Terms & Conditions of Research Analyst Services

TERMS AND CONDITIONS OF RESEARCH ANALYST SERVICES

Wryght Research & Capital Private Limited (“Research Analyst” or ‘RA”), is SEBI Registered Research Analyst bearing Registration No. INH000017295, enlisted with Research Analyst Administration and Supervisory Body (RAASB)- BSE Limited having its Enlistment No. as 6272 (detailed in Schedule 1).

Pursuant to SEBI (Research Analysts) Regulations, 2014, applicable Guidelines, Master Circular and circulars issued thereunder, RA is hereby disclosing below Terms & Conditions and Undertakings:

This document outlines the mandatory terms and conditions governing the relationship between the client (detailed in Schedule 1) and the Research Analyst (RA). By subscribing to or availing of research services provided by the RA, the client confirms their acceptance of these terms and conditions at their sole discretion.

Definitions

For the purpose of these Terms, the following words and phrases shall have the meaning assigned to them as set out below unless the context indicates otherwise.

“Business Days” means any day in which banks are open for business in Mumbai, India.

“Service(s)” means the services provided by the RA which include provision of research content, research data, model portfolios, and research reports, prepared in compliance with the applicable provisions of the RA Regulations and circulars/guidance issued thereunder, for which Clients are paying a fee to the RA.

“Client” shall mean any person who avails Services as per the terms contained herein. The term Client shall also include any person who is authorized to avail of the Services on behalf of the Client with either full rights or limited rights.

”Digital Medium" means and includes mobile applications, web applications and various other online applications including any third-party platforms engaged by the RA for providing the Services.

Eligibility

Use of the Services shall be available only to persons who can enter into legally binding contracts under Indian Contract Act, 1872, where applicable. Persons who are "incompetent to contract" within the meaning of the Indian Contract Act, 1872 including minors, un-discharged insolvents, etc. shall not be eligible to use the Services. The Client represents and warrants that he/she is at least 18 years old and all information submitted is true, accurate and complete while registering with the RA to avail the Services. If the Client is a minor i.e. under the age of 18 years, he/she/it shall not register as a Client with the RA to avail the Services.

Acceptance of Research Services

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

Obligations on RA and Client

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

Client Information and KYC Requirements

The client agrees to provide complete and accurate information as required by the RA for Know Your Customer (KYC) compliance, including any details as mandated by SEBI or RAASB from time to time.

The RA will collect, store, upload and verify KYC records in accordance with SEBI guidelines through a KYC Registration Agency (KRA) as specified from time to time.

Standard Terms of Service

By subscribing to the research services, the client confirms the following:

“I/We have read and understood the terms and conditions applicable to a research analyst as defined under regulation 2(1)(u) of the SEBI (Research Analyst) Regulations, 2014, including the fee structure.”

“I/We are subscribing to the research services for our own benefits and consumption, and any reliance placed on the research report provided by research analyst shall be as per our own judgement and assessment of the conclusions contained in the research report.”

“I/We understand that –

Any investment made based on the recommendations in the research report are subject to market risk.

Recommendations in the research report 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”

By agreeing to render the research services, the RA declares the following:

It is duly registered with SEBI as an RA under the SEBI (Research Analysts) Regulations, 2014 and its registration details are –

Registration number- INH000017295

Registration date- Jul 03, 2024

It has registration and the qualifications required to render the research services as contemplated under the RA Regulations and the same are valid and subsisting;

The services provided do not conflict with or violate any applicable law or agreement.

The maximum fee charged by the RA is ₹1.51 lakhs per annum per family of clients.

Recommendations provided by the RA do not provide any assurance of returns.

Fees and Payment Terms

The client agrees to pay the fees for the research services as mutually agreed upon, along with applicable statutory charges. The Scope of service and fee details are enclosed as Annexure 1.

The subscription fees shall be paid in advance, provided that such advance shall be for the period allowed as per the prevailing regulations.

Fees shall be payable by way of direct credit to the designated bank account/s through channels like Net Banking/Debit Card/NEFT/ RTGS/ IMPS/ UPI/ eNACH mandate/ any other acceptable mode as per the RA regulations. Payment may also be processed though payment gateway services opted by RA from time to time. The fees shall not be accepted in cash.

An option of payment through SEBI authorised ‘Centralised Fee Collection Mechanism (CeFCoM) is available with every investor. If a client likes to opt for ‘Centralised Fee Collection Mechanism (CeFCoM)’, an email request for the same may be sent to RA for processing of the same.

