Compliance & policies.

This disclaimer is provided by https://bsestocks.com/ (herein referred as "AT RESEARCH & RISK MANAGERS" or the "SEBI Registered Research Analyst") that apply to your access and use of the website (herein referred as "AT RESEARCH & RISK MANAGERS" or the "website") which is the property of the Research Analyst.

Fraudulent / Declined Transactions

AT RESEARCH & RISK MANAGERS reserves the right to recover the cost of service charges and lawyers' fees from persons using the website fraudulently. AT RESEARCH & RISK MANAGERS also reserves the right to initiate legal proceedings against such persons for fraudulent use of the website and any other unlawful acts or acts or omissions in breach of these terms and conditions.

Warranty Regarding Any Access of the Website and Content

The contents of this site, any service or product available on it and availed by you are provided to you without any warranty by AT RESEARCH & RISK MANAGERS or this website. You acknowledge that any warranty that is provided in connection with any of the products or services described herein is provided solely by the owner, advertiser, manufacturer or supplier of that product and/or service, and not by AT RESEARCH & RISK MANAGERS. Though all best possible efforts are made by AT RESEARCH & RISK MANAGERS for your best navigation of this site but AT RESEARCH & RISK MANAGERS does not warrant that your access to the site and/or related services will be uninterrupted or error-free, that defects will be corrected, or that this site or the server that makes it available is free of viruses or other harmful components. Access to and use of this site and the information is at your risk and AT RESEARCH & RISK MANAGERS does not undertake any accountability for any irregularities, viruses or damage to any computer that results from accessing, availing or downloading of information from this site. AT RESEARCH & RISK MANAGERS does not warrant or make any representations regarding the use or the results of the use of any product and/or service purchased in terms of its compatibility, correctness, accuracy, reliability or otherwise. You assume total responsibility and risk for your use of this site and site-related services.

Electronic Communications

When you visit the website or send emails to us, you are communicating with us electronically. You consent to receive communications from us electronically. We will communicate with you by email or by posting notices on the website. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

Force Majeure

AT RESEARCH & RISK MANAGERS shall not be responsible for delay or default in the performance of their obligations due to contingencies beyond their control, such as (including but not limited to) losses caused directly or indirectly by exchange or market rulings, suspension of trading, fire, flood, civil commotion, earthquake, war, strikes, failure of the systems, failure of the internet links or government / regulatory action.

Intellectual Property Rights

The contents of the website that including Company Logo, Brand image, design (e.g., text, graphics, images, logos and button icons), graphic user interface, photographs, editorial content, notices, software (including html-based computer programs) are property of AT RESEARCH & RISK MANAGERS. The contents belong or are licensed to AT RESEARCH & RISK MANAGERS or its software or data or content suppliers. The Company grants you the right to view and use any of the content subject to these terms. Any distribution, reprint or electronic reproduction of any content from the website of AT RESEARCH & RISK MANAGERS in whole or in part for any other purpose is expressly prohibited. The Customer acknowledges that the software underlying the Website as well as other Internet related software which are required for accessing AT RESEARCH & RISK MANAGERS Online Services are the legal property of the Company and/or its vendors or contractors. The Terms underlying this agreement will not convey any proprietary or ownership rights in the above software. The Customer agrees that he/she shall not attempt to modify, translate, disassemble, recompile or reverse engineer the software underlying the website or create any derivative product based on the software. The customer further agrees not to use the name, logo or mark of AT RESEARCH & RISK MANAGERS and any related patent, trademarks and service marks applications, design rights, copyrights, and all or any similar or equivalent rights arising or subsisting in any country in the world.

Disclaimer Regarding SEBI & Stock Exchanges

National Stock Exchange of India Limited, Bombay Stock Exchange Limited and Securities and Exchange Board of India are not in any manner answerable, responsible or liable to any person or persons for any acts of omission or commission, errors, mistakes and/or violation, actual or perceived, by us or our partners, agents, associates etc., of any of the Rules, Regulations, Bye-laws or any other laws in force from time to time. The Stock Exchanges or the SEBI are not answerable, responsible or liable for any information on this website or for any services rendered by AT RESEARCH & RISK MANAGERS, its employees or associates.

