Smarter Investing Starts With Trusted Research

Disclosures

In terms of Regulation 19 of the SEBI (Research Analysts) Regulations, 2014, and the applicable SEBI Master Circular for Research Analysts (as amended from time to time), I make the following disclosures. These disclosures are made on a standing basis and, where applicable, additional or updated disclosures specific to a subject company are carried in the relevant research report itself.

Business, Registration and Compliance Details

• Particulars: Details
• Name of Research Analyst: RUSHIKESH UDAY GONJARE (Trade Name: Advait Research)
• Type of Registration: Individual – Research Analyst
• SEBI Registration No.: INH000029263
• Validity of Registration: July 23, 2026 – Perpetual
• RAASB Enlistment: BSE Limited, presently recognized as the Research Analyst Administration and Supervisory Body (RAASB)
• Registered / Correspondence Address: A-903, Teerth Avila, Vidya Valley School Road, Sus, Pune – 411021, Maharashtra, India
• Contact Person / Compliance & Grievance Officer: Rushikesh Uday Gonjare
• Telephone: +91 9766873676
• E-mail: rushikeshgonjare@gmail.com
• Website: https://advaitresearch.com/
• BSE Complaints against RA: https://scores.sebi.gov.in / RAASB designated e-mail ID

Disciplinary History

• There is no material disciplinary action taken against me by SEBI, any stock exchange, RAASB, or any other regulatory or statutory authority in the last five (5) years, other than as may be specifically disclosed to a client in writing or updated on the website from time to time.
• Any change to this position will be disclosed to clients and updated on the website within the timelines specified by SEBI.

Terms and Conditions of Research Services

The terms and conditions on which research services are offered, including the Most Important Terms and Conditions (MITC), fee structure, fee limits, payment mode, and refund terms, are set out in the document titled "Terms & Condition of Research Service Including MITC", forming part of this Manual, and are separately furnished to and accepted by every client prior to on-boarding.

Details of Associates

As on the date of this document, I do not have any associate (as defined under the SEBI (Intermediaries) Regulations, 2008) engaged in merchant banking, investment banking, brokerage, or underwriting services. In the event any associate relationship is established in the future, the same, along with the nature of activities undertaken by such associate, shall be disclosed to clients and updated in this document.

Ownership and Material Conflicts of Interest (Regulation 19(i))

In respect of every research report and public appearance, I disclose, as applicable:

• Whether I or any of my relatives has any financial interest in the subject company, and the nature of such financial interest.
• Whether I or any of my relatives has actual or beneficial ownership of one per cent (1%) or more of the securities of the subject company as of the end of the month immediately preceding the date of publication of the research report or the public appearance.
• Whether I have any other material conflict of interest at the time of publication of the research report or at the time of the public appearance.

Receipt of Compensation (Regulation 19(ii) and (iii))

In respect of every research report, I disclose whether, in the preceding twelve (12) months, I or any associate:

• Have received any compensation from the subject company.
• Have managed or co-managed a public offering of securities for the subject company.
• Have received any compensation for investment banking, merchant banking, or brokerage services from the subject company.
• Have received any compensation for products or services other than investment banking, merchant banking, or brokerage services from the subject company.
• Have received any other compensation or benefits from the subject company or any third party in connection with the research report.

I further disclose whether I have served as an officer, director, or employee of the subject company, and whether I have been engaged in any market-making activity for the subject company. As an independent individual Research Analyst, I do not undertake merchant banking, investment banking, underwriting, or brokerage services, and accordingly several of the above disclosures will, in the ordinary course, be recorded as "Not Applicable / Nil" in individual research reports, save where a specific fact requires disclosure.

Use of Artificial Intelligence Tools

In accordance with SEBI's disclosure requirements, I disclose the extent, if any, of use of Artificial Intelligence (AI) tools in the preparation of research reports and in providing research services. Where AI-based tools are used, they are used only in a supportive/analytical capacity, such as data collation, formatting, or preliminary screening. The final research view, recommendation, and rating remain my own independent professional judgement, and I remain fully responsible and accountable for the content and accuracy of every research report.