Risk Factors

Investments in securities carry inherent market risks, including potential loss of capital.

Historical performance of recommendations is not indicative of future returns.

The client must independently assess the suitability of investment decisions based on the research reports provided.

Registration granted by SEBI/ BSE, and certification from NISM in no way guarantee performance of the RA (intermediary) or provide any assurance of returns to the clients.

Conflict of Interest

The RA shall comply with all the applicable regulations/ circulars/ directions as specified by SEBI from time to time in relation to disclosure and mitigation of any actual or potential conflicts of interest.

Any actual or potential conflict of interest will be disclosed transparently to the client as and when identified. Disclosures with respect to material information of the RA are described in Annexure 2.

Access

The RA will endeavor to ensure that access to and availability of the Services remains uninterrupted and error free. However, access to the Website and/or Digital Medium from where Clients might be availing the Services may occasionally be suspended or restricted to allow for repairs, maintenance, or for the introduction of new facilities and Services and in such cases the RA shall not be liable for any disruption of any Services.

Provision of the Services

The RA shall not be liable for the Client acting on any recommendation which is set out as part of its Services, other than as expressly provided in any deliverable.

The RA does not engage in services such as profit sharing or representation that its Services guarantee a minimum return.

Investments in securities markets are subject to risks and each Client shall assess its own risk appetite and profile prior to relying on the Services of the RA for making investment decisions.

The RA does not include within the ambit of the Services execution of any trades, investment decisions and/or buy-sell orders for the Client. 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, the Client is advised not to permit RA to execute any trade on the Client’s behalf.

The RA shall render the Services on a best effort basis.

Investment Disclosures

The Services as provided by the RA shall not be construed to be solicitation of an investment. The decisions of the Client with respect to their investments shall be done based on their risk appetite and risk tolerance levels and the Services shall be utilized as one of the variables to make investment decisions. It is abundantly clarified by the RA that past returns are not indicative of guaranteed future returns and the Services rendered always remain subject to market risk.

The information as provided on the Website and/or Digital Medium, which includes index value, return numbers and rationale are for informational and illustration purposes only and are only provided by RA when the client requests for the same. These metrics shall not be relied upon by the Client in any form or manner and should not be considered as advertisement or solicitation. Any graphical representations, including charts, performance numbers etc. are calculated vide standard methodology and do not include the impact of transaction fee and other related costs, unless specifically mentioned.

The data used by the RA in the methodologies for calculations as stated above are obtained from third-party providers and such data is not authenticated, validated nor audited by the RA and the RA shall not be liable for any deficiencies with respect to such data and the Services provided basis the same.

Security

Subject to the provisions stated herein and as specified by the RA from time to time, the Client will not hold the RA liable in case of any improper/fraudulent/unauthorized/ duplicate/erroneous use of the Client’s mobile and/or the web-based access. The RA will also not be liable for any consequences connected with the use/ misuse of the Client's mobile/ email account by any third party. If any third parties gain access to the Services, the Client will be responsible and shall indemnify the RA against any liability, costs or damages arising out of such misuse / use by third parties based upon or relating to such access and use, or otherwise.

The Client shall be fully and solely liable for: (a) any unauthorized use of his mobile/ email account; and/or (b) all authorized transactions on his mobile/email account.

Use the Services at Your Own Risk

The RA reserves the right to refuse any Service to anyone for any reason at any time. The Client understands that the Client’s content and data may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices.

The Client agrees not to reproduce, duplicate, copy, distribute, sell, resell or exploit any portion of the Services, use of the Services, or access to the Services or any contact on the Website and/or Digital Medium through which the Service is provided, without prior express written permission from the RA.

Trademarks

The RA name, logo, the names of individual Service(s) and their logos are trademarks of the RA. The Client agrees not to display or use, in any manner, the RA trademarks, without the RA’s prior permission.

Disclaimer of Warranties

The Client expressly understands and agrees that the use of the Services is at their sole risk. The Services are provided on an as-is-and-as-available basis. The RA expressly disclaims all warranties of any kind, whether express or implied, including, but not limited to, the implied warranties of merchantability and fitness for a particular purpose. The RA makes no warranty that the Services will be uninterrupted, timely, secure, or error free. Use of any material downloaded or obtained through the use of the Services shall be at the Client’s own discretion and risk and they will be solely responsible for any damage to their computer system, mobile telephone, wireless device or data that results from the use of the Services or the download of any such material. The RA, its employees or representatives shall not create any warranty not expressly stated in the terms.