In Case of Any Losses

You agree that, except as provided under the AT RESEARCH & RISK MANAGERS return policy, AT RESEARCH & RISK MANAGERS and its directors, officers, employees, agents, sponsors, consultants, business partners or other representatives ('service providers') shall not be responsible or liable for any direct, indirect, incidental, consequential, special, exemplary, punitive or any other damages (including without limitation loss of profits, loss or corruption of data, loss of goodwill, work stoppage, computer failure or malfunction, or interruption of business) under any contract, negligence, strict liability or other theory arising out of or relating in any way with the use of the site or in reliance of the information available on the site, site-related services, or any products or services offered or sold or displayed on https://bsestocks.com/

Miscellaneous

Although AT RESEARCH & RISK MANAGERS makes best efforts to ensure the integrity, correctness and authenticity of the data available on the site, it makes no guarantees whatsoever as to its completeness, correctness or accuracy. In the event that any such inaccuracy arises, please inform AT RESEARCH & RISK MANAGERS so that it can be corrected.

AT RESEARCH & RISK MANAGERS does not make any recommendations to buy, sell or hold a particular security. The information on our Internet site is provided solely to enable investors to make their own investment decisions and they themselves are responsible for profits/losses arising out of their dealings on the stock market.

This Internet site is available only to Indian Residents and is presently not available to Foreign Nationals and Non Resident Indians in foreign jurisdiction where the services cannot be offered without prior regulatory compliance. In such cases due efforts are been made to comply with regulatory requirements in various jurisdictions which shall be notified from time to time. This service does not constitute an offer to sale or a solicitation to any person in any jurisdiction where it is unlawful to make such an offer or solicitation.

You understand and agree that no joint venture, partnership, employment or agency relationship exists between you and us as a result of this agreement or on account of use of our web site.

Price and availability of products and services offered on the site are subject to change without prior notice. AT RESEARCH & RISK MANAGERS shall not be liable for any lack of availability of products and services you may order through the site.

Do's

• Always deal with SEBI registered Research Analyst
• Ensure that the Research Analyst has a valid registration certificate
• Check for SEBI registration number
• Please refer to the list of all SEBI registered Research Analysts which is available on SEBI website at this link: SEBI Registered Research Analysts
• Always pay attention towards disclosures made in the research reports before investing
• Pay your Research Analyst through banking channels only and maintain duly signed receipts mentioning the details of your payments
• Before buying securities or applying in public offer, check for the research recommendation provided by your Research Analyst
• Ask all relevant questions and clear your doubts with your Research Analyst before acting on the recommendation
• Inform SEBI about Research Analyst offering assured or guaranteed returns

Don'ts

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

1) Definitions

The parties referenced in these Terms of Service are defined as follows:

a) Owner, Us, We: The Owner, serving as the Research Analyst, offers Research Services on securities to users. Terms such as AT RESEARCH & RISK MANAGERS, Owner, Us, We, Our, Ours, and other first-person pronouns refer to the Owner and all employees and affiliates associated with the Owner.

b) You, the User, the Client: As the user of the Research Services, you will be identified throughout these Terms of Service with second-person pronouns like You, Your, Yours, or as User or Client. In this context, "User" or "you" denotes any individual or legal entity accessing the Research Services.

c) Parties: Collectively, the Owner and you will be referred to as Parties in these Terms of Service.

2) Assent & Acceptance

By utilizing the Research Services, you confirm that you have read and understood these Terms of Service and agree to adhere to them. If you do not accept these Terms of Service, please request a refund immediately (if applicable). The owner will provide access to the Research Services only if you agree to these Terms. Additionally, depending on the services obtained by a User, further terms and conditions may apply, which will be seen as an agreement between Users and the Owner.

3) Availing the Research Services

By accepting the delivery of the research service, the client confirms their choice to subscribe to the research service of "RA AT RESEARCH & RISK MANAGERS: INH000013794" at their discretion. The service "RA AT RESEARCH & RISK MANAGERS: INH000013794" affirms that research services will be delivered in compliance with the relevant provisions of the RA Regulations.

4) Obligations on RA

"RA AT RESEARCH & RISK MANAGERS: INH000013794" and the client are required to comply with the SEBI Act and all applicable SEBI rules and regulations, including the RA Regulations and relevant government notifications, as they may be updated from time to time.

5) Client Information and KYC

The client must provide all necessary details in full as required by "RA AT RESEARCH & RISK MANAGERS: INH000013794" in its standard format, along with any supporting documentation mandated by RAASB/SEBI. "RA AT RESEARCH & RISK MANAGERS: INH000013794" will collect, store, upload, and verify KYC records of clients with the KYC Registration Agency (KRA) as directed by SEBI periodically.

