judgement and assessment of the conclusions contained in the research report.
9. The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
10. For any grievances,

    Step 1: the client should first contact the RA using the details on its website or following contact details: Debotro Sinha, grievances@dear-finance.com, +91 79801 25779 — see the full Grievance Redressal / Escalation Matrix.

    Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through SEBI’s SCORES platform at www.scores.sebi.gov.in

    Step 3: The client may also consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in

11. Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.
12. The RA shall never ask for the client’s login credentials and OTPs for the client’s Trading Account Demat Account and Bank Account. Never share such information with anyone including RA.

13. Optional Centralised Fee Collection Mechanism

An optional ‘Centralised Fee Collection Mechanism for IA and RA’ (CeFCoM), managed by BSE Limited as the recognised RAASB, is available to clients for payment of fees to the RA. Clients may use it if they prefer, and guidance on doing so will be provided on request.

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Refund of fees

In the event of premature termination of research services in terms of the agreed terms and conditions — by either the client or the Research Analyst — the client shall be refunded proportionate fees for the unexpired period.

In the case of suspension of the certificate of registration of the Research Analyst for more than 60 (sixty) days, or cancellation of the registration, fees will be refunded on a pro-rata basis for the period from the effective date of cancellation or suspension to the end of the subscription period, as set out at clause 8 above.

To request a refund, write to admin@dear-finance.com. Refunds are made to the source account through banking channels. Cash is not used for any payment or refund.

Use of AI tools in providing research services

SEBI requires a Research Analyst to disclose the extent of use of artificial intelligence tools in providing research services. This is a summary of that disclosure; the full version forms part of the terms and conditions provided to clients.

We use artificial intelligence tools as research-support tools at specific stages of the research process: gathering data, extracting and organising information from documents, screening and prioritising material for review, supporting analysis and the construction of research models, preparing preliminary drafts, and checking for inconsistencies or missing information. Which of these apply may vary with the research service.

AI tools do not produce or determine our recommendations. They do not issue a Buy, Hold or Sell rating, set a target price, or constitute the investment view. The view, the rating, the target price and the final recommendation are formed, determined and signed off by the registered analyst, and responsibility for them rests with him personally. AI output is an analytical input and does not replace the analyst’s judgement, review or accountability.

Client information is not entered into any third-party artificial intelligence tool. The audit trail for each recommendation is retained for five years.

Whatever tools are used, every research report published under registration number INH000029573 is the work and the responsibility of Debotro Sinha. No recommendation is published without human review and sign-off.