Termination of Services and Refunds

The Terms shall remain in force till terminated. If the Client is on an auto-renew plan, the terms and conditions of the arrangement and the Client’s consent thereon will remain in force until the subscription is canceled by the Client or the RA in accordance with these terms. This arrangement may be terminated by either Party by giving a 30 days prior written notice.

In the event that the Client breaches these Terms or in the event that any other Client or a third party reports violation of any of its rights as a result of the Client’s use of the Services, the RA reserves the right, to suspend or terminate such Client’s access to the Service with or without notice, and to exercise any other remedy available under the law.

The RA shall have the right to indefinitely suspend or block access to the Client’s account on the Website and/or Digital Medium and/or any other platform used by the Client to consume services offered by the RA and refuse to provide the Client access to the Website and/or Digital Medium if:

the Client engages in or is suspected of engaging in any illegal, fraudulent or abusive activity; or

the Client provides any information that is untrue, inaccurate, not current or incomplete in any respect or the RA has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, or not in accordance with these Terms

the Client is engaged in spreading mis-information, market rumors, unauthorized distribution of research/other services of RAs or any other such similar misconducts

the Client breaches any material term of this document

the Client is admitted into liquidation (except a voluntary liquidation for the purpose of reconstruction or amalgamation) or commits any act of bankruptcy or if a receiver is appointed in respect of any assets of the Client.

The RA reserves the right to suspend or terminate services in the event of suspension or cancellation of their SEBI registration.

In case of cancellation of SEBI Registration, RA shall refund the pro-rata fees for the remaining subscription period to the client on suspension or termination of services.

In case of suspension of certificate of registration for more than 60 (sixty) days, RA shall refund the pro-rata fees for the remaining subscription period to the client on suspension or termination of services.

Remaining subscription period shall be period from the effective date of cancellation/ suspension to end of the subscription period.

Pausing of Services by the Client

The Client may, if they so desire, choose to pause the receipt of the Services. In such a case, while the Services will continue to be rendered to the Client until the end of the period for which the fee has been paid (“Payment Period”), the payment will not be auto-debited at the end of the Payment Period, and the Services will be paused to be provided.

The Client may, subsequently, resume the Services at the same fees charged for the last Payment Period, subject to receipt of such fee amount within 7 days of opting to resume the Services. In case such payment is not received within the said 7 days, and the Client subsequently wishes to resume the Services, the Client shall not be entitled to resume the Services at the same fees charged for the last Payment Period and will have to resume such Services by paying a fee as may be applicable at the time of such resumption of Services. Notwithstanding anything else contained in this clause 19, in order to be eligible to resume the Services at the same fees charged for the last Payment Period, the Client shall have an active mandate at all times.

Indemnity

The Client shall keep the RA indemnified from and against any and all liability (including but not limited to liabilities, judgments, damages, losses, claims, costs and expenses,) or any other loss that may occur, arising from or relating to any claim, suit or proceeding brought against the RA by another Client/third party for reasons including, but not limited to (i) a breach, non-performance, non-compliance or inadequate performance by the Client of any of the terms, conditions, representations, obligations or warranties made by him/her/it; (ii) any acts, errors, misrepresentations, willful misconduct or negligence of the Client, or his employees, subcontractors and agents in performance of their obligations under these Terms.

Disclosure of Information

The RA may access, preserve and disclose any of Client’s information if required to do so by law, or if the RA believes in good faith that it is reasonably necessary to: (i) respond to claims asserted against the RA or to comply with the legal process, (ii) for fraud prevention, risk assessment, investigation, Client support, product development and debugging purposes, or (iii) protect the rights, property or safety of the RA, its Clients or members of the public.

The RA may further engage agents and / or third-party vendors/partners for carrying out the acts (to the extent permissible under applicable law) in relation to rendering its Services. The Client consents to the sharing of their information with such authorized agents and/or third party vendors/partners engaged by the RA from time to time.

