WHEREAS

1. The Investment Adviser is registered under SEBI (Investment Advisers) Regulations, 2013 (herein referred to as IA Regulations), having registration number INA000018382, valid from 23 August, 2023 till perpetual.
2. The Investment Adviser is engaged in the business of providing investment advisory services. The Investment Adviser is owner of the website www.coinstreet.in (hereinafter referred to as “the Website”)
3. The Client is desirous of obtaining Services from the Investment Adviser on such terms and conditions as mentioned in this Agreement and payment of fees.
4. The Investment Adviser, having the necessary financial knowledge, resources and technical know-how, has expressed its readiness and willingness to deliver the Services required by the Client.
5. Both the parties agree to be bound by the terms of this Agreement.

NOW, THEREFORE, IN CONSIDERATION OF THE MUTUAL UNDERSTANDING AS SET FORTH IN THIS AGREEMENT, THE PARTIES THERETO HAVE AGREED TO THE FOLLOWING TERMS AND CONDITIONS:

I. INTERPRETATION & CONSTRUCTION

In this Agreement, unless the context or meaning thereof otherwise requires:

(A) The singular includes the plural and vice versa;

(B) Investment’ shall include disinvestment

(C) References to a person shall include the Client and Client’s family members, Client’s successors and assigns;

(D) Words importing the masculine gender shall, where the context admits, include the feminine gender.

(E) Any communication in writing shall mean and include communication via email.

(F)    The captions used in this Agreement are for convenience only and are not intended to have any legal effect.

II.  Appointment of the Investment Adviser

In accordance with the applicable laws, Client hereby appoints, entirely at his own risk, Coinwise Research Private Limited as the Investment Adviser to provide the required Services in accordance with the IA Regulations and circulars issued thereunder, as applicable and in force from time to time and terms and conditions mentioned herein.

III.  Consent from the Client

The Client hereby consents that-

 i.The Client has read and understood the terms and conditions of investment advisory services provided by the Investment Adviser along with the fee structure and mechanism for charging and payment of fee.

ii. An opportunity was provided by the Investment Adviser to ask questions and interact with person(s) associated with the investment advice.

IV.  Declaration from Investment Adviser

The Investment Adviser hereby declares that-

 i.It shall neither render any investment advice nor charge any fee until the Client has signed this Agreement.

ii.It shall not manage funds and securities on behalf of the Client and shall only receive such sums of monies from the Client as are necessary to discharge the Client’s liability towards fees for the Services rendered by the Investment Adviser.

iii.It shall not, in the course of performing the Services to the Client, hold out any investment advice implying any assured returns or minimum returns or target return or percentage accuracy or service provision till achievement of target returns or any other nomenclature that gives the impression to the Client that the investment advice is risk-free and/or not susceptible to market risks and or that it can generate returns with any level of assurance.

iv.It recommends direct implementation of advice i.e. through direct schemes/direct codes of securities wherever possible and applicable.

v.It shall always abide by the Code of Conduct as specified in the Third Schedule of the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013.

V.  Fees

a. Fees specified under the IA Regulations and relevant circulars issued there under

The above table is for information purpose only and reflects the modes of charging fees permitted under SEBI and the Investment Adviser has an option to choose any one mode for charging fees to the Client.

i)  AUA is defined as the market value of stocks, liquid assets, cash, cash equivalents etc. as on the date of calculation. Market value shall mean the price of the securities as on the day of calculating as quoted in the National Stock Exchange, India. The AUA will be calculated prior to deducting any short-term (STCG) and long term (LTCG) capital gains taxes. The Client agrees to provide such supporting documents as required by the Investment Adviser to demonstrate AUA.

ii) The AUA for the first quarter will be the value of assets as mentioned above.

iii) AUA for the subsequent quarters will be calculated on the last date of each quarter from the date of last invoice.

