Waves Strategy Advisors (“Research Analyst” or ‘RA”), is SEBI Registered Research Analyst bearing Registration No. INH000001097, enlisted with Research Analyst Administration and Supervisory Body (RAASB)- BSE Limited having its Enlistment No. as 5069.

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 (as 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.

1. Acceptance of Research Services

The client confirms that he/she has elected to subscribe 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).

2. 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.

3. 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.

4. Standard Terms of Service

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

 i. “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.”

ii. “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.”

iii. “I/We understand that –

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

ii.Recommendations in the research report do not provide any assurance of returns.

iii. 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:

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

o Registration number- INH000001097

o Registration date- July,20,2015

ii. 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;

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

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

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

5. 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 the advance amount is not more than that for a period of twelve (12) months only, as permitted by SEBI.

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 client likes to opt for ‘Centralised Fee Collection Mechanism (CeFCoM)’, an email request for the same may be sent to RA for processing of same.

6. 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.

7. 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.

8. Termination of Services and Refunds

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

• 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.

9. Grievance Redressal and Dispute Resolution

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

o Non-receipt of research report, or

o Missing pages or inability to download the entire report, or

o Any other deficiency in the research services provide by RA

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

o Name- Ashish Kyal

o Email- [email protected] •

•  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/

10. 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 

1) Full payment in advance for any mode of subscription and renewal of subscription, Training & Education

2) For Training programs no refund will be allowed.

3) The minimum subscription period will be 1 month

4) All reports will be available on email or on website after secured client login

5) If opted for any training the access to the videos would be for limited period only.

6) By joining or registering on the mailing list of Waves Strategy Advisors / Ashish Kyal Trading Gurukul / Trivedikyal.com or by filling any form, you have chosen to receive free course / syllabus updates via email, SMS,or any other modes of communication and you agree to abide by all the terms mentioned here. These terms maybe subject to change from time to time, and you are bound by such changes.

7) By joining the mailing list of Waves Strategy Advisors, Ashish Kyal Trading Gurukul or Trivedikyal.com or subscribing to any of our paid services, you have chosen to receive course / Training updates via, email, SMS, or other modes of communication, in text video or webinar formats or other technology formats that maybe available from time to time.

8)Membership/Subscription means paid access to the website/blog and updates posted on www.wavesstrategy.com. It does not guarantee a specific quantity or frequency of course / Training updates, nor does it ensure timeliness or a fixed schedule for updates. However, Waves Strategy Advisors endeavors to maintain the highest level of accuracy, timeliness, and quality in its work.

9) Any reference  to “Waves Strategy Advisors” , “wavesstrategy.com” or “Ashish Kyal Trading Gurukul (AKTG)” refers  to the same company . Waves Strategy Advisors and wavesstrategy.com are synonymous.

10) All content published on wavesstrategy.com or wavesstrategyadvisors.com is the property and copyright of the company. Redistribution, republication ,or plagiarism, without prior approval from Waves Strategy Advisors and without proper credit is subject to legal action under Indian copyright law.

11) Certain portions of the website have restricted access for subscribers only. Restricted access rules may change from time to time, and it is at the sole discretion of Waves Strategy Advisors  to determine which portions of the website will be restricted to members and which will remain public. Prior notice of such changes will not be provided.

12) If Waves Strategy Advisors provides you with a user ID and password to access restricted areas of this website or other content or services, you must keep the user ID and password confidential. The company may disable your user ID and password at its sole discretion, without notice or explanation.

PLEASE READ THE FOLLOWING “TERMS OF SERVICE” AGREEMENT CAREFULLY BEFORE SUBSCRIBING.

Waves Strategy Advisors provides services subject to your compliance with the terms and conditions set forth in this Agreement. By subscribing to these services, you agree to be bound by these terms and conditions.

This Agreement is made between you and us. We reserve the right to modify the terms and conditions of this Agreement at any time, change the services (including eliminating or discontinuing any content or feature of the service), or adjust any fees or charges for the service.