Fee Disclosure

The maximum fee chargeable by me to individual and HUF clients is capped at Rs. 1,51,000/- (Rupees One Lakh Fifty-One Thousand only) per annum per family of client for all research services taken together, exclusive of statutory levies, as prescribed by SEBI/RAASB from time to time. This cap does not apply to non-individual clients or accredited investors. The applicable fee cap, as revised by SEBI from time to time, shall automatically apply in supersession of the figure stated above.

Confidentiality and Data Privacy

I maintain confidentiality in respect of a research report until it is made available in the public domain, and I respect the data-privacy rights of clients as set out in the Privacy Policy forming part of this Manual.

Annual Audit

In accordance with Regulation 25(3) of the SEBI (Research Analysts) Regulations, 2014, I undertake an annual audit in respect of compliance with the RA Regulations, conducted by a member of the Institute of Chartered Accountants of India or the Institute of Company Secretaries of India, and the audit report/compliance status is submitted to RAASB within the timelines prescribed by SEBI.

Advertisement Code

All advertisements, marketing material, and communications with clients or prospective clients are issued in adherence with the Advertisement Code for Research Analysts prescribed under the SEBI Master Circular for Research Analysts, as amended from time to time, and do not contain any statement promising assured, guaranteed, or risk-free returns.

Standard Disclaimer:

The securities quoted (if any) in research reports, on the website, or in any advertisement are for illustration only and are not recommendatory. Registration granted by SEBI, enlistment with RAASB, and certification from NISM in no way guarantee the performance of the intermediary or provide any assurance of returns to investors.

Investor Charter

This Investor Charter is issued in terms of SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 dated June 2, 2025, read with Clause 5 of the SEBI Master Circular for Research Analysts dated May 21, 2024 (as amended), and is disclosed on my website, mobile application (if any), and at my place of business, and shall also be furnished to every client, existing and new, as part of the client on-boarding process.

Vision and Mission

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

Business Transacted by the Research Analyst

• To publish research reports based on my research activities.
• To provide an independent, unbiased view on securities.
• To offer unbiased recommendations, disclosing financial interests, if any, in recommended securities.
• To provide research recommendations based on analysis of publicly available information and known observations.
• To conduct an annual audit as required under the RA Regulations.
• To ensure that all advertisements adhere to the Advertisement Code for Research Analysts.
• To maintain records of interactions with all clients, including prospective clients (prior to on-boarding), where any conversation relating to research services has taken place.

Services Provided to Investors

• On-boarding of clients.
• Sharing of terms and conditions of research services, including the MITC.
• Completing KYC of fee-paying clients.
• Disclosure to clients of information material to an informed decision, including business activity, disciplinary history, terms and conditions of research services, details of associates, and risks and conflicts of interest, if any.
• Disclosure of the extent of use of Artificial Intelligence tools in providing research services.
• Disclosure, while distributing any third-party research report, of any material conflict of interest of the third-party research provider, or provision of a web address directing the recipient to the relevant disclosures.
• Disclosure of any conflict of interest between research services and any other activity undertaken.
• Distribution of research reports and recommendations to clients without discrimination.
• Maintenance of confidentiality of a research report until it is made available in the public domain.
• Respect for the data-privacy rights of clients, and measures to protect against unauthorized use of confidential information.
• Disclosure of timelines for services provided and adherence to such timelines.
• Provision of clear guidance and adequate caution notice when recommending complex and high-risk financial products/services.
• Treating all clients with honesty and integrity.
• Ensuring confidentiality of client information, unless required to be disclosed to discharge a legal obligation or with the client's specific consent.

Grievance Redressal Mechanism and How to Access It

Filing a complaint directly with the Research Analyst In case of any grievance or complaint, an investor may approach me at the contact details below, and I shall strive to redress the grievance immediately, but not later than twenty-one (21) days from the date of receipt of the grievance.

• E-mail rushikeshgonjare@gmail.com - Telephone +91 9766873676
• Postal Address Rushikesh Gonjare, A-903, Teerth Avila, Vidya Valley School Road, Sus, Pune – 411021, Maharashtra, India
• Designated Grievance Contact Rushikesh Gonjare (Compliance & Grievance Officer)

Filing a complaint on SCORES / with RAASB

• SCORES 2.0: A web-based, centralised grievance redressal system of SEBI for effective, time-bound redressal: https://scores.sebi.gov.in. Complaints on SCORES are subject to a two-level review – a first review by the designated body (RAASB), and a second review by SEBI.

