Independent research,
clear decisions.

These are the Most Important Terms & Conditions (MITC) based on the SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 dated February 17, 2025.

1. The terms and conditions and the consent thereon are for the research services provided by the RA and RA cannot execute/ carry out any trade (purchase/ sell transaction) on behalf of the client. Thus, you are advised not to permit RA to execute any trade on your behalf.
2. The fee charged by RA to the client will be subject to the maximum of amount prescribed by SEBI/ Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for Individual and HUF Clients).
   1. The current fee limit is Rs 1,51,000/- per annum per family of client for all research services of the RA.
   2. The fee limit does not include statutory charges.
   3. The fee limits do not apply to a non-individual client / accredited investor.
3. RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one quarter. In case of pre-mature termination of the RA services by either the client or the RA, the client shall be entitled to seek refund of proportionate fees only for unexpired period.
4. Fees to RA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognized RAASB).
5. The RA is required to abide by the applicable regulations/ circulars/ directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.
6. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the RA.
7. The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA’s research services. All opinions, projections, and 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.
9. Any reliance placed on the research report provided by the RA shall be as per the client’s own judgement and assessment of the conclusions contained in the research report.
10. The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
11. For any grievances,
    1. Step 1: the client should first contact the RA using the details on its website or following contact details: Neeraj Vasudevan, Part-time SEBI Registered Research Analyst — [email protected], +91 96333 68806 (see the Escalation Matrix below).
    2. Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through SEBI’s SCORES platform at scores.sebi.gov.in
    3. Step 3: The client may also consider the Online Dispute Resolution (ODR) through the Smart ODR portal at smartodr.in
12. Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.
13. The RA shall never ask for the client’s login credentials and OTPs for the client’s Trading Account, Demat Account and Bank Account. Never share such information with anyone including RA.

Annexure A — Investor Charter in respect of Research Analysts (RAs).

1. 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.

2. 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.

3. 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.

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

Investor can lodge complaint/grievance against the Research Analyst in the following ways:

1. Mode of filing the complaint with the research analystIn 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.
2. Mode of filing the complaint on SCORES or with RAASBSCORES 2.0 (a web based centralized grievance redressal system of SEBI) — scores.sebi.gov.in. Two level review for complaint/grievance against a Research Analyst: first review done by the designated body (RAASB); second review done by SEBI. An investor may also email the designated email ID of RAASB.
3. SMART ODRIf 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 the SMART ODR platform for its resolution through online conciliation or arbitration.

With regard to physical complaints, investors may send their complaints to:

5. 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 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 in accordance with agreed terms
• Right to receive clear guidance and caution notice for complex/high-risk products
• Additional Rights to vulnerable consumers
• Right to accessible services even if differently abled
• Right to provide feedback
• Right against coercive, unfair and one-sided clauses

6. Expectations from the investors (Responsibilities of investors)

1. About the Research Analyst

Mr. Neeraj Vasudevan is a Part-time SEBI registered Research Analyst having his registered office at No. 62, Anizham, Aiswarya Nagar, East Vennakkara, Nurani P.O, Palakkad, Kerala – 678004. He was registered with SEBI as an Individual vide Registration number INH000022534 with effect from 06 August 2025, pursuant to which he provides Research Analyst services to his clients.

2. Qualifications and experience

He holds the NISM Series XV — Research Analyst certification, as required under the SEBI (Research Analysts) Regulations, 2014. add qualifications / experience

3. Details of business activities

He provides independent research recommendations on equity securities, covering both short-term and long-term ideas. Short-term ideas are based on price trend and technical levels; long-term ideas are based on business quality, earnings growth and valuation. Each recommendation is communicated with a defined entry, stop-loss and target.

4. Disciplinary history

There are no outstanding litigations and no disciplinary history against him. No penalties or directions have been issued by SEBI under the SEBI Act or the Regulations made thereunder, nor by any other regulatory authority. confirm

5. Terms and conditions on which the research report is issued

He has exercised due diligence in checking the correctness and authenticity of the information contained herein, so far as it relates to current and historical information, but does not guarantee its accuracy or completeness. The opinions expressed are based on his current research as of the date appearing in the material and may be subject to change from time to time without notice.

He does not accept any liability arising from the use of this document or the information contained herein. The recipients of this material should rely on their own judgement and take their own professional advice before acting on this information.

6. Financial interest

He or his associates, including relatives — (a) do not hold any financial interest in the subject Company; (b) do not have any actual or beneficial ownership of more than 1% in the subject Company; (c) do not have any other material conflict of interest. Where any such interest exists at the time of publication, it is disclosed in the research report itself.