Please review this Agreement periodically to stay informed of the most current version. Our policy regarding the collection and use of your personal information is outlined in our Privacy Policy.

Code of Conduct

While using any of the Service you agree not to:

Restrict or inhibit any other visitor or subscriber from using the Service, including, without limitation, by means of “hacking” or “cracking” or defacing any portion of any of the Service or Website

Use the Website for any unlawful purpose

Express or imply that any statements you make are endorsed by us, without our prior written consent.

Transmit any content or information comprising the Service or Website, which is unlawful, fraudulent, threatening, harassing, abusive, libelous, defamatory, obscene or otherwise objectionable, or infringes on our or any third party’s intellectual property or other rights

Engage in spamming or flooding

Transmit any software or other materials that contain any virus, worm, time bomb, Trojan horse, or other harmful or disruptive component

Modify, adapt, sublicense, translate, sell, reverse engineer, de-compile or disassemble any portion of the Service or Website

Remove any copyright, trademark, or other proprietary rights notices contained in the Service or Website

“Frame” or “mirror” any part of the Service or Website without our prior written authorization

Use any robot, spider, site search/retrieval application, or other manual or automatic device or process to retrieve, index, “data mine,” or in any way reproduce or circumvent the navigational structure or presentation of the Service, Website or its contents

Harvest or collect information about Site visitors or members without their / our express consent or

Permit anyone else whose account or subscription was terminated to use the Service or Website through your subscription, username or password.

While using the Site you agree to comply with all applicable laws, rules and regulations.

If you are our subscriber, and you have reason to believe that your online account is no longer secure, you must promptly change your password by updating your account information and immediately notify us by emailing us at: [email protected]

Termination

This Agreement shall remain effective until terminated in accordance with its terms. We may terminate this Agreement, and/or your access to and use of the Site or any portion thereof, immediately, if we determine, in our sole discretion, that you have breached this Agreement. Additionally, we reserve the right to terminate this Agreement without cause.

Services and Tools

Your use of certain services or the Website may be governed by additional rules, which are available on the Site or  through hyperlink from other sites in connection with the Service. By using any Service, you  acknowledge that you have reviewed all corresponding rules and agree to be bound by them. Some Services may be  provided by third parties for your use. You expressly acknowledge and agree that your use of all services is solely at your risk.

Ownership and Restrictions on Use

The copyright to the services and  Website is owned by Waves Strategy Advisors. You may only access and use the material, and download and/or print out a single copy of any material, solely for your personal use. You may not republish, upload, post, transmit or distribute material in any way without our prior written permission. Modification of the material or use of the material for any other purpose is a violation of our copyright and other proprietary rights, and is strictly prohibited. You acknowledge that you do not acquire any ownership rights by using the Site.

Links to Other Websites

The Site may contain links to other Internet websites or resources. We neither control nor endorse such other websites, nor have we reviewed or approved any content that appears on them. You acknowledge and agree that we shall not be held responsible for the legality, accuracy, or inappropriate nature of any content, advertising, products, services, or information found on or through any other websites, nor for any loss or damages caused or alleged to have been caused by the use of or reliance on such content.

DISCLAIMERS

The Website, the material contained in any service, and anything that is obtained or accessed through the Website are provided “as is” and without representations or warranties of any kind, either expressed or implied, to the fullest extent permissible pursuant to applicable law. Waves Strategy Advisors, its officers, directors, employees, affiliates, suppliers, advertisers, and agents disclaim all warranties, express, implied or statutory, including, but not limited to, implied warranties of title, non-infringement, merchantability, and fitness for a particular purpose, and all warranties relating to the adequacy, accuracy or completeness of any information contained in the Service / Website. Waves Strategy Advisors, and its affiliates, suppliers, agents and sponsors do not warrant that your use of any Service / Website will be uninterrupted, error-free, or secure, that defects will be corrected, or that the Site or the server(s) on which the Site is hosted are free of viruses or other harmful components. You acknowledge that you are responsible for obtaining and maintaining all telephone, computer hardware and other equipment needed to access and use the Site, and all charges related thereto. You assume total responsibility and risk for your use of the Service / Website and your reliance thereon. No opinion, advice, or statement of Waves Strategy Advisors, or its affiliates, suppliers, agents, members, or visitors, whether made on the Site or otherwise, shall create any warranty. Your use of the Services / Website and any materials provided is entirely at your own risk.

