Smarter Investing Starts With Trusted Research

• The particulars given in this Disclosure Document have been prepared in accordance with SEBI (Research Analysts) Regulations, 2014.
• itemThe purpose of this document is to provide essential information about the Research and Recommendation services to help clients make informed decisions before engaging in such services.
• item For the purpose of this Disclosure Document, the "Research Analyst" refers to Bhupendra Kumar Kushwaha.

Descriptions about “Research Analyst”

History, Present business and Background:

• Research Analyst is registered with SEBI with Registration No. INH000022604. The Analyst got its registration on 07th August, 2025 and is engaged in research and recommendation Services.
• The focus of Research Analyst is to provide research and recommendations services to the clients. Analyst aligns its interests with those of the client and seeks to provide well researched services.

Terms and conditions of Research and Recommendation Services:

• Terms and conditions of Research and Recommendation Services are detailed in the terms and condition document. Please refer to the same for details

Disciplinary history:

• There are no pending litigations, legal proceedings, regulatory actions, or disciplinary events reported against the Research Analyst, its associates, or relatives.

Details of Associates

• There are no associates linked with the Research Analyst.

Disclosures with respect to Research and Recommendations Services:

• The Research Analyst or relatives may hold financial interest or beneficial ownership of one percent or more in securities recommended. Any such details shall be disclosed during the time of recommendation.
• There are no conflicts of interest that may compromise independence or objectivity in research activities. Should any arise, they will be promptly disclosed.
• The Research Analyst or relatives have no material association with any issuer of securities recommended.
No compensation is received from any company for providing research recommendations.
• The Research Analyst has not managed or co-managed any public offerings in the last 12 months.
• No compensation has been received for investment banking or brokerage services from the subject company in the last 12 months.
• The subject company is not a client of the Research Analyst or associates.
• The Research Analyst does not serve as an officer, director, or employee of the subject company.
• The Research Analyst does not engage in market-making activities for the subject company.

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. Business Transacted by the Research Analyst

• Publish research reports based on research activities of the Research Analyst.
• Provide an independent and unbiased view on securities.
• Offer recommendations while disclosing any financial interest in recommended securities.
• Provide research recommendations based on publicly available information and analysis.
• Conduct annual audits.
• Ensure compliance of advertisements with the Advertisement Code for Research Analysts.
• Maintain records of client interactions, including prospective clients.

C. Details of Services Provided to Investors

• Sharing terms & conditions of research services and completing KYC (for fee-paying clients).
• Disclosing all material information, risks, conflicts of interest, business activities and disciplinary history.
• Distributing research reports and recommendations without discrimination.
• Maintaining confidentiality until research is made public.
• Protecting clients’ personal and confidential data.
Providing cautionary guidance when recommending high-risk or complex instruments.
• Ensuring timelines for services are communicated and followed.

D. Grievance Redressal & Escalation Mechanism

• If you have a grievance, you may first contact the Research Analyst. The grievance shall be addressed within 21 working days.
• SCORES Portal (SEBI online grievance system): https://scores.sebi.gov.in
• SMART ODR (For Online Dispute Resolution): https://smartodr.in
• RAASB (Supervisory Body): Complaints reviewed first by RAASB, then SEBI if unresolved.
Physical Complaint Address: Office of Investor Assistance and Education, 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 & Fair Practices.
• Right to Adequate and True Information.
• Right to Grievance Redressal within stipulated timelines.
• Right to exit services as per agreed terms.
• Right to caution notices on high-risk recommendations.
• Right to provide feedback.

F. Responsibilities of Investors

Do's:

• Deal only with SEBI registered Research Analysts.
• Check SEBI registration number before engaging.
• Make payments only through banking channels and keep receipts.
• Read disclosures before acting on recommendations.
• Ask questions and seek clarity when in doubt.
• Report any misleading or guaranteed return claims to SEBI.

Don'ts:

• Do not hand over funds for investment to the Research Analyst.
• Do not fall for promises of assured profits or limited-time offers.
• Do not share your trading or banking login credentials.