6) Standard Terms of Service

The client's consent will be obtained based 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 benefit and consumption; any reliance on the research report provided by the research analyst will be based on our own judgment and assessment of the conclusions within the report.

I/We understand that —

1. Investments based on recommendations in the research report are subject to market risk.
2. Holding positions without stop-loss or target may lead to significant losses in unfavorable market conditions or company events.
3. Market risks may result in partial or total loss of investments under certain conditions.
4. Registration by SEBI and certification from NISM do not guarantee the performance of the intermediary or assure returns to investors.
5. Past performance is not indicative of future results.
6. Recommendations in the research report do not guarantee returns.
7. "There is no avenue for claiming losses incurred based on the recommendations in the research report."

Declaration from "RA AT RESEARCH & RISK MANAGERS: INH000013794"

1. "RA AT RESEARCH & RISK MANAGERS: INH000013794" is duly registered with SEBI as an RA pursuant to the SEBI (Research Analysts) Regulations, 2014, and its registration details are:
   • Registration Name: AT RESEARCH & RISK MANAGERS
   • Registration Number: INH000013794
   • Registration Date: 30-November-2023
   • Trade Name for Research Services: AT RESEARCH & RISK MANAGERS
   • Website for Research Services: www.bsestocks.com
2. "RA AT RESEARCH & RISK MANAGERS: INH000013794" holds valid registration and qualifications necessary to provide the services outlined in the RA Regulations, which remain valid and active.
3. Services provided by "RA AT RESEARCH & RISK MANAGERS: INH000013794" do not conflict with or violate any laws, rules, regulations, contracts, or other agreements to which it is bound or to which its property is subject.
4. The maximum fee charged by "RA AT RESEARCH & RISK MANAGERS: INH000013794" is ₹1.51 lakhs per annum per family of clients.
5. Recommendations made by "RA AT RESEARCH & RISK MANAGERS: INH000013794" do not guarantee returns.

7) Consideration and Mode of Payment

The client shall promptly pay "RA AT RESEARCH & RISK MANAGERS: INH000013794" the agreed fees for the services rendered, along with any applicable statutory charges. Such fees and charges will be payable through specified methods and mechanisms.

1. For services details and charges, please visit our website: www.bsestocks.com.
2. Refunds will be processed as per SEBI guidelines on a pro-rata basis of unused services.

8) Terms and Conditions for RA Services Mentioned Above

• You will receive 1-15 research recommendations each month.
• The number of recommendations may vary based on market conditions.

9) Risk Factors

(A statement covering standard risks associated with investment in securities will be included here by RA AT RESEARCH & RISK MANAGERS: INH000013794)

Investing in securities carries several risks that could negatively impact your investments or portfolio:

• Market Risk: Fluctuations in market conditions can affect revenue and profitability.
• Financial Risk: Changes in currency and interest rates can impact financial results.
• Operational Risk: Natural disasters or disruptions can lead to production delays and losses.
• Regulatory Risk: Changes in regulations or legal actions can affect business operations.
• Competition Risk: Intense competition can result in pricing pressures and reduced market share.
• Technology Risk: Cybersecurity breaches or technology failures can compromise data security.
• Supply Chain Risk: Disruptions caused by supplier issues can affect production.
• Environmental and Sustainability Risk: Non-compliance with regulations can harm the business.
• Credit Risk: Economic downturns or borrower defaults can lead to loan losses for financial institutions.
• Litigation Risk: Ongoing legal proceedings can result in financial liabilities.

MARKET RISKS WARNING: Investments in the securities market are subject to market risks. Please read all related documents carefully before investing.

LOSS POSSIBILITY WARNING: Market risks may lead to partial or total loss of investments under certain market conditions.

Risks in Futures and Options Trading are VERY HIGH

SEBI REGISTRATION: Registration granted by SEBI and certification from NISM do not guarantee performance by the intermediary or assure returns to investors.

PAST PERFORMANCE WARNING: Past performance is not indicative of future results.

NO WARRANTIES WARNING: The Research Analyst does not guarantee the accuracy or results of recommended securities.

EXERCISE CAUTION WARNING: "RA AT RESEARCH & RISK MANAGERS: INH000013794" provides research analysis and specific securities recommendations but does not offer portfolio management services, personal account handling, profit sharing, or risk-profiling-based investment advisory services.

10) Conflict of Interest

"RA AT RESEARCH & RISK MANAGERS: INH000013794" complies with all applicable regulations, circulars, and directives from SEBI regarding the disclosure and mitigation of any actual or potential conflict of interest.