VI. Scope of Services:

a. The Services provided by the Investment Adviser and agreed by the Client is mentioned in details as Annexure A (herein referred to as Services).

b. The Client agrees to execute the trades for the advice given by the Investment Adviser on his own risk and responsibility. The Client has the sole discretion to decide on whether to act upon the recommendations / advice rendered by the Investment Adviser.

c. The services provided by the Investment Adviser shall be subject to the activities permitted under the IA regulations.

d. The Investment Adviser shall provide implementation / execution services to its advisory clients only through direct schemes /products in the market. However, no consideration including commission or referral fees shall be charged for such services.

VII.  Functions, obligations, duties and responsibilities of the Investment Adviser:

a. The Investment Adviser shall act in a fiduciary capacity towards its clients at all times.

b. The Investment Adviser shall always comply with IA Regulations and its amendments, rules, circulars and notifications issued by SEBI from time to time.

c. The Investment Adviser undertakes to abide by all laws, acts, rules and regulations applicable to it.

d. It will always be ensured that the Principal Officer and all persons associated with investment advice are appropriately qualified and certified as specified in regulation 7 of IA regulations.

e. It will always be ensured that the net worth is maintained as specified under regulation 8 of IA regulations.

f.  The Investment Adviser will be providing reports to clients on the current investments of the Client. This would include disclosures and information provided on the website and subsequent communication to client (both via email or verbal communication)

g. The Investment Adviser shall always maintain of records i.e. Client-wise KYC, risk assessment, analysis reports of investment advice and suitability, terms and conditions document, related books of accounts and a register containing list of clients along with dated investment advice and its rationale in compliance with the IA regulations.

h. The Investment Adviser regularly and transparently participates in the audits conducted by SEBI and is regular in complying to the inputs provided by these audits conducted by SEBI. As required under IA regulations, the Investment Adviser will ensure that the annual compliance audit is done within 6 months of the end of the financial year.

i. The Investment Adviser shall always display the details about the complaints on the Website.

VIII.  Risk Profile

a. The Investment Adviser shall ensure that the risk assessment procedure of the Client including his risk capacity and risk aversion is followed at all times.

b. The Investment Adviser shall ensure that investment advice provided is appropriate to the risk profile and suitability to investment objectives of the Client.

c.  The Investment Adviser shall ensure that the Services as mentioned in Annexure A are suitable to the risk profile of the Client.

d. The Investment Adviser shall ensure that the risk profile of the Client is communicated to the Client.

e. The Client agrees to give consent on the risk profile arrived at in the manner as required by the Investment Adviser under the IA Regulations.

f. The information provided by clients and their risk assessment shall be updated whenever there is any change in the financial situation of the Client or at the time of renewal of this Agreement, whichever is earlier.

IX.  Investment objective and guidelines:

a. The Investment Adviser shall provide investment advice on Investment Advisory Services in compliance with SEBI guidelines, covering Equities, Bonds, Gold, ETFs, Mutual Funds, and REITs.

b. The Investment Adviser shall provide particulars regarding financial plan or model or strategy as agreed with the Client (based on the risk profiling conducted for the client, total asset under advice of the client and time period for deployment).

c. The investment objective of the Investment Adviser is to generate superior and consistent risk adjusted returns for the Client.

d. The objectives sought to be achieved by the Investment Adviser are subject to the risks pertaining as stated under the Clause X “Risk Factors” of this Agreement.

e. The advice given by the Investment Adviser is based on quantitative analysis (or factor based investment strategy) which also includes technical parameters as well

f. The Clients agrees that the Investment Adviser does not guarantee the future performance, any specific level of performance, success of any investment decisions or strategy that the Investment Adviser may advice.

g. The Client acknowledges that long term capital gains tax and short-term capital gains tax would be applicable on sale of securities. If the holding period is less than one year, short term capital gains tax of 15% would be applicable and in case where the holding period is more than one year, a long term capital gains tax of 10% would be applicable on the gains. These rates may be revised by the Government of India from time to time. The tax liability on the Exchange Traded Fund (ETF) component of the portfolio, if any, would depend on the underlying asset class of the ETF. The Client may contact the Investment Advisor for a detailed discussion on the capital gain tax to be paid by the Client.

