Compliance & Disclosures

Annexure A — Most Important Terms and Conditions

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).
   • 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 quarter. 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: +91 62666 59514 · info@posaresearch.com.
    • Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through SEBI's SCORES platform at scores.sebi.gov.in.
    • Step 3: The client may also consider the Online Dispute Resolution (ODR) through the Smart ODR portal at 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.

Annexure B — Disclosure of Mandatory Terms and Conditions

In compliance with the SEBI circular dated 8 January 2025, RAs are required to maintain records of interactions with all clients (including prospective clients prior to onboarding), where any conversation related to its services has taken place, in the form of:

1. Physical record written & signed by client
2. Telephone recordings
3. Email from registered email id
4. Record of SMS messages
5. Any other legally verifiable record

Such records begin with the first interaction and continue till the completion of research services. RAs are required to maintain these records for five years; in case a dispute is raised, records are maintained till resolution, or as further specified by SEBI.

Standard Terms of Service

The consent of client shall be taken on the following understanding:

"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 benefit and consumption, and any reliance placed on the research report provided by the 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 is 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."

Declarations by the RA

• The RA is duly registered with SEBI under the SEBI (Research Analysts) Regulations, 2014. Registration number: INH000023579; registration date: 10 October 2025. BSE Enlistment No.: 7112.
• The RA holds the registration and qualifications required to render the services contemplated under the RA Regulations, and the same are valid and subsisting.
• The Research Analyst services do not conflict with or violate any provision of law, rule or regulation, contract, or other instrument to which the RA is a party.
• The maximum fee that may be charged by the RA is ₹1,51,000 per annum per family of client (for individual / HUF clients).
• Recommendations provided by the RA do not provide any assurance of returns.
• The RA is not engaged in any additional professional or business activities, on a whole-time basis or in an executive capacity, which interfere with or have the potential to interfere with the independence of research reports and / or recommendations.

Termination & refund

The RA may suspend or terminate research services on account of suspension or cancellation of registration of the RA by SEBI, and shall refund the residual amount to the client. In case of cancellation by the client, NIL refund shall be provided. In case of suspension of the RA's certificate of registration for more than 60 days, or cancellation of the RA registration, the RA shall refund fees on a pro-rata basis for the period from the effective date of cancellation / suspension to the end of the subscription period.

Mandatory notice — Do's and Don'ts

Clients are requested to go through the Do's and Don'ts while dealing with an RA, as specified in SEBI master circular SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated 21 May 2024, or as may be specified by SEBI from time to time.

Disclosure

Investment in securities market are subject to market risks. Read all the related documents carefully before investing.

Recommendations issued by Posa Research Analyst are prepared on the basis of technical analysis and other studies by Research Analyst Nishant Shukla (SEBI Reg. No. INH000023579). SEBI registration does not guarantee any profit or returns. Investing is subject to market risks. Please read all related information carefully and consider consulting a financial advisor before trading.

Disclaimer

Investment in securities market are subject to market risks. Read all the related documents carefully before investing.

I, Nishant Shukla, am an active individual SEBI-registered Research Analyst. Neither the analyst nor SEBI registration guarantees any profits. Investments in financial markets are subject to market risks; please consult your financial advisor as appropriate.

Segments covered

Equity Cash · Equity Futures · Equity Options · Non-Agri Commodities (MCX) · Agri Commodities (NCDEX)

Clients can seek clarification or raise complaints in writing, by email, or by phone:

• Email: info@posaresearch.com
• Phone: +91 62666 59514
• Registered Office Address: Shop No. M-26, 2nd Floor, Mapple High Street, Narmadapuram Road, Bhopal, Madhya Pradesh, India

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

If the client is not satisfied with the response, they may lodge a grievance with SEBI through the SCORES portal at scores.sebi.gov.in or write to the office of SEBI directly.

After exhausting the above options, if the investor is still not satisfied with the outcome, they can initiate dispute resolution through the ODR portal. For details on the ODR mechanism, fees and timelines, please visit smartodr.in.

Compliance Officer

• Name: Nishant Shukla
• Phone: +91 62666 59514
• Email: info@posaresearch.com

All sales are final, and we do not offer refunds for the paid period of services already availed by the client. Complaints or dissatisfaction regarding the quality of services during the paid period shall not entitle the client to any refund or compensation.

As per SEBI guidelines, if a client requests to cancel the subscription, a refund shall only be issued for the unused portion of the subscription period. The refund will be calculated on a pro-rata basis, deducting the charges for the services already availed, including applicable taxes and administrative fees.

Refunds will not be provided for the period of services already availed, irrespective of the client's satisfaction with the recommendations or the outcome of trades. Investments in securities markets are subject to market risks. Profits and losses incurred due to the use of our recommendations are solely the responsibility of the client.

By subscribing to our services and making payment, the client acknowledges that they have read, understood, and agreed to the refund policy, as well as the disclaimer, disclosure, and other terms mentioned on this website.

For any questions regarding the refund policy, contact info@posaresearch.com.

At Posa, we value your privacy and are committed to protecting your personal information. This policy outlines how we collect, use, and safeguard your data.

• Information collection: We collect information when you register, subscribe or interact with our services, including name, contact details and financial preferences.
• Use of information: Your information is used to provide research services, process subscriptions, and improve client experience.
• Data protection: We implement reasonable security measures to protect your data from unauthorised access.
• Third-party disclosure: We do not sell or trade your information. Data may be shared with regulators where required by law, or with trusted partners under strict confidentiality.
• Cookies: We use cookies to improve website functionality and user experience.
• Your rights: You can access, update, or request deletion of your information by writing to us.

For any concerns, contact info@posaresearch.com.

The Prevention of Money Laundering Act, 2002 (PMLA) is an Indian law enacted to combat the offence of legalising income or profits from an illegal source. The Act enables government authorities to confiscate property and / or assets earned from illegal sources or through money laundering. The burden of proof lies with the accused, who must prove that the suspect property or assets have not been obtained through proceeds of crime. The PMLA provides for Anti-Money Laundering and Anti-Terrorist Financing measures to be taken in India.

Stayvan complies with all applicable PMLA obligations, including KYC verification, record-keeping, and reporting of suspicious transactions where required.

It has come to our attention that fraudulent individuals sometimes misuse the SEBI registration numbers, Aadhaar, PAN and GST numbers of registered Research Analysts to defraud investors.

Such actions are not connected to Posa in any way, and Nishant Shukla does not authorise anyone to act on his behalf or use his personal or professional details under any circumstances.

How to protect yourself

• Verify credentials: Interact with Posa only through the official channels listed on this site.
• Be cautious: Treat unsolicited calls, messages or emails claiming to represent Posa with caution.
• Check SEBI's records: You can verify SEBI registration and other official details on the SEBI website or by contacting SEBI directly.
• Never share credentials: Posa will never ask for your trading-account, demat or bank-account login or OTP.

How to file a complaint

1. Inform Posa directly by phone +91 62666 59514.
2. Visit the SEBI Complaint Redress System (SCORES) at scores.sebi.gov.in and register or log in.
3. File the complaint with all relevant details about the fraudulent activity.
4. Attach any supporting documents that could help SEBI investigate.

You can also contact SEBI's official helpline on 022 2644 9000 or by email at sebi@sebi.gov.in.

Annual audit reports as required under the SEBI (Research Analysts) Regulations, 2014. The most recent reports are available on request — please contact info@posaresearch.com.

PDF links to the most recent audit reports will be added here as each cycle is published.