11) Termination of Service and Refund of Fees

Disclosure that "RA AT RESEARCH & RISK MANAGERS: INH000013794" may suspend or terminate research services to clients due to suspension or cancellation of the RA's registration by SEBI, and will refund any remaining amount to the client.

If the certificate of registration of "RA AT RESEARCH & RISK MANAGERS: INH000013794" is suspended for over 60 days or canceled, the "RA AT RESEARCH & RISK MANAGERS: INH000013794" will refund the fees on a pro-rata basis for the duration from the effective date of cancellation/suspension to the end of the subscription period.

If services are terminated prematurely as outlined, consideration, and mode of payment, the fees for research services are non-refundable.

If a client choose not to continue with the "RA AT RESEARCH & RISK MANAGERS: INH000013794" services, the fee for one month will not be refunded under any circumstances due to various costs and factors related to portfolios and securities. Thus, it is not feasible to refund the entire fee.

For example, after subscribing to any "RA AT RESEARCH & RISK MANAGERS: INH000013794" services, investors gain access to both current and historical securities.

12) Grievance Redressal and Dispute Resolution

Any grievances regarding:

1. Non-receipt of research reports
2. Missing pages or inability to download the complete report
3. Deficiencies in the research services provided by "RA AT RESEARCH & RISK MANAGERS: INH000013794"

Must be promptly escalated to the designated person/employee:

• Designated Person/Employee Name: Aditya Thukral
• Email ID: aditya.thukral423@gmail.com
• Phone: +91 9066795009

"RA AT RESEARCH & RISK MANAGERS: INH000013794" will address grievances within 7 business working days or within timelines specified by SEBI under the RA Regulations.

Grievances will be resolved in a timely and transparent manner. Disputes may be resolved through arbitration or any methods specified by SEBI from time to time.

SEBI Resources

• SCORES Link: https://scores.sebi.gov.in/
• SEBI ODR Link: https://smartodr.in/
• SEBI Toll-Free Number: 1800 22 7575 or 1800 266 7575
• SEBI Office Addresses: https://www.sebi.gov.in/contact-us.html

13) Additional Clauses

All additional voluntary clauses added by "RA AT RESEARCH & RISK MANAGERS: INH000013794" must comply with SEBI's rules, regulations, and circulars. Any changes to such voluntary clauses/documents will be preceded by a notice of 15 days.

Some voluntary clauses for "RA AT RESEARCH & RISK MANAGERS: INH000013794" include:

• Research service fees paid are non-refundable or refundable with the conditions mentioned above or as per SEBI guidelines.
• Any changes or updates to the terms and conditions will be communicated to you in advance for your approval.

14) Mandatory Notice

Clients are encouraged to review the Do's and Don'ts while dealing with "RA AT RESEARCH & RISK MANAGERS: INH000013794" 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 subsequently.

15) Most Important Terms and Conditions (MITC)

1. These terms and conditions, and consent thereon are for the research services provided by the Research Analyst – "RA AT RESEARCH & RISK MANAGERS: INH000013794" 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 AT RESEARCH & RISK MANAGERS: INH000013794" 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.
3. "RA AT RESEARCH & RISK MANAGERS: INH000013794" 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 premature termination of the RA 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.
4. Fees to "RA AT RESEARCH & RISK MANAGERS: INH000013794" 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 AT RESEARCH & RISK MANAGERS: INH000013794" 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 AT RESEARCH & RISK MANAGERS: INH000013794".
7. The "RA AT RESEARCH & RISK MANAGERS: INH000013794" 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 AT RESEARCH & RISK MANAGERS: INH000013794" 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 AT RESEARCH & RISK MANAGERS: INH000013794" or assure any returns to the client.
10. For any grievances:
    • Step 1: The client should first contact the "RA AT RESEARCH & RISK MANAGERS: INH000013794" using the details on its website www.bsestocks.com or via email at aditya.thukral423@gmail.com.
    • 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 www.smartodr.in.
11. Clients are required to keep contact details, including email id and mobile number/s updated with the "RA AT RESEARCH & RISK MANAGERS: INH000013794" at all times.
12. The "RA AT RESEARCH & RISK MANAGERS: INH000013794" 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.

16) Optional Centralised Fee Collection Mechanism

Centralized Fee Collection Mechanism (CeFCoM): This initiative by SEBI aims to ensure that investor payments are securely directed to legitimate SEBI-registered advisors rather than elsewhere.