X.  Risk Factors

a. All investments in stock markets, securities and other financial instruments are subject to market risks and the returns may go up or down depending upon the factors and strategies affecting the securities market. The prices may swing widely, beyond expectations, and may lead to unanticipated losses.

b. There are no guaranteed return and that the Client may suffer financial losses anytime during the course of the agreement.

c. Equity investments may be subject to volatility in market prices which may occur on account of various factors such as corporate events, adverse news events, future market expectations, changes in industry factors, change in management / key personnel, acquisition / loss of key contracts, overall economic slowdown, unanticipated corporate performance, etc.

d. Past performances of the advice given by Investment Adviser do not guarantee its future performance.

e. Investment advice given by the Investment Adviser is for the medium to longer term returns.

f.  Liquidity of investments in equity and equity related securities are often restricted by factors such as trading volumes and settlement periods.

g. Acts of State, or sovereign action, acts of nature, acts of war, civil disturbance are extraneous factors which can impact the advice provided by the Investment Adviser.

XI.  Validity of advisory services

a. This Agreement is deemed to have commenced with effect from the date of execution of this Agreement and will be valid until terminated by either Party.

b. The terms of this Agreement can be reviewed as mutually agreed between both the parties after the completion of one year of the agreement.

XII.  Amendments

Where the parties sense that the terms and conditions governing the advisory services under this Agreement need alteration, none of these amendments and/or modifications of any of the provisions of this Agreement shall be effective unless made in writing specifically referring to this Agreement and duly signed by the Parties hereto.

XIII. Termination

1. This Agreement may be terminated under the following circumstances, namely-

(a)  Non-payment of fee after 30 days of date of invoice

(b) Voluntary / mandatory termination by the Investment Adviser.

(c) Voluntary / mandatory termination by the Client.

(d) Expiry of the service period and non-renewal of Services by the Client

(e) Suspension/Cancellation of registration of Investment Adviser by SEBI.

(f) Bankruptcy or liquidation of the Investment Adviser;

(g) Bankruptcy or liquidation of the Client. Any other action taken by other regulatory body/ Government authority.

2. The Parties may by mutual consent terminate this Agreement.

3. In case of a voluntary termination of the agreement, either Party may terminate this Agreement by giving a prior written notice of thirty (30) days to the other Party and on the expiry of such notice period, the Agreement shall stand terminated. However, the Client will be liable to pay the fees for the notice period of the Agreement.

4. In case of suspension of the certificate of registration of the IA, the Client may be provided with the option to terminate this Agreement with prior intimation to the Investment Adviser.

XIV.  Implications of amendments and termination

a. In case of amendments in the Agreement not accepted by Client, the Client can opt for termination of agreement.

b. In case of pre-mature termination of the Agreement, the fee be refunded for the unexpired period. However, the Investment Adviser will retain a maximum breakage fee of not greater than fee for one quarter.

c. This Agreement shall not be assigned by either party without the other party’s prior written consent.

d. Both the parties agree to fulfil the obligations prior to termination of the Agreement.

e. The Investment Adviser agrees to provide support for transition to avail services of any other intermediary.

XV.  Relationship with related parties:

The Investment Adviser hereby declares that it is carrying on such activities independently, at an arms-length basis with its related parties. The Investment Adviser further declares that a disclosure in case of any conflicts will be made to the Client at all times.

XVI.  Investment Adviser engaged in other activities:

a. The Investment Adviser shall ensure that the other activities shall be carried out at arms-length basis.

b. The Investment Adviser is not registered with AMFI, IRDA or any other SEBI Intermediaries

c. The Investment Adviser hereby represents that it does not have any group company and in future will not provide investment advisory services, for securities and investment products, either directly or through their its group to the distribution Client.

XVII. Representation to Client:           

The Investment Adviser will ensure that it will take all the necessary consents and permissions from the Client prior to undertaking any actions in relation to the securities or investment product advised by the Investment Adviser.