7 – 10. Associates, compensation and market making

• He or his associates are not affiliated with any other intermediaries, and have not received any brokerage or commission from any third party.
• He or his associates have not received any compensation from the Company covered by the Research Analyst during the past twelve months.
• He or his associates have not managed or co-managed a public offering of securities of the Company during the past twelve months.
• He or his associates have not served as an officer, director or employee of the Company, and have not been engaged in market making activity for the Company.

11. Reliability of facts

He has ensured that the facts mentioned in the research report are taken from a reliable source and information. However, investors are advised to independently evaluate the market conditions and risks involved before making an investment decision.

12. Use of Artificial Intelligence

He may use Artificial Intelligence tools in the course of providing research services. The extent of any such use is disclosed to clients as required under the Investor Charter. The analysis, the judgement and the responsibility for every published recommendation remain his own.

Neeraj Vasudevan is registered with SEBI as an Individual Research Analyst vide Registration number INH000022534 with effect from 06 August 2025, pursuant to which he provides Research Analyst services to his clients.

• I am not affiliated with any other intermediaries, nor do I receive any brokerage or commission from any third party.
• SEBI has issued no penalties or directions under the SEBI Act, and no other regulatory body has done so.
• I do not recommend any stock broker or other intermediary to a client, nor do I receive any consideration by way of remuneration, compensation or in any other form whatsoever from a stock broker or another intermediary.
• Investment in equity shares has its own risks. Sincere efforts have been made to present the right investment perspective. The information contained herein is based on analysis and on sources that I consider reliable. I, however, do not vouch for the consistency or the completeness thereof. This material is for personal information and I am not responsible for any loss incurred due to it.
• I do not provide any promise or assurance of a favourable view for a particular industry, sector or business group in any manner. The investor is requested to take into consideration all the risk factors including their financial condition and suitability to risk-return profile before investing.
• I or any other person related to me might be holding positions in the stocks recommended. Any such position is disclosed in the research report.
• Research recommendations are provided to all my clients who are entitled to receive research reports. Any client, any third party or anyone else has no right to forward or share my calls, reports or any information provided by me to or with anyone, through any medium. If found so, serious legal action can be taken.
• If a client wants an opinion on a specific position, such suggestion or view shall under any circumstances be considered an opinion and not advice. I am not liable for any losses whatsoever the client may incur in accepting this opinion.
• I do not have any association in any manner with any issuer of products or securities; this ensures that there are no actual or potential conflicts of interest, and that objectivity and independence in carrying on research services is not compromised.
• Stock trading is inherently risky, and you agree to assume complete and full responsibility for the outcomes of all trading decisions that you make.
• You, and not I, assume the entire cost and risk of any trading you choose to undertake. You are solely responsible for making your own investment decisions.
• Everything posted on social media is for education and illustration purposes and should not be counted as a recommendation or investment advice.

Language of this website

This website is written and published in English. A language option is provided in the header which uses an automated machine-translation service to display the page in other Indian languages, offered purely as a reading convenience.

The Research Analyst is committed to providing prompt, fair and transparent grievance redressal to all clients.

1. Contact the Research Analyst

If you are not satisfied with the services and wish to lodge a complaint, you may communicate your grievance by telephone or email. Every effort shall be made to acknowledge and resolve your grievance promptly.

Phone: +91 96333 68806  ·  Email: [email protected]

The Research Analyst shall endeavour to resolve the grievance within 7 business working days from the date of receipt, or within such timeline as may be prescribed by SEBI from time to time.

2. Escalation to the Research Analyst

If the grievance remains unresolved within the above timeline, escalate directly to:

Name

Neeraj Vasudevan

Designation

Research Analyst, Principal Officer & Compliance Officer

Address

No. 62, Anizham, Aiswarya Nagar, East Vennakkara, Nurani P.O, Palakkad, Kerala – 678004

Email

[email protected]

Phone

+91 96333 68806

The Research Analyst shall personally review the grievance and make every effort to resolve it in a fair, transparent and timely manner. In any case, all grievances shall be resolved within 21 calendar days from the date of receipt.

3. Complaint through SCORES

If your grievance remains unresolved, lodge your complaint through the SEBI Complaints Redress System (SCORES 2.0) at scores.sebi.gov.in. Two-level review mechanism — first level: RAASB; second level: SEBI.

4. Online Dispute Resolution (SMART ODR)

If you are not satisfied with the resolution provided through the above mechanism, you may initiate dispute resolution through the SMART Online Dispute Resolution platform at smartodr.in.

5. Physical complaint to SEBI

Office of Investor Assistance and Education, Securities and Exchange Board of India (SEBI), SEBI Bhavan, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (East), Mumbai – 400051.