• It enables investors to track all payments made to SEBI-registered advisors.
• Investors can request a link for the Centralized Fee Collection Mechanism (CeFCoM) from registered Research Analysts and can make payments using various methods.

17) The Use of AI Tools in Research and Advisory Services Involves Several Key Points

• Our recommendations are based on technical and fundamental analysis.
• Our responsibility for client data security, confidentiality, and compliance is upheld on the use of AI.
• AI trading risks include system vulnerabilities that can amplify errors.
• Handling sensitive data poses privacy and security risks, including potential breaches.
• Concerns include biased outputs, privacy violations, lack of transparency, data quality issues, and misleading results from poor data.
• Severe data glitches may result in significant losses related to your security or portfolio.

18) Client-Level Segregation of Research and Distribution Activities

The "RA AT RESEARCH & RISK MANAGERS: INH000013794" mandates client-level segregation of research and distribution activities per Regulation 26C(5) of RA Regulations.

Existing clients cannot access both services within the same group / family of the RA. New clients can choose either research or distribution services at on-boarding, but not both.

19) Model Portfolio by Research Analyst

"RA AT RESEARCH & RISK MANAGERS: INH000013794" will adhere to the Research Analysts' Guidelines for recommending a 'model portfolio' whenever necessary.

20) Jurisdiction, Venue & Governing Law

Through your use of the website www.bsestocks.com or services, you agree that the laws of SEBI shall govern any matter or dispute relating to Service, as well as any dispute of any kind that may arise between You and the Owner. In case any litigation specifically permitted under these Service is initiated, the Parties agree to submit to the exclusive jurisdiction of the courts at Ludhiana, Punjab, India. The Parties agree that this choice of law, venue, and jurisdiction provision is not permissive, but rather mandatory in nature.

21) Amendments

We may modify or update these T&C in accordance with SEBI regulations. Notice of material changes will be posted on our website or emailed to you. Continued use of the services indicates your acceptance of updated T&C.

22) Indemnification

You agree to protect the RA, its officers, employees, and affiliates from any claims, damages, losses, or liabilities arising from:

• Your breach of these terms or violation of the law.
• Unauthorized or improper use of your account.
• Third-party claims related to your actions or inactions.

23) Suspension & Termination

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.

Termination

• Violation of T&C by you.
• Directions from SEBI or any competent regulatory authority.
• Non-payment of fees (beyond the grace period, if any).
• Refunds (if any).

A. Vision and Mission Statements for Investors

Vision

Invest with knowledge & safety.

Mission

Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

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

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

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

• Onboarding of Clients
• Sharing of terms and conditions of research services
• Completing KYC of fee paying clients

Disclosure to Clients

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

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

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

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. Refer to the list of all SEBI registered Research Analysts on SEBI website at: SEBI Registered RAs
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 rumours.
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.

If you have a grievance, you can reach out to our Support Team for assistance.

Designation	Contact Person	Address	Phone	Email	Working Hours
Customer Care	Aditya Thukral	5588 Anand Nagar, Raghubir Park, Haibowal Kalan, Ludhiana – 141001	+91 9066795009	aditya.thukral423@gmail.com	Mon–Fri 9 AM – 5 PM
Head of Customer Care	Aditya Thukral	5588 Anand Nagar, Raghubir Park, Haibowal Kalan, Ludhiana – 141001	+91 9066795009	aditya.thukral423@gmail.com	Mon–Fri 9 AM – 5 PM
Compliance Officer	Aditya Thukral	5588 Anand Nagar, Raghubir Park, Haibowal Kalan, Ludhiana – 141001	+91 9066795009	aditya.thukral423@gmail.com	Mon–Fri 9 AM – 5 PM
CEO	Aditya Thukral	5588 Anand Nagar, Raghubir Park, Haibowal Kalan, Ludhiana – 141001	+91 9066795009	aditya.thukral423@gmail.com	Mon–Fri 9 AM – 5 PM
Principal Officer	Aditya Thukral	5588 Anand Nagar, Raghubir Park, Haibowal Kalan, Ludhiana – 141001	+91 9066795009	aditya.thukral423@gmail.com	Mon–Fri 9 AM – 5 PM

The above mentioned details would facilitate the complainants to approach the concerned RA before filing complaint to SEBI. For more details, see BSE Circular dated 09-Dec-2024.

We aim to resolve all grievances within 21 working days from the date of receipt.

If your grievance is not resolved within this time frame, you can escalate it to SEBI's SCORES Platform (SEBI Complaints Redress System).