XVIII. No right to seek Power of Attorney:

The Investment Adviser hereby declares that it shall not seek any power of attorney or authorizations from its clients for implementation of investment advice.

XIX. No conflict of interest:

a. The Investment Adviser shall disclose all conflicts of interest as and when they arise and not derive any direct or indirect benefit out of the Client’s securities/investment products.

b. The Investment Adviser shall ensure that it shall disclose to the client any 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 investment advisory services.

c. The Client has perused and understood the disclosures made by the Investment Adviser in Annexure B.

XX. Maintenance of accounts and confidentiality:

a. The Investment Adviser shall be responsible for maintenance of the Client accounts and data as mandated under the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013 and maintain confidentiality of such data and information.

b. The Client agrees that the Investment Adviser has right to disclose the Confidential Information of the Client without his permission where such disclosure is required to be made in compliance with any securities opted by the Client or any law for the time being in force or requested by any Government authority.

XXI. Terms of fees and billing:

(i) The fee shall be billed in advance at the beginning of each quarter.

(ii) The first quarter fee will be due from the date of execution of this Agreement. Thereafter, the fees for the subsequent quarters will be due after the end of three months period from the date of the agreement.

(iii) An invoice will be raised by the Investment Adviser on each due date and the fee shall be paid within 15 days of date of invoice.

(iv) The Client shall provide the Deposit Slip or UTR reference number or transaction reference number for online payment or an email confirmation evidencing payment of fee. An email will be sent to the client confirming receipt of fees.

(v) The fees is exclusive of all taxes and subject to tax deducted at source as may be applicable under the Income Tax Act, 1961.

(vi) Illustration(s) on how the fee will be determined:

Considering a case whereby a client enters into an agreement with the Adviser on April 1, 2023. The first instalment will be due on April 1, 2023 for which an invoice will be raised by the end of day and the client will have to pay the fee before April 15, 2023. The subsequent fee instalment shall be due on the first day of each subsequent 3-month period from the last fee date and will be generated on the last day of that period.

(for AUA)

(for Fixed)

(vii) In case of any delay beyond 15 days, the Services will be suspended. Further, if the dues are not cleared within 30 days from the date of receipt of the invoice, this Agreement shall stand terminated. An email will be sent to the registered email Id of the Client intimating the suspension of Services or termination of the Agreement as the case may be.

(viii) The payment of fees shall be through any of the mode i.e. account payee crossed cheque/ Demand Drafts or by way of direct credit to the bank accounts through NEFT/ RTGS/ IMPS/ UPI or any other mode specified by SEBI from time to time. However, the fees shall not be accepted in cash.

XXII. Liability of Investment Adviser

a. The Client hereby agrees that the Investment Adviser shall not incur any liability by reason of any loss, which the Client may suffer by reason of any depletion in the value of the assets under advice, which may result by reason of fluctuation in asset value, or by reason of non-performance or under-performance of the securities/funds or any other market conditions.

b. The Investment Adviser will not be liable to Client for:

(i) any loss that Client may suffer by reason of any investment decision made or other action taken or omitted in good faith by Adviser; or

(ii) any act or failure to act by the third party/ intermediary referred to the client by the Investment Adviser.

c. Neither the Investment Adviser nor its Partners, Principal Officer and employees warrant accuracy of the investment advice and disclaim all liabilities, which may arise from the investment advice.

XXIII. Indemnities

Without prejudice to the right of indemnity available to the Investment Adviser under any law, the Client agrees to indemnify and hold the Investment Adviser harmless to the full extent against:

(a) any and all lawful claims, losses, damages, liabilities, costs and expenses as incurred in connection with investigation of, preparation for and defence of any pending or threatened claim and any litigation or other proceeding arising out of or related to any actual or proposed acts done or not done or the Investment Adviser ‘s engagement hereunder.

(b) For any negligence/mistake or misconduct by the Client.

(c) For any breach or non-compliance by the Client of the rules/terms and conditions stated in this Agreement.