Limitation of Liability

The Client acknowledges and agrees that, to the maximum extent permitted by law, the entire risk arising out of the Client’s access to and use of the Website and/or Digital Medium and/or Services, remains with the Client. The RA shall not be liable with respect to providing or delivering the Services for any incidental, special, exemplary or consequential damages, including lost profits, loss of data or loss of goodwill, service interruption, loss of monies pursuant to any of the Services, computer damage or system failure or the cost of substitute services, or in connection with these terms, as a result of the Client’s use of the Website and/or Digital Medium and/or Services, whether based on warranty, contract, tort (including negligence), product liability or any other legal theory, and whether or not the RA has been informed of the possibility of such damage, even if a limited remedy set forth herein is found to have failed of its essential purpose.

The liability of the RA towards the Client shall be limited to the fees as received by the RA for rendering Services to the Client, for a period of 6 preceding months from the date on which the claim in relation to actions of proven fraud, gross negligence, willful default in connection with discharge of duties of the RA.

Grievance Redressal and Dispute Resolution

Clients may escalate grievances related to deficiencies in services as mentioned below to the RA's designated person-

Non-receipt of research report, or

Missing pages or inability to download the entire report, or

Any other deficiency in the research services provided by RA

Contact details of designated person for escalation of grievances are as below-

Name- Siddhesh More

Email- siddhesh@wrightresearch.in

RA shall redress grievances of the client in a timely and transparent manner.

RA shall resolve grievances within seven business working days or as specified by SEBI under RA Regulations.

In case you are not satisfied with our response you can lodge your grievance with SEBI at https://scores.sebi.gov.in/ or you may also write to any of the offices of SEBI. SCORES may be accessed thorough SCORES mobile application as well, same can be downloaded from below link:

https://play.google.com/store/apps/details?id=com.ionicframework.sebi236330

Disputes between the RA and the client may be resolved through arbitration or any other modes or mechanism as specified by SEBI from time to time.

ODR Portal could be accessed, if unsatisfied with the response. Your attention is drawn to the SEBI circular no. SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131 dated July 31, 2023, on “Online Resolution of Disputes in the Indian Securities Market”. A common Online Dispute Resolution Portal (“ODR Portal”) which harnesses conciliation and online arbitration for resolution of disputes arising in the Indian Securities Market has been established. ODR Portal can be accessed via the following link - https://smartodr.in/

Mandatory Notices

Clients are advised and requested to familiarize themselves with SEBI’s guidelines, including the Do’s and Don’ts while dealing with RAs, as specified in SEBI’s Master Circular No. SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated May 21, 2024, or as updated by SEBI from time to time. Link to Master circular for reference - https://www.sebi.gov.in/sebi_data/attachdocs/may-2024/1716290553655.pdf

Investor Charter

In regards of SEBI circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 dated June 2, 2025, pertaining to the Revised Investor Charter Research Analysts (RAs), updated Investor Charter is attached herewith as Annexure 3.

Most Important Terms and Conditions (MITC)

These terms and conditions, and consent thereon are for the research services provided by the Research Analyst (RA) and RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client. Thus, the clients are advised not to permit RA to execute any trade on their behalf.

The fee charged by RA to the client will be subject to the maximum amount prescribed by SEBI/ Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for Individual and HUF Clients).

Note:

2.1. The current fee limit is Rs 1,51,000/- per annum per family of client for all research services of the RA.

2.2. The fee limit does not include statutory charges.

2.3. The fee limits do not apply to a non-individual client / accredited investor.

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 year. 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 an unexpired period.

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).

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.

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.

The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA’s research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of the research report.

Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the client’s own judgement and assessment of the conclusions contained in the research report.

The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.

For any grievances,

Step 1: The client should first contact the RA using the details on its website or following contact details:

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

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

Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.

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.

Revision of Fees Clause

The RA reserves the right to revise the fees charged for research services. Any such revision will be applicable prospectively and will be implemented strictly in accordance with the SEBI Master Circular No. HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026 for Research Analysts dated February 06, 2026. The implementation process, client communication, and notice periods are detailed in Annexure 1 (Process for Fee Revision), which forms an integral part of this agreement.

Usage of Artificial Intelligence (AI) for the purpose of providing Services to Clients

At Wright Research, we leverage cutting-edge Artificial Intelligence (AI) technologies to enhance the quality, accuracy, and efficiency of the services we offer to our clients. Our AI-driven systems are used for various functions, including but not limited to, data analysis, market trend predictions, risk management, and portfolio optimization. The AI models analyze vast datasets to provide personalized, data-backed recommendations that are aligned with each client’s financial goals.