SCORES Portal: scores.sebi.gov.in

In case you are unsatisfied with the resolution provided through our support or the SCORES platform, you can access the Online Dispute Resolution (ODR) Portal.

ODR Portal: smartodr.in

Details of Complaints

Last updated on: 15 December 2025

Sr. No.	Received From	Pending at the end of last month	Received	Resolved	Total Pending	Pending Complaints > 3 months	Average Resolution Time
1	Support	0	0	0	0	0	0
2	SEBI Scores	0	0	0	0	0	0
3	Other Sources	0	0	0	0	0	0
Grand Total		0	0	0	0	0	0

SEBI vide its Notification No. LAD-NRO/GN/2014-15/07/1414 dated September 1, 2014 has notified SEBI (Research Analysts) Regulations, 2014 (hereinafter referred to as 'SEBI Regulations'). These regulations have been introduced by SEBI with the objective of fostering transparency in security research and provide the investors with more reliable and useful information to make investment decisions. According to these regulations, Research Analyst(s) or Research Entity are required to put in place a comprehensive policy framework as prescribed in Chapter III of the SEBI Regulations.

To ensure compliance with SEBI Regulations, AT RESEARCH & RISK MANAGERS (referred to as Research Analyst), is required to adopt and adhere to such regulations, subject to the following internal policies and control procedures:

Applicability

This policy shall be applicable to Research Analyst, i.e. a person primarily responsible for preparation or publication of the content of the research report; or providing a research report or making "buy / sell / hold" recommendation or giving price target or offering an opinion concerning public offer with respect to securities that are listed or proposed to be listed in a Stock Exchange, whether or not such person has the job title of a "research analyst". It also includes an associated person who reports directly or indirectly to the Research Analyst.

Definitions

Various terms shall have the following definitions and the other terms shall have the same meaning assigned to them in the SEBI Regulations.

"Associate" means associate as defined in Securities and Exchange Board of India (Intermediaries) Regulations, 2008. Securities and Exchange Board of India (Intermediaries) Regulations, 2008 defines associate as any person controlled, directly or indirectly, by the intermediary, or any person who controls, directly or indirectly, the intermediary, or any entity or person under common control with such intermediary, and where such intermediary is a natural person will include any relative of such intermediary and where such intermediary is a body corporate, will include its group companies (as defined in the Monopolies and Restrictive Trade Practices Act, 1969 (Act No. 54 of 1969) or any re-enactment thereof) or companies under the same management.

"Price Target" means expectations of the Research Analyst on the future performance of specific securities.

"Public Appearance" means any participation in a conference call, seminar, forum (including interactive and non-interactive electronic forum), radio or television or internet or web or print media broadcast, authoring a print media article or other public speaking activity in public media in which a Research Analyst makes a recommendation or offers an opinion, concerning securities or public offer; provided that it does not include a password protected webcast, conference call or such other events with the clients, if all of the event participants previously received the research report or other documentation that contains the required applicable disclosures and that the Research Analyst appearing at the event corrects and updates during the public appearance any disclosure in the Research Report that are inaccurate, misleading or no longer applicable.

"Public Offer" includes initial public offer, further public offer, offer for sale, disinvestment, takeover, buy-back or delisting of securities.

"Research Analyst" means a person who is primarily responsible for: preparation or publication of the content of the research report; providing research report; giving price target; offering an opinion concerning public offer, with respect to securities that are listed or to be listed in a stock exchange, whether or not any such person has the job title of "research analyst" and includes any other entities engaged in issuance of research report or research analysis. It also includes any associated person who reports directly or indirectly to such a research analyst in connection with activities provided above.

"Relative" means a person as defined in sub section (77) of section 2 of the Companies Act, 2013 and who is financially dependent on independent research analyst or individual research analyst employed by research entity.

"Research Entity" means an intermediary registered with SEBI who is also engaged in merchant banking or investment banking or brokerage services or underwriting services and issue research report or research analysis in its own name through the individuals employed by it as research analyst and includes any other intermediary engaged in issuance of research report or research analysis.

"Research Report" means any written or electronic communication that includes research analysis or research recommendation or an opinion concerning securities or public offer, providing a basis for investment decision and does not include the following communications:

• Comments on general trends in the securities market
• Discussions on the broad-based indices
• Commentaries on economic, political or market conditions
• Periodic reports or other communications prepared for unit holders of mutual fund or alternative investment fund or clients of portfolio managers and investment advisers
• Internal communications that are not given to current or prospective clients
• Communications that constitute offer documents or prospectus that are circulated as per regulations made by the Board
• Statistical summaries of financial data of the companies
• Technical analysis relating to the demand and supply in a sector or index
• Any other communication which SEBI may specify from time to time.

