A. Disclosures of Material Interest (as per SEBI Regulations)

In accordance with SEBI (Research Analysts) Regulations, 2014, the Research Analyst (Amit) hereby discloses the following:

1. Ownership & Holding: The Research Analyst or his associates/relatives do NOT hold more than 1% financial interest in the subject companies recommended in our research reports as of the date of publication. Any personal holdings of the analyst are explicitly disclosed in the respective research report.
2. Compensation & Conflict: The Research Analyst or his associates/relatives have not received any compensation from the subject companies in the past twelve months, nor do we have any banking / investment banking relations with them.
3. Market Making: The Research Analyst does not act as a market maker for any recommended securities.
4. Directorships: The Research Analyst does not serve as an officer, director, or employee of any subject company recommended in the research reports.

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

• Publish research reports based on diligent research activities of the RA.
• Provide independent, unbiased views on securities.
• Offer unbiased recommendations, disclosing any financial interests in recommended securities.
• Provide research recommendations, based on analysis, publicly available info and known observations.
• Conduct annual audits and ensure compliance with SEBI advertisement codes.
• Maintain proper records of interactions with all clients and prospective clients (prior to onboarding) where research service-related conversations have occurred.

C. Services Provided to Investors

• Onboarding clients by explaining terms, services, and risk disclosure, and completing KYC for fee-paying clients.
• Facilitating access to research reports via email or registered portal.
• Ensuring confidentiality of research results prior to publication.
• Disclosing information material to the client (including business activities, disciplinary history, risks, and potential conflicts of interest).
• Distributing research reports and recommendations to clients without discrimination.
• Disclosing the extent to which Artificial Intelligence (AI) tools are used in generating research services.
• Timebound resolution of investor grievances (within 30 calendar days).

D. Grievance Redressal Mechanism & Timelines

If you have any grievance, approach the Research Analyst directly at query.amitsangawar@gmail.com or registered office: Dabki Road, Laxmi Road, Akola, MAHARASHTRA, 44400, India. The analyst must resolve it within 30 days. If unsatisfied, escalate to SEBI via the SCORES portal (scores.sebi.gov.in) or send physical complaints directly to SEBI Office: 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. Expectations from Investors (Do’s and Don’ts)

Do’s:

• Deal only with SEBI-registered Research Analysts (verify registration number on SEBI site).
• Check the SEBI registration certificate and validity details.
• Read disclaimers and disclosures carefully before making investment choices.
• Pay subscription fees only through authorized banking channels (NEFT/RTGS/IMPS/UPI) and maintain receipts.
• Ensure that you provide complete and accurate information during onboarding.
• Ask questions and clear all doubts with the RA regarding their recommendations before acting on them.
• Report misconduct to SEBI if an RA promises assured or guaranteed returns.

Don’t’s:

• Do not pay any cash or cash-equivalents to the Research Analyst.
• Do not share secure login credentials (PINs, passwords, OTPs) with anyone.
• Do not sign blank documents or accept guaranteed returns / profits.
• Do not deal with unregistered intermediaries.
• Do not act on suggestions or messages received on unverified social channels (Telegram/WhatsApp channels).
• Do not provide funds to the Research Analyst for investment purposes (RAs provide research; they do not manage capital).
• Do not fall prey to luring advertisements, market rumors, or promises of limited-period discounts/incentives.

We respect client confidentiality. We collect client names, contact details, PAN, and KYC details during onboarding:

• All information collected is used solely for verification, invoicing, record keeping (mandated for 5 years by SEBI), and delivering research reports.
• We do not sell, rent, or share customer database logs with third-party marketing companies.
• Information may be shared only with regulatory bodies (like SEBI or income tax departments) if officially demanded under legal provisions.

We maintain a transparent fee and refund policy in line with SEBI regulations:

A. Eligible Refund Scenarios

Subscribers may request a refund or cancellation under the following specific circumstances:

• Double Payment / Billing Error: If a client is charged multiple times due to a gateway/technical error, the duplicate transaction will be refunded in full.
• Non-Delivery of Services: If we fail to deliver the research reports or recommendations promised under your subscription tier, you will be entitled to a refund.
• Premature Termination: In the event of premature termination of research services by either party, the client is entitled to a refund of fees for the unexpired/unused subscription period on a pro-rata basis.
• Regulatory Action: If the registration of the Research Analyst is suspended or canceled by SEBI, any subscription fee collected for the unexpired portion of the subscription period shall be refunded to the client on a pro-rata basis.

B. Non-Refundable Scenarios

In accordance with industry compliance and market risk disclaimers:

• Market Losses: Investments in the securities market carry risk. Under no circumstances will refunds be issued for losses incurred based on our research recommendations.
• Performance Dissatisfaction: Dissatisfaction with the performance of recommended stocks, targets, or stop-loss hits is not eligible for a refund.

C. Refund Processing & Claims

To claim an eligible refund, email us at query.amitsangawar@gmail.com within 7 days of occurrence with invoice details and transaction proof. Verified refunds will be processed to the client’s bank account within 10 to 15 working days. Any statutory deductions (such as GST or payment gateway processing charges) will be deducted from the final refund amount as permitted by SEBI guidelines.

1. Execution of Trades

We do not provide trade execution, direct trading accounts, or portfolio management services. Trades must be executed through your own stockbroker at your own discretion.

2. Safe Advisory Boundaries

Recommendations are purely for information. We are not liable for any losses incurred in the market. Please allocate capital responsibly using proper stop-loss limits.

3. Fee Collection Route

All subscription payments must only be made through digital pathways from the client’s own self-owned bank account. Cash payments are strictly prohibited under compliance circulars.

Please read these Terms & Conditions carefully before subscribing to our research reports.

1. Nature of Service

All subscription packages at Neetesh Research are strictly for **Research Reports**. We do not provide customized financial planning, personalized investment advisory, discretionary wealth management, or execute trades. All investment choices are made solely by the client.

2. Subscription Fees & Payment

Subscription fees are payable in advance and must be sent only through authorized digital channels (NEFT, UPI, Netbanking). Under no circumstances will cash payments be accepted. Accounts are activated only after verifying KYC compliance.

3. Risk Disclosure

Securities market investments are subject to market volatility and risk. Historical performance of any recommendation is not indicative of future returns. You agree that you are fully aware of market risks and bear sole responsibility for any trading gains or losses.

4. Intellectual Property

The research reports shared with subscribers are for their personal, non-commercial use only. Unauthorized distribution, copying, or forwarding of reports on messaging channels (like Telegram, WhatsApp) is strictly prohibited and subject to legal action under intellectual property laws.

Securities Market Warning: Investments in securities market are subject to market risks. Read all the related documents carefully before investing.

Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

All reports and technical recommendations are prepared under SEBI (Research Analyst) Regulations, 2014. Registration details: Amit Raju Sangawar, Trade Name: AS Capital Research, SEBI Registration No: INH000028972 , validity: July 17, 2026 – Perpetual, Type: Individual. Registered office: Dabki Road, Laxmi Road, Akola, MAHARASHTRA, 444001 Compliance Officer: Amit Raju Sangawar, Phone: 9075495590, Email:query.amitsangawar@gmail.com