Empower Your Trading & Investing Journey

1. Purpose

The purpose of the document is to provide essential information about the Research Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging in Research services before onboarding.

2. History, Present Business, and Background

Sidharth Rajput is registered with SEBI as Research Analyst with registration no. INH000016612. The Research Analyst offers research and recommendation services under the brand name The Stock Savvy.

3. Terms and Conditions of Research Services

The Research Services will be limited to providing independent research recommendations and shall not be involved in any advisory or portfolio allocation services.

The Research Analyst never guarantees the returns on the recommendation provided. Investor shall take note that Investment/trading in stocks/Index or other securities is always subject to market risk. Past performance is never a guarantee of same future results.

The Research Analyst shall not be responsible for any loss to the Investors.

4. Disciplinary History

• There are no pending material litigations or legal proceedings against the Research Analyst.
• As on date, no penalties / directions have been issued by SEBI under the SEBI Act or Regulations made thereunder against the Research Analyst relating to Research Analyst services.

5. Details of Associates

No associates

6. Disclosures with Respect to Research and Recommendations Services

• The Research Analyst or any of its officer/employee does not trade in securities which are subject matter of recommendation.
• There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/securities.
• Research Analyst or its employee or its associates have not received any compensation from the company which is subject matter of recommendation.
• Research Analyst or its employee or its associates have not managed or co-managed the public offering of any company.
• Research Analyst or its employee or its associates have not received any compensation for investment banking or merchant banking or brokerage services from the subject company.
• Research Analyst or its employee or its associates have not received any compensation for products or services other than above from the subject company.
• Research Analyst or its employee or its associates have not received any compensation or other benefits from the Subject Company or 3rd party in connection with the research report/recommendation.
• The subject company was not a client of Research Analyst or its employee or its associates during twelve months preceding the date of recommendation services provided.
• Research Analysts or its employee or its associates has not served as an officer, director or employee of the subject company.
• Research Analysts has not been engaged in market making activity of the subject company.

1. Complaints for the Month (Ending March 2026)

2. Trend of Monthly Disposal of Complaints

3. Trend of Annual Disposal of Complaints

1. Contact for Queries and Complaints

Clients can seek clarification to their query and are further entitled to make a complaint in writing, orally or telephonically. An email may be sent at info@thestocksavvy.com

Alternatively, the Investor may call on: +91 9039165557

A letter may also be written with their query/complaint and posted at the below mentioned address:

The Stock Savvy Office
10 A Friends CHS, Advance Builder Compound,
Sakinaka, Kherani Road,
Mumbai, MH, 400072

The client can expect a reply within 21 days of approaching the Research Analyst.

2. Escalation Process

In case client is not satisfied with our response they can lodge grievance with SEBI at http://scores.gov.in or may also write to the office of SEBI.

After exhausting the above options for resolution of the grievance, if the investor/client is still not satisfied with the outcome, they can initiate dispute resolution through the ODR Portal.

For more details about the ODR mechanism, fees, timelines etc., you may read the master circular released by SEBI titled: “Online Resolution of Disputes in the Indian Securities Market”

3. Details of Compliance Officer

Name: Sidharth Rajput
Contact No.: +91 9039165557
Email: info@thestocksavvy.com

4. Contact Details

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

• To publish research report based on the research activities of the RA.
• To provide an independent unbiased view on securities.
• To offer unbiased recommendation, disclosing the financial interests in recommended securities.
• To provide research recommendation, based on analysis of publicly available information and known observations.
• To conduct 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: Material information, business activity, disciplinary history, terms & conditions, associates, risks, conflicts of interest, etc.
• To distribute research reports and recommendations without discrimination.
• To maintain confidentiality and respect data privacy rights of clients.
• To treat all clients with honesty and integrity.
• To provide clear guidance and caution notice for complex/high-risk products.

D. Details of Grievance Redressal Mechanism

1. Lodge complaint with Research Analyst: Approach the Research Analyst — redressal within 21 days.

2. Lodge on SCORES: Escalation to SCORES 2.0 at https://scores.sebi.gov.in.

3. SMARTODR Platform: For online conciliation or arbitration if not satisfied.

Physical complaints may be sent to: 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 Fair & True Advertisement.
• Right to be Heard and Satisfactory Grievance Redressal.
• Right to Exit from Financial product or service.
• Right to clear guidance on Complex & High-Risk Products.

F. Expectations from the Investors (Responsibilities of Investors)

1. Parties

Research Analyst: Sidharth Rajput, SEBI Registered Research Analyst (Registration No. INH000016612) operating under the brand name The Stock Savvy.

Client/User: Any individual or entity subscribing to or availing research services and meeting eligibility under Indian law.

2. Purpose

These Terms & Conditions govern your use or subscription to our research services, including Digital Platforms.

• Incorporates SEBI circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 dated January 08, 2025.
• SEBI guidelines override these T&C in case of conflict.

3. Definitions

• Client/User: Any registered person or entity.
• Services: Research reports, data, model portfolios, and advisory recommendations.
• Digital Platform: Any technology used for delivery of research recommendations.
• KYC: Know Your Customer verification.

4. Scope of Services

• Research-Only: No trade execution, fund handling, or guaranteed returns.
• Model Portfolios: Informational recommendations only.
• AI Usage: We remain accountable for AI-supported content.
• No Guarantees: Investments carry market risk.

5. Eligibility

• Legal Capacity: Must be 18+ and legally competent.
• KYC: Must provide accurate KYC info. Incomplete/false KYC may lead to termination.

6. Registration & Accounts

• Complete registration and accept T&C.
• Keep credentials confidential and report breaches.
• Unauthorized use of content may result in legal action.