"Significant news or event" means any news or event which is expected to have a material impact on or that reflects a material change to, the subject company's earnings, operations or financial condition, other than unpublished price sensitive information.

"Subject company" means the company whose securities are the subject of a Research Report or a public appearance.

Management of Conflict of Interest and Disclosure Requirements

The Research Analyst shall maintain arms-length relationship between the research activities and other activities.

Limitations on trading by research analysts

Personal trading activities of the research analysts, if any, shall be monitored, recorded and wherever necessary, shall be subject to a formal approval process.

Research Analyst shall not

• The Research Analyst shall not publish or distribute research report or research analysis or make public appearance regarding a subject company for which he has acted as a manager or co-manager at any time falling within a period of: (i) 40 days immediately following the day on which securities are priced if the offering is an initial public offering; or (ii) 10 days immediately following the day on which securities are priced if the offering is a further public offering.
• In case the Research Analyst is acting as an underwriter of any initial public offering, he shall not publish or distribute a research report or make public appearance regarding that issuer for 25 days from the date of offering.
• In case the Research Analyst has acted as a manager or co-manager of public offering of securities of a company, he shall not publish or distribute a research report or make public appearance concerning that company within 15 days prior to date of entering into and 15 days after expiration / waiver / termination of a lock-up agreement or any other agreement that the Research Analyst has entered into with the subject company that restricts or prohibits the sale of securities held by the subject company after the completion of public offering of securities.
• The Research Analyst shall not participate in business activities designed to solicit investment banking or merchant banking or brokerage services business, such as sales pitches and deal road shows.
• The Research Analyst shall have adequate documentary basis, supported by research, for preparing a research report.
• The Research Analyst shall not provide any promise or assurance of favourable review in the Research Report to a company or industry or sector or group of companies or business group as a consideration to commence or influence a business relationship of for the receipt of compensation or other benefits.
• The Research Analyst shall not issue a Research Report that is not consistent with the views of the individuals employed as research analyst regarding a subject company.

Disclosures in Research Report

The Research Analyst shall disclose all material information including the business activity, disciplinary history, the terms and conditions on which the Research Report is offered details of associates and such other information as is necessary to take an investment decision, including the following:

The Research Analyst shall disclose the following in Research Report and in public appearance with regard to ownership and material conflicts of interest: whether the Research Analyst has any financial interest in the subject company and the nature of such financial interest; whether the Research Analyst has actual / beneficial ownership of 1% or more securities of the subject company, at the end of the month immediately preceding the date of publication of the Research Report or date of the public appearance; whether the research analyst, has any other material conflict of interest at the time of publication of the Research Report or at the time of public appearance.

The Research Analyst shall disclose the following in Research Report with regard to receipt of compensation:

• whether he has received any compensation from the subject company in the past 12 months;
• whether he has managed or co-managed public offering of securities for the subject company in the past 12 months;
• whether he has received any compensation for investment banking or merchant banking or brokerage services from the subject company in the past 12 months;
• whether he has received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past 12 months;
• whether he has received any compensation or other benefits from the Subject Company or third party in connection with the Research Report.
• whether the subject company is or was a client during 12 months preceding the date of distribution of research report and the types of such services provided;
• whether the Research Analyst has served as an officer, director or employee of the subject company;
• whether the Research Analyst has been engaged in market making activity for the subject company.

Such other disclosures in the Research Report or public appearance as specified by SEBI under any other regulations.

Contents of Research Report

The Research Analyst shall ensure that facts in the Research Reports are based on reliable information and shall define the terms used in making recommendations, and these terms shall be consistently used.

If the Research Analyst employs a rating system, it must clearly define the meaning of each such rating including the time horizon and benchmarks on which a rating is based.

If a Research Report contains either a rating or price target for subject company's securities and the Research Analyst has assigned a rating or price target to the securities for at least 1 year, such Research Report shall also provide the graph of daily closing price of such securities for the period assigned or for a 3-year period, whichever is shorter.

The Research Analyst shall disclose the registration status and details of financial interest in the subject company, if he makes public appearance.

The Research Report shall not be made available selectively to internal trading personnel or a particular client or class of clients in advance of other clients who are entitled to receive the Research Report.