RAASB: An investor may also submit a complaint through the designated e-mail ID of RAASB – BSE Limited (RAASB).

• Online Dispute Resolution (ODR)

If an investor is not satisfied with the resolution provided, the investor has the option to file the complaint/grievance on the SMARTODR platform: https://smartodr.in for resolution through online conciliation or arbitration, in terms of SEBI Circular No. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023, on Online Resolution of Disputes in the Indian Securities Market. - Physical Complaints to SEBI Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, 'G' Block, Bandra-Kurla Complex, Bandra (East), 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, including all statutory and regulatory disclosures.
• Right to Fair and 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 to Satisfactory Grievance Redressal, including timely redressal.
• Right to Exit from the service in accordance with the agreed terms and conditions.
• Right to receive clear guidance and a caution notice when dealing with complex and high-risk financial products and services.
• Additional rights to vulnerable consumers, including the right to access services in a suitable manner even if differently abled.
• Right to provide feedback on the products and services used.
• Right against coercive, unfair, and one-sided clauses in agreements.

Expectations from Investors (Responsibilities of Investors)

Do's

• Always deal with a SEBI-registered Research Analyst.
• Ensure that the Research Analyst has a valid registration certificate; check the SEBI registration number. The list of registered RAs is available at sebi.gov.in.
• Always pay attention to disclosures made in research reports before investing.
• Pay your Research Analyst only through banking channels and maintain duly signed receipts mentioning payment details; fee-paying clients may also use the Centralized Fee Collection Mechanism (CeFCoM) of RAASB, where opted for.
• Before buying/selling securities or applying in a public offer, check for the research recommendation provided.
• Ask all relevant questions and clear doubts with your Research Analyst before acting on any recommendation.
• Seek clarification and guidance on recommendations, especially for complex and high-risk financial products and services.
• Be aware that you have the right to stop availing the RA's services as per the agreed terms of service.
• Be aware of your right to provide feedback on the services received.
• Be aware that you will not be bound by any clause prescribed by the RA that contravenes any regulatory provision.
• Inform SEBI of any Research Analyst offering assured or guaranteed returns.

Don'ts

• Do not provide funds for investment to the Research Analyst.
• Do not fall prey to luring advertisements or market rumours.
• Do not get attracted to limited-period discounts or other incentives/gifts offered by a Research Analyst.
• Do not share the login credentials or password of your trading, demat, or bank accounts with the Research Analyst.

Complaint Data Disclosure: Complaint data, including the number of complaints received, resolved, and pending, along with the trend, is displayed on my website on a monthly basis, latest by the 7th day of the succeeding month, in the format prescribed under Annexure B to SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 dated June 2, 2025.

Grievance Redressal Policy

This Grievance Redressal Policy sets out the internal mechanism through which client complaints and grievances are received, recorded, escalated, and resolved, in accordance with the SEBI (Research Analysts) Regulations, 2014, the SEBI Master Circular for Research Analysts, and the Investor Charter forming part of this Manual.

Objective

To ensure that every grievance received from a client or prospective client is acknowledged promptly, investigated fairly, and resolved within the timelines prescribed by SEBI, and that the investor is kept informed of the status of the complaint at every stage.

What Constitutes a Grievance

• Non-receipt of a subscribed research report or recommendation;
• Missing pages, corrupted files, or inability to access/download a research report;
• Disputes regarding fees charged, billing, or refunds;
• Complaints regarding the conduct, communication, or service standards of the RA;
• Any other deficiency in the research services provided.

