Investor Charter & Disclosures

REGISTRATION DETAILS

PART A: INVESTOR CHARTER FOR RESEARCH ANALYST

(As per SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 dated June 02, 2025)

A. Vision and Mission Statements for Investors

Vision: Deliver reliable intelligence on the performance and outlook of companies.

Mission: Provide institutional quality analysis across the market breadth.

B. Details of Business Transacted by the Research Analyst

• To publish research reports based on the research activities of the Research Analyst
• To provide an independent, unbiased view on securities
• To offer unbiased recommendations, disclosing the financial interests in recommended securities
• To provide research recommendations based on analysis of publicly available information and known observations
• To conduct an 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

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 business activity, disciplinary history, terms and conditions of research services, details of associates, risks and conflicts of interest
• 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
• To disclose any conflict of interest of the activities of providing research services with other activities of the research analyst

General Services:

• 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 the 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. Grievance Redressal Mechanism

1. Filing Complaint with Research Analyst:

In case of any grievance/complaint, an investor may approach Mool Capital Private Limited who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.

2. Filing Complaint on SCORES or with RAASB:

• SCORES 2.0 (https://scores.sebi.gov.in) - A web-based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner

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 (BSE Limited)

3. SMART ODR Platform:

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 (https://smartodr.in/login) for its resolution through online conciliation or arbitration.

4. 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 - 400051

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 Investors (Responsibilities)

Do's:

1. Always deal with SEBI registered Research Analyst.
2. Ensure that the Research Analyst has a valid registration certificate.
3. Check for SEBI registration number. Please refer to the list of all SEBI registered Research Analysts available on SEBI website: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=14
4. Always pay attention towards disclosures made in the research reports before investing.
5. 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 Centralised Fee Collection Mechanism (CeFCoM) of RAASB if the research analyst has opted for the mechanism.
6. Before buying/selling securities or applying in public offer, check for the research recommendation provided by your Research Analyst.
7. Ask all relevant questions and clear your doubts with your Research Analyst before acting on recommendation.
8. Seek clarifications and guidance on research recommendations from your Research Analyst, especially if it involves complex and high-risk financial products and services.
9. 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.
10. Always be aware that you have the right to provide feedback to your Research Analyst in respect of the services received.
11. Always be aware that you will not be bound by any clause, prescribed by the research analyst, which is contravening any regulatory provisions.
12. Inform SEBI about Research Analyst offering assured or guaranteed returns.

Don'ts:

13. Do not provide funds for investment to the Research Analyst.
14. Don't fall prey to luring advertisements or market rumors.
15. Do not get attracted to limited period discount or other incentive, gifts, etc. offered by Research Analyst.
16. Do not share login credential and password of your trading, demat or bank accounts with the Research Analyst.

PART B: INVESTOR CHARTER FOR INVESTMENT ADVISER

(As per SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/80 dated June 02, 2025)

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 Investment Adviser

• To enter into an agreement with the client providing all details including fee details, aspects of conflict of interest disclosure and maintaining confidentiality of information
• To do a proper and unbiased risk-profiling and suitability assessment of the client
• To conduct audit annually
• To disclose the status of complaints on its website
• To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI Office details on its website
• To employ only qualified and certified employees
• To deal with clients only from official number
• To maintain records of interactions with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place
• To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers
• Not to discriminate in terms of services provided, among clients opting for same/similar products/services offered by investment adviser

C. Details of Services Provided to Investors

Onboarding of Clients:

• Sharing of agreement copy
• Completing KYC of clients

Disclosure to Clients:

• To provide full disclosure about its business, affiliations, compensation in the agreement
• To not access client's accounts or holdings for offering advice
• To disclose the risk profile to the client
• To disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser
• To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services
• To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client
• To treat all advisory clients with honesty and integrity
• To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser
• To provide clear guidance and adequate caution notice to clients when providing investment advice for dealing in complex and high-risk financial products/services
• 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
• To disclose the timelines for the various services provided by the investment adviser to clients and ensure adherence to the said timelines

D. Grievance Redressal Mechanism

1. Filing Complaint with Investment Adviser:

In case of any grievance/complaint, an investor may approach Mool Capital Private Limited who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.

2. Filing Complaint on SCORES or with IAASB:

• SCORES 2.0 (https://scores.sebi.gov.in) - A web-based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner

Two-level review for complaint/grievance against Investment Adviser:

- First review done by designated body (IAASB)

- Second review done by SEBI

• Email to designated email ID of IAASB (BSE Limited)

3. SMART ODR Platform:

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 (https://smartodr.in/login) for its resolution through online conciliation or arbitration.