In case of distribution of any third-party research report, the Research Analyst shall review such third-party research report for any untrue statement of material fact or any false or misleading information. The Research Analyst shall also disclose any material conflict of interest of such third party research provider or he shall provide a web address that directs a recipient to the relevant disclosures.

Maintenance of Records

The Research Analyst shall maintain the following records:

• Research Report duly signed and dated;
• Research recommendation provided;
• Rationale for arriving at research recommendation;
• Record of public appearance.

All records shall be maintained either in physical or electronic form and preserved for a minimum period of 5 years. Provided that where records are required to be duly signed and are maintained in electronic form, such records shall be digitally signed.

The Research Analyst shall conduct annual audit in respect of compliance with the SEBI Regulations from a member of Institute of Chartered Accountants of India or Institute of Company Secretaries of India.

Other Conditions

The Research Analyst shall be the compliance officer responsible for monitoring the compliance of the provisions of the Securities and Exchange Board of India Act, 1992, these SEBI Regulations and circulars issued by SEBI.

The Research Analyst shall ensure that his employees or partners, as may be applicable, comply with the certification and qualification requirements under regulation 7 at all times.

This Refund Policy is provided by AT RESEARCH & RISK MANAGERS (herein referred as "www.bsestocks.com" or the "Research Analyst") that apply to your access and use of the website www.bsestocks.com (herein referred as "bsestocks.com" or the "website") which is the property of the Research Analyst.

Fraudulent / Declined Transactions

AT RESEARCH & RISK MANAGERS reserves the right to recover the cost of service charges and lawyers' fees from persons using the Site fraudulently. AT RESEARCH & RISK MANAGERS also reserves the right to initiate legal proceedings against such persons for fraudulent use of the Site and any other unlawful acts or acts or omissions in breach of these terms and conditions.

Refund Eligibility

Refunds are only applicable to subscriptions purchased directly through AT Research & Risk Managers website. Refund requests must be made within 7 days of the initial subscription purchase. Refunds are not applicable for renewals, upgrades, or promotional discounts.

Contact Support

To request a refund, please contact our support team at aditya.thukral423@gmail.com with your order details and reason for the refund. Verification: Our support team will verify your request and may ask for additional information to process your refund.

Processing Time

Once your refund request is approved, we will process the refund within 5–7 working days. The refund will be credited to your original method of payment. Processing time for the credit to appear in your account may vary depending on your payment provider.

Conditions

We reserve the right to refuse a refund if the request is made after the 7-day period or if the subscription has been significantly used or tampered with. In the case of any fraudulent activities or misuse of our services, refunds will not be provided, and the account may be terminated.

These Terms & Conditions are the same as the SEBI RA Policy and form the binding agreement between the Research Analyst and the Client. Both documents are published in identical form per SEBI RA Regulations, 2014.

Refer to the SEBI RA Policy section above for the complete Terms of Service, including: Definitions · Assent & Acceptance · Availing the Research Services · Obligations on RA · Client Information & KYC · Standard Terms of Service · Consideration & Payment · Risk Factors · Conflict of Interest · Termination & Refund · Grievance Redressal · Mandatory Notice · Most Important Terms and Conditions (MITC) · Optional Centralised Fee Collection Mechanism · Use of AI Tools · Client-Level Segregation · Model Portfolio · Jurisdiction, Venue & Governing Law · Amendments · Indemnification · Suspension & Termination.

By utilizing the Research Services, you confirm that you have read and understood these Terms of Service and agree to adhere to them.

Section 1 – What do we do with your information?

When you purchase something from our platform, as part of the buying and selling process, we collect the personal information you give us such as your name, address and email address.

When you browse our platform, we also automatically receive your computer's internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system. Email marketing (if applicable): With your permission, we may send you emails about our platform, new products and other updates.

Section 2 – Consent

How do you get my consent?

When you provide us with personal information to complete a transaction, verify your credit card, or place an order, we imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at aditya.thukral423@gmail.com and 9066795009.

Section 3 – Disclosure

We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.

Section 4 – Payment

We do not use any payment gateway for processing payments. We accept UPI payments and direct transfers to our bank account only.

Section 5 – Third-Party Services

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

Once you leave our platform's website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website's Terms of Service.

Links

When you click on links on our platform, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

Section 6 – Security

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

Section 7 – Cookies

We use cookies to maintain session of your user. It is not used to personally identify you on other websites.

Section 8 – Age of Consent

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

Section 9 – Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. The changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our platform is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.

Questions and Contact Information

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at aditya.thukral423@gmail.com and 9066795009.