Terms and Conditions for Research Services

1. Availing the research services

You have elected to subscribe to the research services offered under the product name SWIP at your sole discretion. We render research services in accordance with the SEBI (Research Analysts) Regulations, 2014 and the circulars, guidelines and directions issued under them.

SWIP publishes swing-trading research recommendations on NSE-listed cash equities. Each recommendation is published with an entry level, a stop-loss and two target levels, before the position is taken. SWIP is a research display product: there is no order placement, no execution partner, and we never hold or touch client funds or securities.

2. Obligations on the Research Analyst

Both parties are bound by the applicable rules and regulations, including the Securities and Exchange Board of India Act, 1992, the SEBI (Research Analysts) Regulations, 2014, and the relevant notifications, guidelines, circulars and directions issued by SEBI and by the Research Analyst Administration and Supervisory Body (RAASB), as amended from time to time.

3. Client information and KYC

You undertake to furnish the details required by us for the purpose of availing research services. We collect, store, upload and check your KYC records with a KYC Registration Agency (KRA) as specified by SEBI. In accordance with Regulation 25(1) of the RA Regulations, the KYC procedure applies to fee paying clients; the free trial does not require KYC.

We maintain a register of clients containing PAN, the date and nature of the research service, the securities for which research service was provided, and the fee charged. Records are preserved for a minimum of five years.

4. Standard terms of service

Your consent is taken on the following understanding, in the form prescribed by SEBI:

“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 –
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.”

We in turn declare that:

1. We are registered with SEBI as a Research Analyst with registration number INH000017736, registered on 19 July 2024.
2. Our registration and the qualification and certification of our research analysts are valid and subsisting.
3. The research services we provide do not conflict with or violate any provision of law, rule or regulation, contract or other instrument to which we are a party or by which we are bound.
4. The maximum fee that may be charged by us is ₹1.51 lakhs per annum per family of client.
5. Our recommendations do not provide any assurance of returns.

5. Consideration and mode of payment

SWIP Membership is ₹5,000 per quarter (₹20,000 per annum) plus applicable statutory charges. There is no auto-renewal.

The maximum fee chargeable to an individual or HUF client is ₹1,51,000 per annum per family of client across all our research services, excluding statutory charges. The limit does not apply to non-individual clients or accredited investors. Fees may be charged in advance where agreed by you, not exceeding fees for a period of one year.

Payment may be made by cheque, online bank transfer, UPI or other specified electronic modes. Cash payment is not accepted. Optionally, you may pay through the Centralized Fee Collection Mechanism (CeFCoM) operated by BSE Limited — see section 13.

Full detail, including the pro-rata refund calculation, is at Fees, Cancellation & Refunds.

6. Risk factors

Investments in securities are subject to market and other risks, and there is no assurance or guarantee that the objectives of any investment will be achieved. In addition to the standard risks of investing in securities, the following risks are specific to the nature of SWIP's research:

• Overnight and gap risk. Swing positions are held across sessions. A stock can open materially away from its previous close on news, results, regulatory action or global events. A published stop-loss offers no protection against a gap through it.
• Stop-loss slippage. A stop-loss level we publish is a research level, not a guaranteed exit price. In fast or illiquid markets the price actually achievable may be materially worse than the level stated. A published stop may not be achievable at the stated price.
• Single-stock concentration. Our recommendations are individual cash equities, not a diversified portfolio. The performance of a single company can diverge sharply from the market.
• Liquidity and circuit limits. Mid- and small-cap securities may have limited liquidity or may hit exchange-imposed price bands, in which case exiting at or near a published level may be impossible for a period.
• Execution difference. You place your own orders in your own account. Your entry price, exit price, timing, position size, brokerage, taxes and other costs will differ from the levels we publish, and therefore your outcome will differ from our published record.
• Past performance. Past performance is not indicative of future results, and no assurance of returns is provided or implied.

See our full Risk Disclosure.

7. Conflict of interest

We adhere to the applicable regulations, circulars and directions specified by SEBI and RAASB in relation to the disclosure and mitigation of any actual or potential conflict of interest, and will endeavour to promptly inform you of any conflict that may affect the services being rendered to you.

Our disclosures: our research analysts and their relatives do not trade in the securities covered in our research. We are not associated with any issuer of the securities we cover. We have no financial interest, no actual or beneficial ownership of one per cent or more, and no other material conflict of interest in the subject securities at the time of publication. We have not received any compensation from any subject company, and have not managed or co-managed any public offering. We are not engaged in distribution activities, so the client-level segregation requirement under Regulation 26C(5) does not arise.

8. Termination of service and refund of fees

You may terminate the research services at any time. On pre-mature termination by either party, you are entitled to a refund of proportionate fees for the unexpired period, and we will not charge any breakage fee.

We may suspend or terminate the research services on the suspension or cancellation of our registration by SEBI. If our certificate of registration is suspended for more than sixty (60) days, or is cancelled, we will refund fees on a pro rata basis for the period from the effective date of such suspension or cancellation to the end of your subscription period.