4. 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 - 400051

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 Suitability of the Financial Products
• Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser
• 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 Investors (Responsibilities)

Do's:

1. Always deal with SEBI registered Investment Adviser.
2. Ensure that the Investment Adviser has a valid registration certificate.
3. Check for SEBI registration. Please refer to the list of all SEBI registered Investment Advisers available on SEBI website: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=13
4. Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments. You may make payment of advisory fees through Centralised Fee Collection Mechanism (CeFCoM) of IAASB if investment adviser has opted for the mechanism.
5. Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
6. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
7. Assess the risk-return profile of the investment as well as the liquidity and safety aspects before making investments.
8. Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations before dealing with any Investment Adviser.
9. Be vigilant in your transactions.
10. Approach the appropriate authorities for redressal of your doubts/grievances.
11. Inform SEBI about Investment Advisers offering assured or guaranteed returns.
12. Always be aware that you have the right to exit the service of an Investment Adviser.
13. Always be aware that you have the right to seek clarifications and clear guidance on advice.
14. Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.
15. Always be aware that you will not be bound by any clause, prescribed by the investment adviser, which is contravening any regulatory provisions.

Don'ts:

16. . Don't fall for stock tips offered under the pretext of investment advice.
17. . Do not provide funds for investment to the Investment Adviser.
18. . Don't fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don't let greed overcome rational investment decisions.
19. . Don't fall prey to luring advertisements or market rumors.
20. Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
21. Don't take decisions just because of repeated messages and calls by Investment advisers.
22. Do not fall prey to limited period discount or other incentive, gifts, offered by Investment advisers.
23. Don't rush into making investments that do not match your risk taking appetite and investment goals.
24. Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.

PART C: STATUTORY DISCLOSURES

1. Entity Information

2. Corresponding SEBI Regional Office

NBCC Complex, Office Tower-1, 8th Floor, Plate B, East Kidwai Nagar, New Delhi - 110023 Tel. Board: +91-011-69012998

3. Disclosure on Use of Artificial Intelligence

Mool Capital Private Limited utilizes Artificial Intelligence (AI) tools to enhance the efficiency and accuracy of its research and advisory services. These AI tools assist in:

• Data analysis and processing of financial information
• Pattern recognition and market trend analysis
• Generating insights to support research recommendations
• Predictive modeling and scenario analysis
• Processing and structuring of company filings and disclosures

Human oversight is applied to validate and refine all research outputs. The use of AI tools does not diminish our responsibility for the accuracy, security, confidentiality, and integrity of client data and research recommendations.

4. Conflict of Interest Disclosure

• Mool Capital Private Limited and its affiliated companies, directors, employees, and Research Analysts (including relatives) worldwide may from time to time have long or short positions in, and buy or sell the securities thereof, of companies mentioned in research reports.
• The research entity has not been engaged in a market-making activity for any subject company.
• The research analyst has not served as an officer, director, or employee of any subject company.
• Compensation of Research Analysts is not based on any specific merchant banking, investment banking, or brokerage service transactions.
• Any material conflict of interest will be appropriately disclosed and dealt with in accordance with applicable law.

PART D: INVESTOR COMPLAINT DATA

(Format as per Annexure B of SEBI Circulars - to be updated by the 7th of each succeeding month)

1. Monthly Compliant Data

*Inclusive of complaints of previous months resolved in the current month.

#Inclusive of complaints pending as on the last day of the month.

2. Annual Compliant Data

*Inclusive of complaints of previous months resolved in the current year.

#Inclusive of complaints pending as on the last day of the year.

PART E: DISCLAIMER

IMPORTANT NOTICE: Investment in securities market are subject to market risks. Read all the related documents carefully before investing. Registration granted by SEBI, membership of BASL and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

The information and content presented in research reports are provided for general informational purposes only and should not be construed as professional financial or investment advice. Each recipient should make such investigations as they deem necessary to arrive at an independent evaluation of an investment in securities of the companies referred to in research documents and should consult their own advisors to determine the merits and risks of such investment.

Mool Capital Private Limited accepts no liability and will not be liable for any loss or damage arising directly or indirectly from any use of any information provided, including but not restricted to, fluctuation in the prices of shares and bonds, changes in the currency rates, diminution in the NAVs, reduction in the dividend or income, etc.

Past performance is not indicative of future results. Any projections, forecasts, or estimates contained herein are subject to change without notice.

Useful Links

• SEBI Website: https://www.sebi.gov.in
• SCORES Portal: https://scores.sebi.gov.in
• SMART ODR Portal: https://smartodr.in/login
• SEBI Registered RA List: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=14
• SEBI Registered IA List: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=13

Document Version: 1.0 | Last Updated: February 2026
This document is prepared in compliance with SEBI guidelines and should be read in conjunction with applicable regulations.