Grievance Redressal Policy

Step 1 — Contact Us Directly

Step 2 — Escalate to SEBI SCORES

Step 3 — Online Dispute Resolution

Physical Address

Important Note

Privacy Policy – Dhan Research

1. Information We Collect

• Personal Information: Name, email address, phone number, address, PAN/KYC details, and other personal details that you provide when subscribing to our services, or contacting us.
• Financial Information: Payment details required for processing subscriptions and transactions. We do not store your complete card/bank details — payments are processed through secure, RBI-approved third-party payment gateways.
• Technical Information: IP address, browser type, operating system, device information, and data collected through cookies and similar technologies.

2. Use of Information

• To provide and improve our research services.
• To communicate with you regarding updates, services, subscription renewals, and inquiries.
• To process payments for subscriptions and other services.
• To manage and resolve grievances in accordance with SEBI's investor grievance redressal framework.
• To comply with SEBI, BSE, and other applicable legal and regulatory requirements, including record-keeping obligations under SEBI (Research Analysts) Regulations, 2014.
• To verify client suitability and maintain KYC records as mandated by SEBI.

3. Disclosure of Information

• With Regulatory Authorities: As required by SEBI, BSE, or other relevant regulatory/statutory authorities, including in response to audits, inspections, or investor grievance proceedings.
• With Service Providers: We may share information with trusted service providers who assist us in delivering our services, including payment processors, IT/hosting service providers, and communication (SMS/WhatsApp/email) service providers.
• For Legal Compliance: We may disclose your information if required by law, court order, or regulatory directive, or to protect the rights, property, or safety of Dhan Research, Bhupendra Kumar Kushwaha, its clients, or others.
• We do not sell, rent, or trade your personal information to any third party for marketing purposes.

4. Data Security

• We implement industry-standard security measures — including encryption, access controls, and secure servers — to protect your personal information from unauthorized access, disclosure, alteration, or misuse. ----- While we strive to protect your data, please note that no method of transmission over the internet or electronic storage method is 100% secure, and we cannot guarantee absolute security.

5. Cookies and Tracking Technologies

• Our website uses cookies and similar tracking technologies to enhance your browsing experience, understand user behavior, improve our website, and deliver relevant content. You can control or disable cookies through your browser settings; however, this may affect certain website functionalities.

6. Your Rights

• Access: You may request access to the personal information we hold about you.
• Correction: You have the right to correct any inaccuracies in your information.
• Deletion: You may request deletion of your personal information, subject to statutory record-retention requirements under SEBI regulations.
• Opt-out: You can opt out of receiving marketing/promotional communications from us at any time.
• To exercise any of these rights, please contact us at support@dhanresearch.com

7. Data Retention

• We retain your personal and transaction information for the period mandated under SEBI (Research Analysts) Regulations, 2014 and other applicable laws (currently a minimum of 5 years, or longer if required by ongoing regulatory or legal proceedings), after which it is securely deleted or anonymized.

8. Third-Party Links

• Our website may contain links to third-party websites.
• Dhan Research and Bhupendra Kumar Kushwaha are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

9. Changes to this Privacy Policy

• We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal/regulatory obligations. Any updates will be posted on this page along with the date of the latest revision. Continued use of our website/services after such changes constitutes acceptance of the updated policy.

Acceptance of Terms

Use of Website

• Unlawful purposes or in violation of any applicable laws.
• Distributing malicious code or disrupting website security.
• Impersonating Dhan Research or its representatives.

Intellectual Property

All content — research reports, logos, text, and graphics — is the intellectual property of Dhan Research and is protected under applicable IP laws. No reproduction, redistribution, or modification is permitted without prior written consent.

Limitation of Liability

Dhan Research shall not be liable for any direct, indirect, incidental, or consequential damages arising from:
• Errors or omissions in research content.
• Unauthorized access to or alteration of your data.
• Any investment losses based on our research recommendations.