9. Grievance redressal and dispute resolution

Designated person for grievances: Siddhesh Pednekar, Compliance Officer and Principal Officer.
Email: siddheshpednekar405@gmail.com · Tel: +91 93266 57923 · 10:00 AM – 6:00 PM, Monday to Saturday
Address: A G Shed, Ground Floor, 38, Krishna Krupa, Gokhale Road (North), Dadar West, Mumbai, Maharashtra 400028

We shall resolve your grievance within 7 business working days. If you are not satisfied, you may escalate to SEBI's SCORES platform and thereafter initiate online conciliation or arbitration through the Smart ODR portal. The full escalation matrix is at Grievance Redressal, and our monthly complaint data is published at Complaint Data.

10. Additional clauses

Any additional clause we introduce shall not contravene any rule, regulation or direction of SEBI. We will give you 15 days' prior notice of any change to these terms and conditions, and will seek your consent afresh where the change is material.

These terms are governed by the laws of India. Disputes are subject to the jurisdiction of the courts at Mumbai, Maharashtra, without prejudice to your right to pursue SCORES or ODR.

You will not be bound by any clause prescribed by us which contravenes any regulatory provision.

11. Mandatory notice

Clients are requested to go through the Do's and Don'ts for dealing with a Research Analyst, as prescribed in the SEBI Master Circular for Research Analysts. These are reproduced in full in our Investor Charter, section F.

12. Most Important Terms and Conditions (MITC)

[Forming part of the Terms and Conditions for providing research services. Prescribed by SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 dated 17 February 2025 and reproduced as issued.]

1. 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.
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).
   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.
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 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 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, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/ publication of research report.
8. Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the client's own judgement and assessment of the conclusions contained in the research report.
9. The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
10. For any grievances,
    Step 1: the client should first contact the RA using the details on its website or following contact details: Compliance Officer: Siddhesh Pednekar · Email: siddheshpednekar405@gmail.com · Phone: +91 93266 57923 · 10:00 AM – 6:00 PM, Monday to Saturday
    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
11. Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.
12. 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.

13. Centralised Fee Collection Mechanism (CeFCoM) — optional

SEBI has operationalised a Centralised Fee Collection Mechanism for Investment Advisers and Research Analysts, administered by BSE Limited as the recognised RAASB. Paying through CeFCoM lets you confirm that your fee is going to a genuinely registered Research Analyst, because the mechanism only accepts payments for registered intermediaries.

Use of CeFCoM is optional and is your choice. If you would like to pay this way, tell us and we will raise your invoice through the mechanism instead of our normal payment link.

14. Use of Artificial Intelligence tools

[Disclosure of the extent of use of Artificial Intelligence tools in providing research services, as required by Regulation 19(vii) of the SEBI (Research Analysts) Regulations, 2014.]

Artificial Intelligence tools play no part in deciding what we recommend. Every research decision — which security to cover, whether to recommend it, the entry level, the stop-loss and the target levels — is made by our human research desk. Once a recommendation is published, the closing of that recommendation is determined arithmetically against the stop-loss and target levels already published; no model, statistical or otherwise, participates in that determination.

We do use AI tools, specifically, for the following supporting purposes:

• Plain-language summaries. On request, a short explanation of the rationale for a recommendation that has already been decided and published by our research desk. The summary restates the analyst's reasoning; it does not create it.
• Drafting client communications. Drafts of service emails and internal daily briefs. Every such communication is reviewed by a human before it is sent.
• In-dashboard assistance. An assistant that answers general questions about the dashboard and explains standard terms such as drawdown. It does not give recommendations, and it is not a source of research.
• Marketing copy. Drafts of marketing material, reviewed and approved by a human before publication.

In accordance with Regulation 24(7), we remain solely responsible for the security, confidentiality and integrity of your data, for any output derived from these tools, and for compliance with applicable law — irrespective of the scale or scenario of their use. We do not use client personal data to train third-party models. If the extent of our use of these tools changes materially, we will update this disclosure and notify you.

15. Consent and record-keeping

In accordance with paragraph xii(b) of the Guidelines for Research Analysts, no research service is rendered and no fee is charged until your consent to these terms and conditions has been received. This applies equally to the free trial, which renders research services and therefore requires your consent before it begins.

We record the version of this document you accepted, the date and time of acceptance, and retain that record, together with records of our communications with you, for a minimum of five years as required by Regulation 25(2).

16. Limitation of liability

Our research is provided on an “as is” basis. While it is prepared in good faith from information believed to be reliable, its completeness and accuracy are not guaranteed. The final decision to buy, sell or hold any security is yours alone, and any resulting profit or loss is entirely your own. There is no recourse to claim any losses incurred on investments made on the basis of our recommendations. Nothing in this section limits any liability which cannot lawfully be limited, or affects your rights under the SEBI regulations.