XXIV. Representations and covenants:

The Client hereby represents, warrants, declares and undertakes to the Investment Adviser as under:

a) The Client has legal capacity and authority to execute, deliver and perform this Agreement and has taken all necessary permissions and consents (corporate, statutory, contractual or otherwise) and agree to maintain them throughout the validity of the Services;

b) This Agreement has been duly executed and delivered by the Client and constitutes a legal, valid and binding obligation on the Client, enforceable against the Client in accordance with its terms;

c) The Client has read and understood the Agreement and is aware of all the risks associated with the nature of the Services and the transaction contemplated under the Agreement, whether set out in the Agreement or not, and shall not hold the Investment Adviser and/or any person appointed by it, responsible for the same;

d) The Client is executing this Agreement in his own interest and there is no beneficial or any third party interest involved;

The Investment Adviser hereby represents warrants and declares as under:

a) The Investment Adviser has legal capacity and authority to execute, deliver and perform this Agreement and has taken all necessary permissions and consents (corporate, statutory, contractual or otherwise) and agree to maintain them throughout the validity of the Services.

b) This Agreement has been duly executed and delivered by the Investment Adviser and constitutes a legal, valid and binding obligation on the Investment Adviser, enforceable against it in accordance with these terms.

c) Principal Officer and persons associated with the investment advice fulfil the qualification and certification requirements under regulation 7 of IA Regulations.

d) The Investment Adviser shall intimate the Client of any inquiry or investigation by any government authority including SEBI before or during the course of the Agreement. In such circumstances, Client reserves the right to terminate the Agreement without giving thirty (30) days written notice.

e) Advise provided by the Investment Adviser on securities are based on internal research methodology, Client’s risk profile and suitability and are not driven by commissions / brokerage / gifts.

f) The Investment Adviser shall endeavour to act in the best interest of the Client.

XXV. Client’s Obligations

a) The Client agrees to provide to the Investment Adviser and its principal officer / persons associated with the investment advice about his financial data, income, expenditure, assets and liabilities, details of the dependent family member whose assets on investment advisory originates from income of the Client and such other information and documents as required by the Investment Adviser from time to time in order to provide Services.

b) It will be the responsibility of the Client to ensure that the data, information and documents are true and accurate and not misleading.

c) The Client agrees to provide such documents as required in order to comply with Know Your Client requirements and procedure and Anti Money Laundering Laws of the Country as specified by SEBI from time to time and its updates thereon.

d) The Client agrees to immediately notify the Investment Adviser, in writing or submit such documents, if there is any change in the information provided by the Client at the time of availing Services and at any time thereafter.

e) The Client agrees that if any information is wrongly provided in the risk profiling questionnaire, then Client is likely suffering from unavoidable risks.

f) The Client expressly agrees to use the Services strictly for his personal use. The Client shall not copy, distribute, transmit, display, publish or create derivative works from, transfer, or sell any information proprietary to the Investment Adviser.

XXVI. Death or Disability of Client:

a. In the event of death or disability of the Client during the currency of the Agreement, and on receipt of notice from the Client or successors/heirs, in writing of such an event, the Agreement shall be terminated.

b. The fees already paid by the Client will not be refunded. However, the legal heirs will not be responsible for the payment of the fees for the remaining period of the agreement.

XXVII. Settlement of disputes and provision for arbitration

a. The Investment Adviser shall not be under any liability on account of anything done or omitted to be done or suffered by the Client in good faith in accordance with or in pursuance of any request or advice of the investments made by the Investment Adviser.

b. The procedure for settlement of disputes is as mentioned in Annexure C.

c. All disputes, differences, claims and questions whatsoever, which may arise either during the subsistence of this Agreement or afterwards between the Parties relating to or arising from these clauses or the interpretation of any provision contained herein shall be in the first place settled by mutual discussions between the parties, failing which the same shall be referred to and settled by arbitration in accordance with and subject to the provisions of the Arbitration and Conciliation Act, 1996 or any statutory modification or re-enactment thereof for the time being in force. The arbitration shall be held in Bhubaneshwar and conducted in English language.