All AI implementations are designed and supervised by experienced professionals to ensure the highest standards of accuracy and compliance with relevant regulations. While AI enhances our decision-making process, it does not replace the human oversight that ensures the strategies we deliver meet our clients’ expectations. Our technology acts as a tool to assist in making informed investment decisions based on objective, data-driven insights.

We ensure the confidentiality, integrity, and security of client data in all AI processes. Additionally, we regularly audit and update our AI systems to ensure they remain compliant with evolving industry regulations and best practices. Our clients can trust that our AI technologies are applied ethically and responsibly to provide the best possible outcomes for their investments.

Data Sharing Consent:

The Client hereby acknowledges and consents that the Research Analyst (RA) may share, transfer, or disclose any non-public personal information, Know Your Customer (KYC) documentation, financial records, or transactional data provided by or collected on behalf of the Client to its distinct operating divisions functioning under a separate Portfolio Management Services (PMS) license ("Permitted Recipient").

Purpose & Scope:

Such sharing shall be strictly limited to the extent reasonably necessary for internal operations, client onboarding, regulatory compliance, portfolio administrative support, or offering cross-functional financial services.

Chinese Wall Integrity:

In strict adherence to SEBI rules regarding the mitigation of conflicts of interest, the RA and the Permitted Recipient shall maintain appropriate technical, physical, and operational Chinese Walls to prevent the misuse of non-public research data, proprietary trade insights, or insider information across distinct licensing boundaries.

Confidentiality & Data Protection:

The RA agrees that any Permitted Recipient receiving such information shall be bound by confidentiality obligations no less restrictive than those contained within this Agreement and shall process such data in strict compliance with applicable data protection and regulatory privacy laws.

Client Opt-out mechanism:

The Client reserves the right to withdraw or restrict consent for data sharing across distinct PMS entities at any time, subject to the following terms:

Notice: The Client must submit a written opt-out request via registered email (as per the format specified in Annexure 4) to the designated compliance officer at info@wrightresearch.in / hello@wrightresearch.in / compliance@wrightresearch.in

Effectiveness: The RA shall process and give effect to such opt-out requests within 14 business days of receipt.

Exceptions: Opting out shall not apply to disclosures mandated by SEBI, statutory authorities, tax compliance, or legally required disclosures where data sharing is necessary to comply with applicable laws.

Acknowledgment

By availing of the research services, the client confirms their consent to the above terms and conditions and acknowledges their understanding of the rights and obligations outlined herein.

Schedule 1

DETAILS OF RESEARCH ANALYST

Full Name

Wryght Research & Capital Private Limited

Entity Type

Individual/ Partnership Firm/ LLP/ Company

Registration No.:

INH000017295

BSE Enlistment No.:

6272

Trade Name:

Wryght Research & Capital Private Limited

Residential/ Registered Address:

103, Shagun Vatika, Prag Narayan Road, LUCKNOW, UTTAR PRADESH, 226001

Contact No.:

9619303157

Email No.:

siddhesh@wrightresearch.in

CIN:

U67100UP2019PTC123244

Compliance Officer:

Siddhesh More, siddhesh@wrightresearch.in, 9619303157

Grievance Officer:

Siddhesh More, siddhesh@wrightresearch.in, 9619303157

Annexure 1: Scope of Service and Fee Schedule

Scope of Service

The Research Analyst agrees to render research analysis, model portfolio evaluations, and recommendation services (collectively, "Services") to the Client. The scope of the Services shall be restricted to equity securities, mutual fund schemes, and Exchange Traded Funds (ETFs) listed on recognized stock exchanges in India that form part of the Client's portfolio and are explicitly submitted for analysis

The research and recommendations follow a model portfolio approach, wherein the portfolio composition is reviewed at a fixed frequency based on various quantitative, technical or fundamental factors to determine the portfolio composition for the next period.

The research and recommendation services rendered by the Research Analyst are merely recommendatory and non-binding in nature. The Research Analyst shall use its best judgement and efforts in rendering the research and recommendations to the Client, but shall not assume any management responsibilities in connection with the services and shall not be responsible for the use or implementation of the research and recommendations provided under this Agreement.

The Research Analyst shall not execute or carry out any trade (purchase/sell transaction) on behalf of the Client, and shall not manage any funds or securities on behalf of the Client. All investment decisions shall be taken by the Client at its sole discretion, based on its own evaluation and judgement of the research and recommendations provided.