Designated Grievance Redressal Officer

• Name - Rushikesh Uday Gonjare
• Designation - Compliance Officer & Grievance
• Email - rushikeshgonjare@gmail.com
• Phone - +91 9766873676
• Address - A-903, Teerth Avila, Vidya Valley School Road, Sus, Pune – 411021, Maharashtra, India

Channels for Lodging a Grievance

• Directly with the RA – by e-mail, telephone, or written letter at the contact details above;
• SCORES 2.0 – SEBI's centralized online grievance redressal system at https://scores.sebi.gov.in;
• Through RAASB – BSE Limited (RAASB) – via its designated grievance e-mail ID;
• SMART ODR portal – https://smartodr.in – for online conciliation/arbitration, where the investor remains unsatisfied with the resolution offered.

Complaint Handling Process

• Acknowledgement - Written/e-mail acknowledgement of receipt of the complaint, with a unique reference number. (Within 2 working days).
• Investigation - Examination of records, research report logs, communication history, and fee records relevant to the complaint (Within 10 days of receipt).
• Resolution/Reply - Final written response to the client with the resolution, or reasons where the complaint cannot be resolved in the client's favour. (Not later than 21 days of receipt (per the Investor Charter/SEBI norms)).
• SCORES complaints - Action Taken Report (ATR) filed on the SCORES 2.0 platform. (Within 21 calendar days of the complaint being forwarded on SCORES)
• First Level Review (SCORES) - If the investor is dissatisfied with the ATR, a review may be sought. (Within 15 days of the ATR, reviewed by RAASB)
• Second Level Review - Further review, if the investor remains dissatisfied. (By SEBI, per SCORES 2.0 timelines)

Escalation Beyond Us

Where a client is not satisfied with the resolution provided, or does not receive a response within the timelines above, the client may escalate the grievance to RAASB and/or lodge a complaint on SCORES 2.0, and, if still dissatisfied, pursue Online Dispute Resolution through the SMART ODR platform (conciliation followed by arbitration, as applicable), in line with SEBI circular no. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023.

Record-Keeping

• A complaint register is maintained recording the date of receipt, nature of complaint, client details, action taken, and date and mode of resolution.
• All grievance records, correspondence, and ATRs are preserved for a minimum period of five (5) years, or such longer period as may be required under applicable law, in physical or digitally-signed electronic form as prescribed under Regulation 25 of the RA Regulations.
• Monthly complaint data (received, resolved, pending, and ageing) is published on the website in the SEBI-prescribed format, latest by the 7th of the succeeding month.

Fair Treatment

No client shall be discriminated against, or suffer any adverse consequence in the provision of services, on account of having raised a genuine grievance in good faith.

Review of Policy

This Policy shall be reviewed periodically, and in any event whenever there is a change in applicable SEBI regulations or circulars governing grievance redressal for Research Analysts.

Privacy Policy

This Privacy Policy explains how RUSHIKESH UDAY GONJARE, SEBI Registered Research Analyst (Registration No. INH000029263), collects, uses, discloses, stores, and protects the personal data of clients, prospective clients, and website/app visitors ("you", "your"), in accordance with the Digital Personal Data Protection Act, 2023, the Information Technology Act, 2000 and rules made thereunder, and the confidentiality and data-privacy obligations under the SEBI (Research Analysts) Regulations, 2014 and the SEBI Master Circular for Research Analysts.

Information Collected

• Identity information: name, PAN, Aadhaar (where provided for KYC), date of birth, photograph, signature;
• Contact information: address, e-mail ID, mobile number;
• KYC and financial information: income range, occupation, bank account details (for fee receipt verification only), and other details required for KYC as mandated by SEBI/KRA (KYC Registration Agency);
• Communication records: e-mails, call logs, chat transcripts, and other interactions relating to research services, maintained pursuant to Regulation 25 record-keeping requirements;
• Technical information: IP address, browser type, device identifiers, and cookies collected through the website/mobile application for analytics and security purposes.

Purpose of Collection and Use

• To complete client on-boarding and KYC in accordance with SEBI/KRA requirements;
• To deliver research reports, recommendations, and related communications;
• To process payment of fees and issue receipts;
• To respond to queries, service requests, and grievances;
• To comply with statutory, regulatory, and legal obligations, including reporting to SEBI, RAASB, income-tax, and other authorities as required by law;
• To maintain records as mandated under Regulation 25 of the RA Regulations for a minimum of five years;
• To improve the website/mobile application and communicate service updates.