Governing Law

Termination

CLIENT ONBOARDING CHECKLIST – DHAN RESEARCH

1 — Pre-Onboarding (Before any service begins)

• 1.1 Direct prospective client to check RA's SEBI registration status independently.
• 1.2 Provide prospective client with Disclosure Document (business activity, fee structure, conflict-of-interest policy)
• 1.3 Ensure no research service is rendered and no fee is charged before Steps 2–4 below are completed
• 1.4 Do not promise, hint at, or imply assured/fixed/guaranteed returns at any stage of the sales conversation
• 1.5 Clearly state that RA services are research/recommendation only — not PMS, not portfolio advisory, not trade execution

2 — KYC (Know Your Client)

• 2.1 Collect KYC: full name, PAN, address proof, contact details (mobile + email), signature
• 2.2 Verify PAN and basic KYC through KRA (KYC Registration Agency) records where applicable
• 2.3 Record client's declared purpose of availing research services (self-use, own investment decisions)
• 2.4 Maintain KYC records for a minimum of 5 years (physical or digitally signed electronic form)
• 2.5 Capture and record family/group mapping of the client (for fee-cap monitoring under ₹1,51,000/family/annum)

3 — Disclosure & Consent (MITC)

• 3.1 Share the full Terms & Conditions document (including MITC as Annexure) with the client.
• 3.2 Obtain explicit, recorded client consent on the MITC — physical signature, digital signature, DigiLocker Aadhaar e-sign, or other legally acceptable/traceable mode.
• 3.3 Do NOT render any service until consent is received.
• 3.4 Retain proof of consent (signed copy / e-sign audit trail / recorded email) as part of client record.
• 3.5 For existing clients not yet covered under MITC, send MITC immediately via email/traceable mode (original SEBI deadline was June 30, 2025 — treat as overdue if pending)

4 — Fee Collection

• 4.1 Confirm fee does not exceed ₹1,51,000 per annum per family (individual/HUF clients only; excludes statutory charges)
• 4.2 Collect fees only via cheque, NEFT/RTGS/IMPS, UPI, or CeFCoM (BSE's Centralized Fee Collection Mechanism)
• 4.3 Never accept cash payment for research services

5 — Service Delivery

• 5.1 Every research report/recommendation includes RA name, SEBI Reg. No., and relevant disclosures (conflict of interest, holdings, etc.)
• 5.2 Maintain arm's length between research activity and any other business activity, if applicable
• 5.3 Never request client's Demat/Trading/Bank account login credentials or OTPs, at any point during service
• 5.4 Do not offer PMS, Demat handling, profit-sharing, or loss-recovery schemes at any stage

Terms & Conditions – Dhan Research

1. About the Research Analyst

• 1.1 Bhupendra Kumar Kushwaha, trading as "Dhan Research," is registered with the Securities and Exchange Board of India (SEBI) as an Individual Research Analyst under Registration No. INH000022604, and is enlisted with BSE under Enlistment No. 6732.
• 1.2 Dhan Research is engaged solely in providing independent research and recommendation services relating to securities, in accordance with the SEBI (Research Analysts) Regulations, 2014, as amended from time to time.

2. Nature of Services

• 2.1 Dhan Research provides research reports, recommendations, and related market research services based on publicly available information and independent analysis.
• 2.2 We do not provide:
• a. Portfolio Management Services (PMS);
• b. Demat account handling, trading execution, or custody services of any kind;
• c. Profit-sharing arrangements of any nature;
• d. Any loss recovery plan, scheme, or assurance;
• e. Assured, fixed, minimum, or guaranteed returns under any service or scheme;
• f. Personalized investment advice based on individual client risk profiling (which falls under Investment Adviser services and requires separate SEBI registration).
• 2.3 Our services are limited strictly to research and recommendation services. Any decision to invest, trade, or act upon our research is solely and entirely the client's own decision and responsibility.

3. Fee Structure

• 3.1 Fees charged for research services shall not exceed the maximum limit prescribed by SEBI from time to time (currently ₹1,51,000 per annum per family of client, as per applicable SEBI norms).
• 3.2 Fees shall be collected only through Account Payee Cheque, Demand Draft, Credit Card, NEFT/RTGS/IMPS/UPI, the SEBI-mandated Centralized Fee Collection Mechanism for RAs (CeFCoM), or any other mode specified by SEBI from time to time. We do not accept cash payments.
• 3.3 No fee shall be collected in advance for periods exceeding what is permitted under applicable SEBI regulations.
• 3.4 Full details of our current fee structure and applicable subscription plans are available on our website / on request.