XXVIII. Adherence to grievance redressal timelines:

The Investment Adviser shall be responsible to resolve the grievances within the timelines specified under the SEBI circulars.

XXIX. Severability

If any provision of this Agreement is held or made invalid by a court decision, statute, rule or otherwise, the remainder of this Agreement shall not be affected thereby.

XXX. Force Majeure

The Investment Adviser shall not be liable for delays or errors occurring by reason of circumstances beyond its control, including but not limited to acts of civil or military authority, national emergencies, work stoppages, fire, flood, catastrophe, acts of God, pandemic, epidemic, insurrection, war, riot, or failure of communication or power supply. In the event of equipment breakdowns beyond its control, it shall take reasonable steps to minimize service interruptions but shall have no liability with respect thereto.

XXXI. Intellectual Property

The Investment Adviser shall own all Intellectual Property Rights in respect of all text and data and such other material both electronic & physical, which may form the subject matter of this Agreement provided by it to the Client during the course of this Agreement.

XXXII. Miscellaneous

1. Expenses: Each of the Parties hereto shall bear its own expenses, including fees and expenses of any attorneys, accountants, consultants, investment bankers, brokers, finders or other persons or entities engaged by it, and incurred in connection with this Agreement and the transactions contemplated hereby.

2. Notices: All notices required or permitted, hereunder shall be in writing and in the English language and shall be sent by a nationally / internationally recognized courier or by registered post addressed to the address of each Party set forth in the agreement above, or to such other address as such other Party shall have communicated to the other Party in writing.

Details of the Investment Adviser:

Name: Coinwise Research Private Limited (Non-individual Investment Adviser)

Address: 1003, 10th Floor, Tower B, Emerald Estate Apartments, Sector 65, Haryana, Gurgaon, 122001

Name of the Principal Officer: Mr. Rohit Prakash

Email: rohit.prakash@coinstreet.in

Contact no.: +91 9971016795

Details of the Client: As mentioned in Annexure A

3. Remedies: No remedy conferred by any of the provisions of this Agreement is intended to be exclusive of any other remedy which is otherwise available at law, in equity, by statute or otherwise, and each and every other remedy given hereunder or now or hereafter existing at law, in equity, by statute or otherwise except as stated to the contrary in this Agreement. The election of any one or more of such remedies by any of the Parties hereto shall not constitute a waiver by such Party of the right to pursue any other available remedy except as aforesaid.

4. Entire Agreement: This Agreement, and the Schedules, Annexures and Appendices hereto constitute the entire agreement between the Parties as to the subject-matter hereof and supersede any and all prior understandings between the Parties on the subject-matter hereof.

5. Counter parts: In the event this Agreement is executed in several counter parts, each of the Parties may execute one or more counter parts and the counter parts so executed shall constitute one Agreement and be binding on the Parties, as if they had all executed the same document. This Agreement shall be deemed to have been entered into at such time, as all the Parties hereto have signed a counter part of it.

6. Waiver: Save where this Agreement expressly provides, neither Party shall be deemed to have waived any right, power, privilege or remedy under this Agreement unless such Party shall have delivered to the other Party a written waiver signed by an authorised officer of such waiving Party. No failure or delay on the part of either Party in exercising any right, power, privilege or remedy hereunder shall operate as a waiver, default or acquiescence thereof, nor shall any waiver on the part of either Party of any right, power, privilege or remedy hereunder operate as a waiver of any other right, power, privilege or remedy, nor shall any single or partial exercise of any right, power, privilege or remedy hereunder preclude any other or further exercise thereof or the exercise of any other right, power, privilege or remedy hereunder.

7. The Parties undertake and agree not to act as agent or representative of the other Party.

8. Each Party agrees to perform such further actions and execute such further agreements as are necessary to effectuate the purposes hereof.

XXXIII.  Governing Law and Jurisdiction

This Agreement will be governed by the Laws of India and any disputes arising herein shall be subject to the exclusive jurisdiction of the Courts of Gurgaon, Haryana.

IN WITNESS whereof this Agreement has been entered into by the Parties on the date appearing above as the date of this Agreement.