The equity component of the model portfolio shall be subject to short-term or long-term capital gains tax depending on the holding period of the security. The tax liability on the ETF component of the portfolio, if any, shall depend on the underlying asset class of the ETF. The applicable tax rates may be revised from time to time by the Government of India.

Validity of Service-

The research services shall be valid for the subscription period opted for and paid by the Client, commencing from the date on which the Client’s subscription payment is processed.

Where the Client has opted for an auto-renewal plan, the subscription shall automatically renew at the end of each subscription period and shall remain in force until cancelled by the Client or the Research Analyst in accordance with the terms of this Agreement.

The Client may cancel the subscription at any time by writing to the Research Analyst at info@wrightresearch.in, following which the subscription shall not renew for any subsequent period.

Fee Schedule-

The Client shall pay the Research Analyst the fees for the research services as set out in the table below, along with applicable statutory charges (including GST):

Plan / Service

Subscription Period

Fee (₹) (excl. GST)

Generic Analysis of Client’s Stocks / Portfolio

Ad-hoc basis by the Client

Free

Detailed Analysis of Client’s Stocks / Portfolio

Monthly

1,000

The maximum fee charged by the Research Analyst shall not exceed ₹1,51,000 (Rupees One Lakh Fifty-One Thousand) per annum per family of clients across all research services offered by the Research Analyst, as prescribed by SEBI / RAASB from time to time. The said fee limit is applicable only to Individual and HUF clients, does not include statutory charges, and does not apply to non-individual clients or accredited investors.

The subscription fees shall be paid in advance, provided that such advance shall be for the period allowed as per the prevailing regulations.

Fees shall be payable only through banking channels such as Net Banking, Debit Card, NEFT, RTGS, IMPS, UPI, eNACH mandate or any other mode permitted under the RA Regulations, or through a payment gateway opted by the Research Analyst, or optionally through the SEBI-recognised Centralised Fee Collection Mechanism (CeFCoM) managed by BSE Limited. The fees shall not be accepted in cash.

The CeFCoM is a transparent payment mechanism, which is being implemented in a phased manner depending on whether a research analyst has / does not have an end-to-end digital process for client on-boarding, delivery of services to clients, payments of fees and other related processes. CeFCoM intends to inter alia provide the following advantages: Provides an additional recognition to a research analyst of being a registered intermediary; Multiple modes for collection of fees from clients; Intimation to a research analyst regarding when a client payment falls due; Facility to schedule payment of fees as per convenience of the research analyst and its clients; Master data of clients and their fee payment status; and Facility to track payment of fees by a client.

In the event of pre-mature termination of the research services by either the Client or the Research Analyst, the Client shall be entitled to a refund of the proportionate fees for the unexpired subscription period.

Process of Fee Revision-

1. Advance Notice Period

The RA must provide prior written notice of at least (30) days to all existing clients before implementing any fee increase.

2. Applicability of Revised Fees

Existing Clients: The increased fee shall only be applied upon the expiry of the client's current subscription or at the time of renewal. Fees will not be revised mid-subscription without mutual written consent.

New Clients: New subscribers will be charged the newly published rate.

3. Regulatory Cap & Advance Payments

For individual and HUF clients, the revised annual fee will strictly adhere to the limits mandated by SEBI / RAASB. Furthermore, the RA shall not collect advance fees exceeding the period permitted by regulations (presently up to one year, subject to client agreement).

4. Transparency and Disclosure

The revised fee structure shall be updated on the RA’s official website, updated in the Most Important Terms and Conditions (MITC), and reflected in all marketing and sales materials prior to implementation.

5. Client Consent and Renewal

Clients shall be deemed to have accepted the revised fee structure if they explicitly renew their subscription or pay the invoice for the subsequent billing cycle at the revised rate. Clients who do not agree to the revision may opt to terminate the research services without any breakage or penalty fees.

Annexure 2: Disclosures

For the purpose of this Annexure, Wryght Research & Capital Private Limited is hereinafter referred as “Research Entity”

Descriptions about “Research Entity”

History, Present business and Background

Research Entity is registered with SEBI as Research Analyst with Registration No. INH000017295, BSE Enlistment No: 6272. The firm got its registration on Jul 03, 2024 and is engaged in research and recommendation Services.

The focus of the Research entity is to provide research and recommendations services to the clients. Analyst aligns its interests with those of the client and seeks to provide the best suited services.