Lawful Basis and Consent

Personal data is collected and processed on the basis of the client's consent obtained at the time of on-boarding, and, where applicable, to comply with a legal obligation. Consent may be withdrawn at any time by written intimation, subject to retention obligations under applicable law, which shall continue to apply to data already collected.

Confidentiality of Research Reports

Confidentiality of a research report is maintained until it is made available in the public domain / disseminated to entitled clients, and research reports and recommendations are distributed to clients without discrimination or selective early disclosure to any client or class of clients.

Disclosure to Third Parties

• Personal data is not sold, rented, or traded to any third party for marketing purposes.
• Personal data may be shared with SEBI, RAASB, KRAs, stock exchanges, banking channels for fee collection (including CeFCoM, where opted for), statutory auditors, and other regulators/authorities strictly to the extent required by applicable law or a valid legal process.
• Personal data may be shared with technology/IT service providers engaged for hosting, e-mail delivery, or data storage, under confidentiality obligations, solely to the extent necessary to render research services.

Data Security

• Reasonable technical and organizational security measures are implemented to protect personal data against unauthorized access, alteration, disclosure, or destruction, including access controls, password protection, and secure storage of physical and electronic records.
• Records that are required to be digitally signed are maintained in digitally-signed electronic form as prescribed under Regulation 25 of the RA Regulations.
• I shall never ask for a client's login credentials, passwords, or one-time passwords (OTPs) for the client's trading, demat, or bank accounts, and clients are advised never to share such credentials with anyone, including with me.

Data Retention

Personal data and related records are retained for a minimum period of five (5) years from the date of the relevant transaction/communication, as required under Regulation 25 of the SEBI (Research Analysts) Regulations, 2014, or for such longer period as may be required to comply with any other applicable law, to resolve disputes, or to enforce agreements, after which such data is securely deleted or anonymized.

Rights of the Data Principal

• Right to access and obtain a summary of personal data held and the processing activities undertaken;
• Right to correction and updation of inaccurate or incomplete personal data;
• Right to withdraw consent, subject to the consequences of withdrawal being explained and statutory retention obligations continuing to apply;
• Right to grievance redressal in relation to the handling of personal data, through the Grievance Redressal Policy forming part of this Manual;
• Right to nominate another individual to exercise these rights in the event of death or incapacity, as permitted under the Digital Personal Data Protection Act, 2023.

Cookies

The website/mobile application may use cookies and similar technologies to remember preferences, enable core functionality, and gather anonymised usage statistics. Cookies can be managed or disabled through browser settings; disabling cookies may affect certain website functionalities.

Children's Data

Research services are not knowingly offered to, and personal data is not knowingly collected from, individuals below eighteen (18) years of age without the consent of a parent or lawful guardian.

Grievances Relating to Data Privacy

Any grievance relating to the handling of personal data may be addressed to the Grievance Officer at rushikeshgonjare@gmail.com / +91 97668 73676 and shall be handled in accordance with the Grievance Redressal Policy forming part of this Manual and applicable timelines under the Digital Personal Data Protection Act, 2023..

Changes to this Policy

This Privacy Policy may be updated periodically to reflect changes in law, regulatory requirements, or business practices. The updated version shall be published on the website with the revised effective date, and material changes shall be separately communicated to existing clients.

Terms & Conditions of Research Service (Including MITC)

RUSHIKESH UDAY GONJARE (Trade Name: Advait Research) ("Research Analyst", "RA") is a SEBI-registered Research Analyst bearing Registration No. INH000029263, enlisted with BSE Limited, presently recognized as the Research Analyst Administration and Supervisory Body (RAASB). Pursuant to the SEBI (Research Analysts) Regulations, 2014, and applicable SEBI Master Circular(s)/circulars issued thereunder, the RA hereby discloses the following Terms and Conditions and undertakings, which govern the relationship between the RA and every client. By subscribing to, or availing of, research services from the RA, the client confirms acceptance of these Terms and Conditions.

Availing of Research Services

The client confirms that he/she/it has elected, at his/her/its sole discretion, to subscribe to the research services of the RA. The RA confirms that research services shall be rendered in accordance with the applicable provisions of the SEBI (Research Analysts) Regulations, 2014.