4. Client Onboarding and KYC

• 4.1 Clients are required to complete Know Your Customer (KYC) formalities and provide accurate personal, financial, and contact information prior to availing our services.
• 4.2 Clients must promptly inform us of any change in their contact details, KYC information, or other material information.

5. Risk Disclosures

• 5.1 Investment in securities markets is subject to market risks. Please read all related documents carefully before investing.
• 5.2 Registration granted by SEBI, membership of BSE/RAASB, and certification from NISM do not, in any manner, guarantee the performance of the Research Analyst or provide any assurance of returns to investors.
• 5.3 The Research Analyst does not guarantee any assured, minimum, or fixed returns on any recommendation.
• 5.4 Past performance of any recommendation, strategy, or the Research Analyst is not indicative of future results.
• 5.5 Securities recommended may be subject to price volatility, liquidity risk, and other market risks. Investors should independently evaluate their risk appetite before acting on any recommendation.
• 5.6 Recommendations, if any, are for informational and illustrative purposes only and do not constitute an offer, solicitation, or inducement to buy or sell any security.

6. No Assurance of Returns / No Liability

• 6.1 The Research Analyst does not guarantee the accuracy, adequacy, or completeness of the research and is not responsible for any errors or omissions or for the results obtained from the use of such research.
• 6.2 We shall not be liable for any direct, indirect, incidental, or consequential loss or damage arising from the use of, or reliance on, our research reports or recommendations.
• 6.3 There is no recourse to claim losses incurred on investments/trades made based on the recommendations provided.
• 6.4 Clients are advised to independently verify all information and, where required, consult their own financial, tax, or legal advisor before making any investment decision.

7. Conflict of Interest Disclosure

• 7.1 The Research Analyst, its associates, or relatives may from time to time have positions (long or short) in the securities recommended, or may have other actual or potential conflicts of interest with respect to any recommendation made.
• 7.2 Any such conflict of interest, wherever applicable, shall be appropriately disclosed in the relevant research report as mandated under Regulation 19 of the SEBI (Research Analysts) Regulations, 2014.
• 7.3 The Research Analyst maintains an arm's length relationship between research activities and other business activities, if any, as required under the Regulations.

8. Client's Rights and Responsibilities

As per SEBI's Investor Charter for Research Analysts, clients are entitled to:
• 8.1 Receive research services as agreed in the terms and conditions/client agreement.
• 8.2 Approach the Research Analyst with queries, or requests for clarification regarding any recommendation before acting on it.
• 8.3 Seek clarification on complex or high-risk recommendations before acting on them.

9. Prohibited Practices – Investor Protection Notice

• 9.1 We do not, under any circumstance, request or require clients to share their Demat account login credentials, trading account passwords, OTPs, or any other confidential financial credentials. Clients must never share such credentials with anyone, including individuals claiming to represent Dhan Research.
• 9.2 We do not offer, and clients should not trust any communication claiming, profit-sharing arrangements, guaranteed returns, or loss recovery schemes in the name of Dhan Research or Bhupendra Kumar Kushwaha.
• 9.3 If any person — whether claiming to be our associate, employee, franchise partner, or representative — offers Demat handling, portfolio management, profit sharing, assured returns, or loss recovery in the name of Dhan Research or Bhupendra Kumar Kushwaha, please report it to us immediately at support@dhanresearch.com or 7566368459.
• 9.4 We shall not be held responsible for any loss arising from unauthorized or fraudulent representations made by third parties falsely claiming association with Dhan Research.
• 10. Communication and Marketing
• 10.1 By subscribing to our services, clients consent to receive service-related communication via SMS, WhatsApp, email, or phone call.
• 10.2 Clients may opt out of promotional/marketing communication at any time by writing to support@dhanresearch.com, subject to us still being able to send essential service and regulatory communications.