If you have a grievance, you can reach out for assistance using the contacts below, before filing a complaint with SEBI.

Grievances are aimed to be resolved within 21 days from the date of receipt. If not resolved within this timeframe, escalate to SEBI’s SCORES platform (scores.sebi.gov.in) and thereafter the Online Dispute Resolution portal (smartodr.in).

Complaint register for Research Analyst INH000022534, disclosed in the format prescribed under the SEBI Master Circular (Investor Charter — Annexure B). All complaints, including SCORES complaints, are disclosed and updated on this website by the 7th of the succeeding month. RA to confirm & maintain monthly

A. Data for the month ending 30 September 2026

Registration was granted with effect from 06 August 2025. The figures below are the position as at the end of the reporting month.

Number of complaints received during the month against the Research Analyst due to impersonation by some other entity: 0.

* Inclusive of complaints of previous months resolved in the current month.   # Inclusive of complaints pending as on the last day of the month.   ^ Average resolution time is the sum of time taken to resolve each complaint in days, divided by the total complaints resolved in the month.

B. Trend of monthly disposal of complaints

Maintained from the month of registration (August 2025). Last updated for the month ending 30 September 2026.

C. Trend of annual disposal of complaints

Maintained from the year of registration (FY 2025-26).

Head Office

Securities and Exchange Board of India, SEBI Bhavan BKC, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (East), Mumbai – 400051, Maharashtra.
Telephone: +91 22 2644 9000 / +91 22 4045 9000

Regional office for this Research Analyst

The registered office of the Research Analyst is at Palakkad, Kerala, which falls within the jurisdiction of SEBI’s Southern Regional Office, Chennai, with the Kochi Local Office covering the State of Kerala.

SEBI Southern Regional Office: 7th Floor, 756-L, Anna Salai, Chennai – 600002, Tamil Nadu.
Telephone: +91 44 2888 0222 / +91 44 2852 6686  ·  Email: [email protected]

SEBI Kochi Local Office: 6th Floor, Finance Tower, Kaloor, Kochi – 682017, Kerala.

Office of Investor Assistance and Education

Physical complaints may be sent to the Office of Investor Assistance and Education, SEBI, at the head office address given above.

Toll-free investor helpline: 1800 22 7575. SEBI website: sebi.gov.in. Addresses and numbers here are as published by SEBI at sebi.gov.in/contact-us, which carries the complete and current list of SEBI’s regional and local offices.

Disclosure with respect to the annual compliance audit requirement under Regulation 25(3) of the SEBI (Research Analysts) Regulations, 2014. Annual audits are completed within the prescribed timeline and submitted to SEBI.

Audit reports are published here once each annual compliance audit is completed.

Neeraj Vasudevan, Part-time SEBI Registered Research Analyst (INH000022534), is committed to ensuring that this website is accessible to everyone, including people with disabilities, those using assistive technologies, and older users.

Our commitment

We aim to meet the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA published by the World Wide Web Consortium (W3C).

Accessibility features

• Keyboard-accessible navigation, menus, accordions and forms, with a visible focus indicator and a “skip to main content” link.
• Semantic HTML, a logical heading structure, ARIA labels, and data tables with row and column headers.
• Colour contrast that meets the AA thresholds for body text, headings and interface controls.
• Text that can be resized without loss of content or function, and layouts that reflow on phones, tablets and large displays.
• Respect for the operating system’s “reduced motion” preference, and content that remains readable with JavaScript disabled.
• Wide compliance tables scroll within their own region rather than forcing the page sideways.
• An accessibility toolbar, reachable from the button at the bottom-left of every screen, offering text resizing, read-aloud, high-contrast and inverted modes, a readable font, link and heading highlighting, increased spacing, a larger cursor, a reading guide and reading mask, and an option to stop motion.
• A light and a dark theme, following your device setting by default, with a manual switch in the header.

Assessment

This website was developed and assessed against WCAG 2.2 Level AA by the development team (Arihant Intellect), using a combination of automated testing (axe-core) and manual checks covering keyboard-only navigation, visible focus order, colour-contrast measurement, reflow, text resize and accessible names. This is a developer-led, best-estimate assessment and a point-in-time review — it is not a formal WCAG certification by an independent certifying body.

Ongoing commitment

Accessibility is an ongoing commitment. If you encounter any accessibility barrier while using this website, please contact us using the details below and we will make reasonable efforts to provide the required information or assistance in an accessible format.

Feedback and contact

Name

Neeraj Vasudevan

Designation

Part-time SEBI Registered Research Analyst (INH000022534)

Email

[email protected]

Phone

+91 96333 68806

Escalation