Obligations of RA and Client

The RA and the client shall be bound by the SEBI Act, 1992, the RA Regulations, and all applicable rules, regulations, and notifications issued by SEBI or the Government of India, as in force from time to time.

Client Information and KYC

• The client agrees to provide complete and accurate information required for Know Your Customer (KYC) compliance, including any details mandated by SEBI or RAASB from time to time.
• The RA will collect, store, upload, and verify KYC records in accordance with SEBI guidelines through a KYC Registration Agency (KRA), as specified from time to time..

Fees and Mode of Payment

• The client shall pay the RA the agreed fees for services rendered, together with applicable statutory charges.
• Fees shall be paid only through banking channels – online bank transfer/NEFT/RTGS/UPI/debit card/credit card, or through the Centralized Fee Collection Mechanism (CeFCoM), where opted for. The RA does not accept fees in cash.
• The maximum fee chargeable to Individual and HUF clients is capped at the amount prescribed by SEBI/RAASB from time to time – presently Rs. 1,51,000/- per annum per family of client for all research services taken together (exclusive of statutory charges). This cap does not apply to non-individual clients or accredited investors.
• Fees may be charged in advance if agreed by the client, for a period not exceeding that stipulated by SEBI (presently one quarter).

Risk Factors

• Investments in securities carry inherent market risk, including potential loss of capital.
• Historical performance of any recommendation is not indicative of future returns.
• The client must independently assess the suitability of any investment decision based on the research reports provided.
• Registration granted by SEBI/enlistment with RAASB, and certification from NISM, in no way guarantee the performance of the RA (intermediary) or provide any assurance of returns to the client.

Conflict of Interest

The RA shall comply with all 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, and shall endeavour to promptly inform the client of any conflict of interest that may affect the services rendered.

Termination and Refunds

• The RA reserves the right to suspend or terminate services in the event of suspension or cancellation of its SEBI registration, or in the circumstances set out in the Termination Policy forming part of this Manual.
• Where the services are terminated prematurely, whether by the client or by the RA, the client shall be entitled to a refund of the proportionate (pro-rata) fees for the unexpired subscription period, computed as: (fee paid ÷ total days in the subscription period) × unexpired days remaining as on the effective date of termination.
• In case of cancellation of SEBI registration, the RA shall refund the pro-rata fees for the remaining subscription period.
• In case of suspension of the certificate of registration for more than sixty (60) days, the RA shall refund the pro-rata fees for the remaining subscription period.
• The 'remaining subscription period' is the period from the effective date of cancellation/suspension to the end of the subscribed period.
• Eligible refunds are processed within thirty (30) days of the request/triggering event, only to the originating bank account/payment instrument through which the fee was received, and never in cash. Statutory charges already remitted, and fees for services already duly delivered, are not refundable.
• Further details are set out in the Termination Policy forming part of this Manual.

Grievance Redressal and Dispute Resolution

• Clients may escalate service-related grievances (e.g., non-receipt of a research report, missing pages, or any other deficiency in service) to the RA's designated Grievance Officer.
• Designated Grievance Officer: Rushikesh Uday Gonjare, E-mail: rushikeshgonjare@gmail.com, Telephone: +91 97668 73676.
• The RA shall resolve grievances not later than 21 days from receipt, or such other timeline as specified by SEBI.
• If unsatisfied with the RA's response, the client may lodge a grievance with SEBI at https://scores.sebi.gov.in (SCORES 2.0), also accessible via the SCORES mobile application.
• Disputes may further be resolved through arbitration or such other mechanism as SEBI may specify, including the Online Dispute Resolution (ODR) portal at https://smartodr.in, per SEBI circular no. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023.

Mandatory Notice – Do's and Don'ts

Clients are advised and requested to familiarise themselves with the 'Do's and Don'ts' while dealing with Research Analysts, as specified in the SEBI Master Circular for Research Analysts, as amended/updated by SEBI from time to time.

Optional Centralized Fee Collection Mechanism (CeFCoM)

A client may opt to use CeFCoM, managed by RAASB, for making fee payments, by sending an e-mail request to the RA for processing.