A possibility exists that our Service / Website could include inaccuracies or errors. Additionally, unauthorized alterations may be made by third parties to the Service / Website. Although we strive to ensure the integrity of the Service / Website, we make no guarantees regarding their completeness or accuracy.  In the event that such a situation arises, please contact us at: [email protected] , if possible, with a description of the material to be checked, the location where such material can be found, and information sufficient to enable us to contact you. We will make reasonable efforts to address your concerns as soon as practicable.

Limitation of Liability

Neither Waves Strategy Advisors nor its affiliates, suppliers, advertisers, affiliates, or agents or sponsors are responsible or liable for any indirect, incidental, consequential, special, exemplary, punitive or other damages under any contract, for any negligence, or other damage arising out of or relating in any way to the Service or Website and/or content contained, or any product or service purchased through the Site. Your sole remedy for dissatisfaction with the Service / Website and/or content contained within it is to stop using the Service / Website. The only and maximum liability for all damages, losses, and causes of action shall be the total amount paid by you, if any, to access the Service / Website.

Indemnification

You agree to indemnify, defend and hold us, our officers, directors, employees, agents and representatives harmless from and against any and all claims, damages, losses, costs (including reasonable attorneys’ fees), or other expenses that arise directly or indirectly out of or from (a) your breach of this Agreement, including any violation of the Code of Conduct above; (b) any allegation that any materials that you submit to us or transmit to the Website, infringe or otherwise violate the copyright, trademark, trade secret or other intellectual property or other rights of any third party; and/or (c) your activities in connection with the Service / Website. Waves Strategy Advisors is not a registered investment advisor. Waves Strategy Advisors is registered as an Authorized Person with Nirmal Bang for different exchanges.

Readers are advised that the material / suggestion contained in any Service / Website are  given solely for information purposes and should not to be construed as an offer to sell or the solicitation of an offer to buy any security. The opinions and analyses included herein are based on sources believed to be reliable and are written in good faith, but no representation or warranty, express or implied, is made as to their accuracy, completeness or correctness.

YOU SHOULD VERIFY ALL CLAIMS AND DO YOUR OWN RESEARCH BEFORE INVESTING IN ANY SECURITIES MENTIONED IN ANY SERVICE / WEBSITE. INVESTING IN SECURITIES IS SPECULATIVE AND CARRIES A HIGH DEGREE OF RISK. YOU MAY LOSE PART OR ALL OF YOUR PRINCIPAL INVESTMENT.

Users are urged to consult with their own independent financial advisors with respect to any investment. All information contained in the Service / Website should be independently verified with the companies mentioned. Neither Waves Strategy Advisors nor its officers, directors, partners, contributors or employees/consultants accept any liability whatsoever for any direct or consequential loss arising from any use of information provided in any Service/ Website. Waves Strategy Advisors, and its officers, directors, partners, contributors or employees/consultants may on occasion hold positions in the securities mentioned in reports. These positions may change at anytime.

Please note that Waves Strategy Advisors does not receive compensation of any kind and will never accept any compensation from any company mentioned in its Service / Website.

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/

SEBI Registered Research Analyst “Waves Strategy Advisors” SEBI Registration No. INH000001097 / BSE enlistment No. 5069

Registered office address: A-413, Express Zone, Western Express Highway, Malad East, Mumbai 400097” Compliance officer Munmun Kyal, [email protected], Contact +918369182672/ Grievance Redressal officer – Ashish Kyal, [email protected], contact +919920422202

Warning - “Investment in securities market are subject to market risks. Read all the related documents carefully before investing.”Disclaimer “Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

 USE OF OUR SERVICES / WEBSITE SIGNIFIES YOUR ACCEPTANCE OF THIS TERMS OF SERVICE AGREEMENT