Smarter Investing Starts With Trusted Research

Disclosures & Conflict of Interest Statement:

• A.1 About the Research Analyst:

SUMEET JAIN is an Individual SEBI Registered Research Analyst having his registered/correspondence office at 6-E-235, Kudi Bhagatasani Housing Board, Jodhpur – 342005, Rajasthan, India. SUMEET JAIN is registered with SEBI under Registration No. INH000029519 (Validity: August 10, 2026 – Perpetual), and is enlisted with BSE Limited (RAASB), pursuant to which research analyst services are provided to clients.

• A.2 Qualification and Profile:

SUMEET JAIN holds the professional qualification(s) and NISM certification required under Regulation 7 of the SEBI (Research Analysts) Regulations, 2014, and provides independent research recommendations on securities based on fundamental and/or technical analysis of publicly available information.

• A.3 Details of Business Activities:

SUMEET JAIN offers research reports, analysis, and investment recommendations in respect of securities, based on his own independent research methodology, and does not undertake merchant banking, investment banking, underwriting, portfolio management, or brokerage/execution services.

• A.4 Disciplinary History:

There is no material outstanding litigation, regulatory action, administrative warning, monetary penalty, or disciplinary history against SUMEET JAIN by SEBI, RAASB, or any other regulatory authority, other than as may be specifically and separately disclosed to the Client in writing.

• A.5 Terms on which Research Reports are Issued:

The RA exercises reasonable diligence in verifying the accuracy of information contained in research reports, based on publicly available data and sources believed to be reliable. However, the accuracy or completeness of such information is not, and cannot be, guaranteed. Opinions expressed reflect the RA's judgement as of the date of publication and are subject to change without notice. The RA accepts no liability for any loss arising from reliance on a research report, save as provided in Clause 18 (Limitation of Liability) of this Agreement.

• A.6 Ownership and Material Conflict of Interest:

The RA, and to the best of his knowledge his associates/relatives, do not hold any material financial interest in a subject company covered in a research report, except as specifically disclosed in the relevant research report.

• The RA, and to the best of his knowledge his associates/relatives, do not have actual or beneficial ownership of one per cent (1%) or more of the securities of a subject company as of the end of the month immediately preceding the date of publication of the relevant research report.
• The RA does not have any other material conflict of interest at the time of publication of a research report or at the time of a public appearance, except as specifically disclosed.
• A.7 Affiliations and Third-Party Receipts:

The RA is not affiliated with any other SEBI-registered intermediary in a manner that would compromise the independence of his research, and has not received any brokerage, commission, or fee incentive from any third party in connection with a research recommendation.

• A.8 Compensation Disclosures:

The RA has not received any compensation from a subject company covered in a research report during the preceding twelve (12) months for research analyst services, investment banking, merchant banking, or brokerage services, except as specifically disclosed in the relevant research report.

• A.9 Public Offering and Market-Making Disclosures:

The RA has not managed or co-managed a public offering of securities of any subject company in the preceding twelve (12) months, and does not engage in market-making activity in respect of any subject company.

• A.10 Officer/Director Roles:

The RA has not served as an officer, director, or employee of any subject company covered in his research reports.

• A.11 Use of Artificial Intelligence:

Where AI-based tools are used by the RA in a supportive/analytical capacity (e.g., data collation or formatting) in preparing a research report, this fact is disclosed in the relevant report; the final view, rating, and recommendation remain the RA's own independent professional judgement.

Investor Charter (Research Analyst):

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).

A 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.

B Business Transacted by the Research Analyst:

• Publishing research reports based on the RA's own research activities.
• Providing an independent, unbiased view on securities.
• Offering unbiased recommendations, disclosing financial interests, if any, in recommended securities.
• Providing research recommendations based on analysis of publicly available information and known observations.
• Conducting an annual audit as required under the RA Regulations.
• Ensuring all advertisements adhere to the Advertisement Code for Research Analysts.
• Maintaining records of client interactions, including with prospective clients, relating to research services.

C Services Provided to Investors:

• On-boarding of clients following SEBI/KRA KYC verification guidelines.
• Sharing of terms and conditions of research services, including the MITC.
• Delivering research reports and recommendations to clients without discrimination.
• Disclosing all material conflicts of interest prior to, or along with, research recommendations.
• Disclosing the extent of use of Artificial Intelligence tools in providing research services.
• Maintaining confidentiality of a research report until it is made available in the public domain.
• Respecting the data-privacy rights of clients.
• Providing clear guidance and adequate caution notice when recommending complex or high-risk financial products/services.
• Addressing client queries and grievances within the regulatory timeline referred to below.

D Rights of Investors:

• Right to receive independent, unbiased research reports and recommendations.
• Right to transparent fee details within SEBI-mandated caps (presently Rs. 1,51,000/- per annum per family of client for Individual/HUF clients).
• Right to complete disclosure regarding conflicts of interest, financial holdings, or affiliations of the RA.
• Right to Privacy and Confidentiality, and to Fair and Equitable Treatment.
• Right to Initial and Continuing Disclosure, and to Fair and True Advertisement.
• Right to be informed of the timelines for each service, and to receive clear guidance for complex/high-risk products.
• Right to lodge grievances with the RA, and to escalate to SEBI SCORES (www.scores.sebi.gov.in) or the SMART ODR portal (https://smartodr.in) if unresolved within the timelines specified below.
• Right to Exit from the service in accordance with the agreed terms and conditions.

E Do's and Don'ts for Investors:

Do's

• Always deal with a SEBI-registered Research Analyst; verify the registration number on the SEBI website.
• Pay fees only through approved banking channels (cheque, NEFT/RTGS, UPI, CeFCoM); never pay in cash.
• Carefully read this Agreement, the MITC, and the Investor Charter before subscribing.
• Keep contact details (e-mail ID and mobile number) updated with the RA at all times.
• Evaluate your risk tolerance and investment objectives before acting on any research recommendation.

Don'ts

• Do not share trading, demat, or bank login credentials, passwords, or OTPs with the RA.
• Do not permit the RA to execute any buy/sell trade on your behalf – Research Analysts cannot execute trades.
• Do not expect, or fall for, any promise of assured, guaranteed, or fixed returns.
• Do not make cash payments for research services.

F Grievance Redressal Mechanism and Timelines:

• Step 1: The Client should first contact the RA using the details above, or via the website (https://sumeetjainresearch.com/) or e-mail (sam.sumeet25@gmail.com).
• Step 2: The RA shall resolve the grievance not later than twenty-one (21) days from receipt. If the resolution is unsatisfactory, or not received within twenty-one (21) days, the Client may lodge a grievance through SEBI's SCORES 2.0 platform at www.scores.sebi.gov.in.
• Step 3: The Client may also opt for Online Dispute Resolution through the SMART ODR portal at https://smartodr.in.

Monthly complaint data (received, resolved, and pending, with ageing) is published on the RA's website in the SEBI-prescribed format, latest by the 7th day of the succeeding month, in accordance with Annexure B to SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 dated June 2, 2025.

Refund Policy:

SUMEET JAIN (Trade Name: Sumeet Jain 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 standardised 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: (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 sam.sumeet25@gmail.com within seven (7) days of the occurrence giving rise to the claim, enclosing invoice details and proof of the transaction (e.g., 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 (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 (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 (https://scores.sebi.gov.in) or the SMART ODR portal (https://smartodr.in).

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.