For Coinwise Research Private Limited	For Client:
Name:  Rohit Prakash Designation: Director

The Investment Adviser shall provide Investment Advisory Services in compliance with SEBI guidelines, covering Equities, Bonds, Gold, ETFs, Mutual Funds, and REITs.

About the Company:

Coinwise Research Private Limited (herein referred to as the Company) is a Private Limited Company registered under the Companies act, 2013, having its registered office at Flat No 1603, Almond B, Omaxe Residency 2, Arjunganj, Lucknow, Uttar Pradesh, 226002 and Branch office at 1003, 10th Floor, Tower B, Emarald Estate Apartments, Sector 65, Gurgaon, 122002.

The Company was incorporated on 14th October, 2022.

The Company got registered with SEBI as an investment adviser on 23rd August 2023 and is valid till perpetual (Reg No: INA000018382).

About the Directors:

The details of the Directors are as follows:

1. Mr. Rohit Prakash is an Engineer Graduate from IIT Kanpur and MBA from IIM Calcutta. He has also done CFA Level 1 and FRM Level 1. He has over 9 years of work experience with standard Chartered Bank and has worked in multiple areas including Corporate Finance, Equity Capital Markets and Commercial Real Estate.

2. Mr. Puru Verma is a Computer Science graduate from NIT Trichy and holds MBA from IIM Calcutta. Puru has over 10 years of experience with pharmaceutical companies in India and UAE. He has worked in various roles including sales, strategic projects, investor relation and M&A.

About Business activities:

The Company offers Investment Advisory Services in compliance with SEBI guidelines, covering Equities, Bonds, Gold, ETFs, Mutual Funds, and REITs. Our core services comprise “Model Portfolio” offerings, personalized investment advisory services, and research services. We regularly release market reports, earnings-based analyses, sector reports, and related information. Additionally, educational content is disseminated through our website and social media channels.

Disciplinary History:

There are no outstanding litigations or no disciplinary history against the Company and its Directors.

Disclosure about conflict of interest:

The Company is not registered with AMFI, IRDA or any other SEBI Intermediaries.

Disclosure about holding position of the Company and the Directors:

The Company and the Directors may have a holding position in the same financial products and securities which are subject matter of advice given to the clients.

Other Disclosure:

The Company shall provide execution services only through direct schemes /products in the market. Mr. Rohit Prakash, Principal Officer and the person associated with the Investment Advice shall be responsible for providing implementation services. However, the Company will not receive any consideration for the execution services.

The distribution and implementation / execution services shall be carried on through a separate identified department/division and shall be arm’s length with all the advisory clients. The compliance requirements for client level segregation will be followed by the Company at all times.

Here are the steps a client can follow in case of grievance or feedback:

1. If you are not satisfied with our services and would like to lodge a complaint, we would request you to first talk to our representative / consultant from the Investment Advisers Department who is your point of contact. You can discuss with him / her, and be rest assured that your complaint will be resolved on best efforts within 15 working days.

2. You can also email or talk to the representative / consultant via telephone. The contact no. is

a)  Name: Mr. Rohit Prakash

   Email: rohit.prakash@coinstreet.in

   Phone: +91 9971016795

3. We will try to resolve your complaint within 15 to 30 working days. The first step is for us to be clear about the nature of your complaint, and to identify what we can do to resolve the issue. When we have finished our investigations into your complaint, we will be in touch to provide you with a full response to your complaint.

4. If your complaint is not resolved within a period of one month, you may refer your complaint to the regulator – The Securities and Exchange Board of India (SEBI).

Nodal SEBI office: IDCOL House, Ashok Nagar, Unit – II, Bhubaneswar – 751009, Odisha

5. SEBI has launched a centralized web-based complaints redress system ‘SCORES’.

The link to the platform is https://scores.gov.in/scores/complaintRegister.html#

6. If your complaint is not resolved on SCORES portal, you can start the dispute resolution process through the ODR Portal. The link for the platform is https://smartodr.in/login.