Standard Client Confirmations

By subscribing to research services, the client confirms that:

• “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 Analysts) Regulations, 2014, including the fee structure.”
• “I/We are subscribing to the research services for our own benefit and consumption, and any reliance placed on the research report shall be as per our own judgement and assessment of the conclusions contained therein.”
• “I/We understand that: (i) any investment made based on the recommendations in the research report is subject to market risk; (ii) recommendations in the research report do not provide any assurance of returns; and (iii) there is no recourse to claim any losses incurred on investments made based on the recommendations in the research report.”

RA Declarations

• It is duly registered with SEBI as a Research Analyst under the RA Regulations – Registration No. INH000029263, Validity: July 23, 2026 – Perpetual.
• It holds the registration and qualifications required to render research services as contemplated under the RA Regulations, valid and subsisting.
• The services provided do not conflict with or violate any applicable law or agreement.
• The maximum fee charged is Rs. 1,51,000/- per annum per family of client, subject to the cap prescribed by SEBI/RAASB from time to time.
• Recommendations provided do not offer any assurance of returns.

Contact Details

• Principal Officer / Individual RA - Rushikesh Uday Gonjare (rushikeshgonjare@gmail.com)
• Compliance Officer - Rushikesh Uday Gonjare (rushikeshgonjare@gmail.com) |
• Grievance Officer - Rushikesh Uday Gonjare (rushikeshgonjare@gmail.com) / +91 97668 73676

Annexure A – Most Important Terms and Conditions (MITC)

(As standardized by the Industry Standards Forum for Research Analysts in consultation with RAASB and SEBI, pursuant to SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/22 dated February 17, 2025, issued under Regulation 24(6) of the RA Regulations.)

• These terms and conditions, and the consent thereon, are for the research services provided by the Research Analyst (RA), and the RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client. Clients are advised not to permit the RA to execute any trade on their behalf.
• The fee charged by the RA to the client is subject to the maximum amount prescribed by SEBI/RAASB from time to time (applicable only to 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 and does not apply to a non-individual client/accredited investor.
• The RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI – presently one quarter. In case of pre-mature termination of the RA's services by either the client or the RA, the client shall be entitled to seek a refund of proportionate fees only for the unexpired period.
• Fees to the RA may be paid by the client through any of the specified modes, such as online bank transfer, UPI, cheque, etc. Cash payment is not allowed. Clients may optionally use the Centralized Fee Collection Mechanism (CeFCoM) managed by RAASB.
• 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, and shall endeavour to promptly inform the client of any conflict of interest that may affect the services rendered.
• Any assured/guaranteed/fixed-return scheme, or any scheme of a similar nature, is prohibited by law. No such scheme 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, and estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of the research report.
• Any investment made based on recommendations in research reports is subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on investments made based on the recommendations in the research report. Any reliance placed on the research report shall be as per the client's own judgement and assessment of the conclusions contained therein.
• SEBI registration, enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
• For any grievance: Step 1 – the client should first contact the RA using the details on its website or the contact details in the Grievance Redressal Escalation Matrix; Step 2 – if the resolution is unsatisfactory, the client may lodge a grievance through SEBI's SCORES platform at www.scores.sebi.gov.in; Step 3 – the client may consider Online Dispute Resolution through the SMART ODR portal at https://smartodr.in.
• Clients are required to keep their contact details, including e-mail ID and mobile number(s), updated with the RA at all times.
• The RA shall never ask for the client's login credentials or OTPs for the client's trading, demat, or bank accounts. Clients must never share such information with anyone, including with the RA.

5. Refund Policy

RUSHIKESH UDAY GONJARE (Trade Name: Advait Research) maintains a transparent fee and refund policy in line with the SEBI (Research Analysts) Regulations, 2014, the SEBI Master Circular for Research Analysts dated February 6, 2026 (as amended), and the standardized Most Important Terms and Conditions (MITC) issued vide SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/22 dated February 17, 2025. This Policy sets out the circumstances in which a refund is available, the circumstances in which it is not, and the process for claiming an eligible refund.