11. Grievance Redressal Mechanism

• 11.1 In case of any grievance, clients may first approach us directly at:
Email: support@dhanresearch.com Mobile: 7566368459
• 11.2 We

REFUND POLICY – DHAN RESEARCH

1. Purpose and Scope

• 1.1 This Refund Policy governs all fees paid by clients for research services availed from Dhan Research and forms a binding part of the Terms & Conditions and the Most Important Terms and Conditions (MITC) executed/consented to by the client at the time of onboarding.
• 1.2 By subscribing to any service of Dhan Research, the client unconditionally accepts this Refund Policy in its entirety.

2. Scope of Refund — Strictly Limited

• 2.1 Refunds under this Policy are strictly and exclusively limited to the proportionate, unutilized/remaining subscription period of the service actually paid for by the client, calculated on a pro-rata basis from the date of receipt of a valid, written cancellation request.
• 2.2 No refund shall be granted on any ground other than the unutilized remaining period of service, including but not limited to the grounds expressly excluded under Section 4 of this Policy.
• 2.3 The refundable amount, if any, shall be computed solely on the fee amount actually received by Dhan Research from the client for the relevant subscription. No claim beyond this amount shall be entertained under any circumstance.

3. Refund Eligibility

• 3.1 A client may raise a refund request only for the unexpired/remaining period of an active, paid subscription, subject to:
• a. Submission of a written request as per the process in Section 6;
• b. The subscription being active and not already fully consumed;
• c. No breach of the Terms & Conditions/MITC by the client.
• 3.2 The refund amount shall be calculated as:
Refundable Amount = (Total Fee Paid ÷ Total Subscription Days) × Remaining Unexpired Days less any statutory charges (e.g., GST) already deposited with the government, which are non-refundable.
• 3.3 No breakage fee, exit penalty, or processing charge shall be deducted from the refundable amount so calculated, other than statutory charges as stated above.

4. Grounds Expressly Excluded from Refund

For the avoidance of doubt and to ensure absolute clarity, no refund shall be payable, claimable, or entertained under this Policy on any of the following grounds:
• 4.1 Dissatisfaction with research calls/recommendations. A client shall not be entitled to raise, and Dhan Research shall not entertain, any refund request on the ground that the client is dissatisfied with, disagrees with, or finds unsatisfactory any research call, recommendation, report, or advice issued. Research services are, by their nature, opinion-based and market-risk-dependent, and dissatisfaction with outcomes or views does not constitute a valid ground for refund.
• 4.2 Investment/trading losses. All refunds under this Policy are strictly limited to the unutilized subscription fee amount and do not, under any circumstance, extend to, compensate for, or cover any financial loss, trading loss, investment loss, or opportunity loss incurred or arising from the client's reliance on, or use of, any research report, call, or recommendation issued by Dhan Research. SEBI registration does not guarantee performance, returns, or accuracy, and the client acknowledges having read and accepted this risk at the time of onboarding.
• 4.3 Performance or accuracy of recommendations. No refund shall be payable on the ground that a recommendation did not perform as expected, was inaccurate, or did not achieve any particular result, since Dhan Research does not guarantee returns, profits, or accuracy of any research output.
• 4.4 False or fake commitments by any representative, associate, or third party. Dhan Research shall not be liable to refund any amount, nor entertain any claim, arising from any false promise, assured return commitment, profit-sharing offer, or any other representation made by any person — whether claiming to be an associate, employee, agent, or representative of Dhan Research or Bhupendra Kumar Kushwaha — that is contrary to, or not contained in, the signed service agreement, Terms & Conditions, and MITC. The client expressly acknowledges that:
• a. The client has signed/consented to a written service agreement (Terms & Conditions and MITC) prior to availing services;
• b. It is the client's own sole responsibility to read, verify, and satisfy themselves of all terms, fee structure, and scope of service before making payment and availing the service;
• c. No verbal, written, electronic, or any other representation made by any individual, which is inconsistent with the signed service agreement, shall bind Dhan Research or create any refund liability, irrespective of who made such representation.
• 4.5 Full or partial consumption of service. No refund shall be payable where the subscribed service period has already fully lapsed, or to the extent the service has already been utilized/consumed by the client.
• 4.6 Change of mind after service commencement, market conditions, or any external factor unrelated to a deficiency directly and solely attributable to Dhan Research.
• 4.7 Breach of Terms & Conditions/MITC by the client, including but not limited to unauthorized sharing/redistribution of research reports, providing false KYC information, or fraudulent conduct — in which case Dhan Research reserves the right to terminate services without any refund whatsoever.