Terms and conditions of Research and Recommendation Services

Terms and conditions of Research and Recommendation Services are detailed in the terms and condition document. Please refer to the same for details.

Disciplinary history

No penalties have been issued by SEBI under the SEBI Act or Regulations made thereunder against the Research entity, Research Analyst or its associates or relatives.

There are no pending material litigations or legal proceedings, findings of inspections or investigations for which action has been taken or initiated by any regulatory authority against the Research entity, Research Analyst or its associates or relatives.

Details of its associates

No Associates

Disclosures with respect to Research and Recommendations Services

Research entity or Research Analyst or his associate or his relative may have financial interest or actual / beneficial ownership of one per cent or more in the securities recommended in its personal portfolio at the end of the month immediately preceding the date of publication of the research report or date of the public appearance. Details of the same may be referred through the disclosures made at the time of advice.

There are no actual or potential conflicts of interest arising from any connection of Research entity or Research Analyst or his associate or his relative to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of Research Analyst services. Such conflict of interest shall be disclosed to the client as and when they arise.

Research analyst or research entity or its associates or relatives, may have actual/beneficial ownership of one per cent 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 or research recommendation. Details of the same may be referred through the disclosures made at the time of advice.

Research entity or Research analyst or its associate or relatives has no connection or association of any sort with any issuer of products/ securities recommended herein.

Research analyst or his associate or his relative has no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of research and recommendations services.

Research entity or Research analyst or its associates has not received any kind of remuneration or consideration form the products/ securities recommended herein.

Research entity or Research analyst or its associates have not received any compensation from the subject company in past 12 months.

Research entity or Research analyst or its associates have not managed or co-managed the public offering of Subject Company in past 12 months.

Research entity or Research analyst or its associates have not received any compensation for investment banking or merchant banking of brokerage services from the subject company in past 12 months.

Research entity or Research analyst or its associates have received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past twelve months

Research entity or Research analyst or its associates have not received any compensation or other benefits from the subject company or third party in connection with the research report or research recommendations.

Research entity or Research analyst or its associates have not received any compensation for products or services from the subject company in past 12 months.

The subject company is or was not a client of Research entity or Research analyst or its associates during twelve months preceding the date of distribution of the research report and recommendation services provided.

Research Analysts or its associates has not served as an officer, director or employee of the subject company.

Research Analysts has not been engaged in market making activity of the subject company

The research analyst is using artificial intelligence tools for providing the research services.

Disclosures with respect to Portfolio Management Services

Wryght Research & Capital Pvt Ltd is registered with SEBI as a Portfolio Manager with INP000007979 as the SEBI registration number (valid from Apr 03, 2023, perpetual). The registered office address of Wryght Research & Capital Pvt Ltd is 102, Shagun Vatika, Prag Narayan Road, Lucknow 226001, India. The CIN number of the company is U67100UP2019PTC123244.

The full Disclosure Document for the Portfolio Management Services of Wryght Research & Capital Private Limited, prepared in accordance with the SEBI (Portfolio Managers) Regulations, 2020, can be downloaded below:

https://www.wrightresearch.in/media/pms/disclosure-pms.pdf

Annexure 3: Investor Charter

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

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

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

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.

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)

Before buying/ selling 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 recommendation.

Seek clarifications and guidance on research recommendations from your Research Analyst, especially if it involves complex and high risk financial products and services.

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.

Always be aware that you have the right to provide feedback to your Research Analyst in respect of the services received.

Always be aware that you will not be bound by any clause, prescribed by the research analyst, which is contravening any regulatory provisions.

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 rumors.

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, demat or bank accounts with the Research Analyst.

Annexure 4: Consent Opt-out Request Form

To: Compliance Department / Data Protection Officer

Email: info@wrightresearch.in / hello@wrightresearch.in / compliance@wrightresearch.in

Client Full Name:

Client ID / PAN:

Registered Email:

Contact Number:

I/We hereby exercise my/our right to WITHDRAW / OPT-OUT of consent for the sharing of my/our personal, KYC, and financial data with any affiliate or group entity operating under a separate PMS license.

I/We understand that:

This opt-out request will be processed within 14 business days of receipt by the Compliance Officer.

This withdrawal does not affect data sharing required by statutory, SEBI, tax, or legal authorities under applicable laws.

This opt-out applies prospectively and will not affect data previously processed or retained for regulatory compliance purposes.

__________________

Client Signature

Date: DD / MM / YYYY