7. Fees & Payment

• Max Fee: INR 1,51,000/year per family for individuals/HUFs.
• Non-Individual Clients: Fees negotiable.
• Billing: Quarterly or as agreed; CeFCoM optional.
• Modes: UPI, NEFT, Netbanking, Credit Cards.
• Refunds: Pro-rata for unused duration; no penalty.
• Renewals: Max fee specified; RA may offer lower price.

At The Stock Savvy, we are committed to delivering high-quality research recommendation services with transparency and fairness, in compliance with the Securities and Exchange Board of India (SEBI) (Research Analysts) Regulations, 2014, and related guidelines. This refund policy outlines the conditions under which refunds may be requested for our paid services, ensuring clarity for our clients and alignment with regulatory standards.

1. Scope of the Refund Policy

This policy applies to all paid services provided by Sidharth Rajput (The Stock Savvy), including but not limited to research reports, research recommendation subscriptions, and related educational materials. It does not cover investment outcomes, as all investments are subject to market risks, and we do not guarantee returns or profits.

2. Eligibility for Refunds

Clients may request a refund under the following circumstances:

1. Non-Delivery of Services: If we fail to deliver the agreed-upon service or platform access within the specified timeframe due to reasons within our control.
2. Cancellation Within Cooling-Off Period: If you cancel your subscription within 3 working days from the date of payment, provided the service has not been accessed, downloaded, or utilized.
3. Premature Termination: If you or the Research Analyst terminates the service before the subscription period expires, you are entitled to a pro-rata refund for the unutilized full months.
4. Persistent Technical Issues: If you encounter technical issues that we cannot resolve within 3 working days despite reasonable efforts.
5. Regulatory Actions: If the Research Analyst's SEBI registration is suspended or canceled.
6. Double Payment or Overcharging: If you are charged twice or overcharged beyond the SEBI-prescribed fee limit.
7. Centralized Fee Collection Mechanism (CeFCoM): Refunds processed through CeFCoM in compliance with SEBI guidelines.

3. Non-Refundable Scenarios

1. Dissatisfaction with Investment Outcomes.
2. Accessed or Utilized Services.
3. Partial Month Usage.
4. Expiry of Cooling-Off Period.
5. Client Breach of Terms.
6. Force Majeure Events.
7. Non-Refundable Fees.
8. Disruptions Beyond Our Control.
9. Enrollment in Education Courses / Training Programs: Once a client enrolls in any Education Course, Training Program, or similar educational offering and is granted access to the course materials, platform, or sessions (in full or in part), no refund shall be issued under any circumstances.

4. Refund Process

Submit a Request via email to info@thestocksavvy.com with your full name, service details, payment reference, and reason.

For premature termination, provide written notice at least 10 working days prior.

We will review within 5 working days and process approved refunds within 10 working days (or 30 days for CeFCoM) to the original payment method.

5. Grievance Redressal

Grievance Officer: Sidharth Rajput

Email: info@thestocksavvy.com

Phone: +91 9039165557

Escalate to SEBI SCORES: https://scores.sebi.gov.in

Introduction

This document outlines the Anti-Money Laundering (AML) Policy of Sidharth Rajput, a SEBI-registered Research Analyst Firm (Registration Number: INH000016612) operating as The Stock Savvy. This policy complies with the Prevention of Money Laundering Act, 2002 (PMLA), its rules, and SEBI guidelines, including the SEBI Circular dated February 17, 2025. It ensures that our operations are not misused for money laundering or terrorist financing activities.

Objective

The objective of this policy is to establish a robust framework for detecting and reporting suspicious transactions while ensuring compliance with applicable laws and regulations. This policy covers:

• Policy for acceptance of clients.
• Procedure for identifying clients.
• Transaction monitoring and reporting, especially Suspicious Transactions Reporting (STR).
• Client Due Diligence (CDD) Process.

Policy for Acceptance of Clients

• No accounts will be opened in fictitious or anonymous names.
• Accounts will not be opened if adequate client due diligence (KYC) measures, including PAN card verification, cannot be applied.
• All clients must be KYC registered and provide valid documentation as mandated by SEBI.
• Client identities will be verified against SEBI’s list of banned persons/entities and stock exchange records.
• Risk assessments will be conducted, including checks against sanctions lists maintained by United Nations Security Council Resolutions.

Procedure for Identifying Clients

• Client identities will be verified using reliable sources to ensure accurate and complete KYC details, including PAN card and address proof.
• Any discrepancies in documentation will be escalated to the Compliance Officer for resolution.
• Client records will be updated regularly to comply with SEBI’s requirement for KYC updates.

Maintenance of Records

All client records, including KYC documents and transaction details, will be maintained for a minimum of 10 years or until the resolution of any regulatory action, as per SEBI and PMLA guidelines. Records will be securely stored at the registered office address.

Monitoring and Reporting of Transactions

Monitoring Transactions: Transactions involve service fees accepted only through banking channels. No cash transactions are permitted. All transactions are monitored for suspicious patterns.

Reporting Suspicious Transactions: Suspicious transactions are reported to the Compliance Officer and then to FIU-IND. Confidentiality is maintained.

Roles and Responsibilities

Principal Officer: Sidharth Rajput

Contact: +91 9039165557 | info@thestocksavvy.com

Onboarding Staff: Adhere to KYC/CDD procedures and report suspicious activity.

Communication of Policy • Compliance • Review • Business Hours

The policy is communicated to all staff with annual training and is available on the website.

We ensure full compliance with SEBI, PMLA and cooperate with authorities. Grievances are resolved within 21 days.

The policy is reviewed annually or as required.

Business Hours:
Monday – Friday: 9:00 AM – 6:00 PM
Saturday: 10:00 AM – 2:00 PM
Sunday: Closed