A. Eligible Refund Scenarios

Subscribers may request a refund or cancellation under the following specific circumstances:

• Double Payment / Billing Error: If a client is charged multiple times for the same subscription due to a payment-gateway or technical error, the duplicate transaction will be identified and refunded in full, in addition to (and without affecting) any refund otherwise due under this Policy.
• Non-Delivery of Services: If the RA fails to deliver the research reports or recommendations promised under the client's subscription tier, the client will be entitled to a refund proportionate to the services not delivered, computed in accordance with paragraph 5.C below.
• Premature Termination: In the event of premature termination of research services by either the client or the RA, the client is entitled to a refund of fees for the unexpired/unused subscription period on a pro-rata basis, computed as:

Refund Amount = (Fee Paid ÷ Total Number of Days in the Subscribed Period) × Number of Unexpired Days Remaining as on the Effective Date of Termination. No breakage fee or cancellation penalty shall be levied on the client in respect of such pro-rata refund.

• Regulatory Action: If the RA's SEBI registration is suspended for a continuous period exceeding sixty (60) days or cancelled by SEBI, any subscription fee collected for the unexpired portion of the subscription period shall be refunded to the client on a pro-rata basis, computed in the same manner as set out above.

B. Non-Refundable Scenarios

In accordance with industry compliance requirements and the market-risk disclaimers applicable to research analyst services, the following are NOT eligible for a refund:

• Market Losses: Investments in the securities market carry inherent risk. Under no circumstances will a refund be issued for losses incurred by a client based on the RA's research recommendations, since the RA does not, and cannot, guarantee returns, profits, or the accuracy of any recommendation.
• Performance Dissatisfaction: Dissatisfaction with the performance of recommended stocks, price targets, or stop-loss levels being triggered is not, by itself, a ground for a refund, and does not constitute non-delivery of services under paragraph 5.A above.
• Elapsed / Delivered Portion of the Subscription: Fees corresponding to the portion of the subscription period for which research reports/recommendations were duly delivered are not refundable.
• Statutory Charges: Statutory levies, taxes, and government charges already remitted to the exchequer are not refundable.

C. Refund Processing & Claims

To claim an eligible refund, the client must e-mail the RA at [rushikeshgonjare@gmail.com] and [info@advaitresearch.com] within seven (7) days of the occurrence giving rise to the claim, enclosing invoice details and proof of the transaction, such as payment confirmation, bank/UPI reference number, or gateway transaction ID.

• The RA shall acknowledge receipt of the refund claim within two (2) working days and shall verify the claim against its records, including payment-gateway records, KYC details, and the client's subscription history.
• Verified and eligible refunds will be processed to the client's bank account, being the same account/instrument from which the original payment was made, within ten (10) to fifteen (15) working days of verification.
• Any statutory deductions applicable at the time of refund, such as GST, and any payment-gateway processing charges actually incurred and non-recoverable by the RA will be deducted from the final refund amount, to the extent permitted under SEBI guidelines and applicable law.
• Refunds are made only through banking channels, including NEFT / RTGS / UPI / bank transfer, directly to the client's own verified bank account, and are never paid in cash or to a third-party account.
• Where a refund claim is rejected, in whole or in part, the RA shall communicate the reasons in writing to the client, who may thereafter pursue the matter through the Grievance Redressal Policy forming part of this Manual, and, if unresolved, through SEBI's SCORES 2.0 platform or the SMART ODR portal.

D. General Conditions

• This Refund Policy is subject to, and shall be read together with, the MITC and the Terms & Conditions of Research Service forming part of this Manual. In case of any conflict, the more recent SEBI circular in force at the relevant time shall prevail.
• This Policy applies uniformly to all clients and does not discriminate between clients on any ground other than the objective circumstances set out above.
• This Policy shall be reviewed periodically and updated to reflect any change in the SEBI (Research Analysts) Regulations, 2014, the MITC, or applicable RAASB/SEBI circulars governing fees and refunds.

Registration granted by SEBI, enlistment with RAASB, and certification from NISM in no way guarantee the performance of the intermediary or provide any assurance of returns to investors. Refunds under this Policy relate solely to fees paid for research services and do not, under any circumstance, extend to compensation for investment losses.