5. Client Acknowledgment and Responsibility

• 5.1 Every client, prior to availing services, is required to read and provide explicit consent to the Terms & Conditions and MITC, which include this Refund Policy by reference.
• 5.2 By making payment and availing services, the client confirms that:
• a. They have independently verified all details of the service, fee, and scope prior to subscribing;
• b. They are availing research services solely at their own discretion and risk, for their own use and investment decision-making;
• c. They shall not hold Dhan Research liable for any representation made by any third party that conflicts with the signed agreement;
• d. Refunds, where eligible, are limited strictly to the unutilized fee amount as set out in this Policy, and no other claim shall arise.
• 5.3 It is the client's sole and non-transferable responsibility to conduct their own due diligence, including verifying the RA's SEBI registration on www.sebi.gov.in, before making any payment.

6. Refund Request Process

• 6.1 A refund request must be submitted in writing to support@dhanresearch.com, stating:
Registered name, contact details, and client/subscription ID; Payment reference/transaction ID and date of payment; Specific reason for the request, strictly limited to grounds permitted under Section 3.
• 6.2 Requests made on grounds excluded under Section 4 shall be rejected at the outset and shall not be processed further.
• 6.3 Dhan Research shall acknowledge a valid refund request within 2 working days.
• 6.4 Upon verification of eligibility, the proportionate refundable amount shall be processed within 7 working days from the date of acknowledgment.
• 6.5 Refunds shall be credited only to the original source of payment (same bank account/card/UPI/CeFCoM channel used for the original transaction). No cash refunds shall be made under any circumstance.

7. Finality of Decision

• 7.1 Dhan Research's determination of refund eligibility and the computed refundable amount, made strictly in accordance with this Policy, shall be final, subject only to the grievance escalation mechanism set out in Section 8.

8. Amendments

AML/CFT POLICY – DHAN RESEARCH

• 1. Legal Basis: This Policy complies with the Prevention of Money Laundering Act, 2002 (PMLA) and PML (Maintenance of Records) Rules, 2005; SEBI Master Circular on AML/CFT for Securities Market Intermediaries dated June 6, 2024 (as amended); UAPA Section 51A; WMD Act, 2005 Section 12A; and SEBI (Research Analysts) Regulations, 2014.
• 2. Designated Officers: Bhupendra Kumar Kushwaha acts as both Principal Officer and Designated Director (Rule 2(ba), PML Rules), responsible for AML/CFT compliance, FIU-IND/SEBI coordination, and Policy implementation.
• 3. Client Due Diligence (CDD): No service is rendered, and no fee accepted, without complete KYC (PAN + OVD + contact details) per Regulation 25(1) and PML Rules. Identity is verified via KRA records/OVDs. Where a client acts for another person, the beneficial owner is identified before onboarding. CDD is repeated periodically for existing clients based on risk/materiality and upon any material change in client information.
• 4. Risk-Based Categorization: Clients are classified Low/Medium/High risk based on source of funds, geography, occupation, and transaction pattern. Clients of Special Category (CSC) — NRIs, high-net-worth individuals with unclear fund sources, Politically Exposed Persons and associates, clients from FATF-flagged jurisdictions, and non-profits/trusts — receive Enhanced Due Diligence. Verified low-risk clients may receive simplified diligence within regulatory limits.
• 5. Sanctions Screening: Every client is screened, at onboarding and periodically, against the UAPA S.51A designated list, WMD Act S.12A list, and any other government/SEBI/UNSC list. On a positive match, the relationship is not proceeded with, funds are frozen/withheld, and the match is reported immediately to FIU-IND and SEBI's UAPA Nodal Officer (sebi_uapa@sebi.gov.in).
• 6. Payment Norms: Fees are accepted only via cheque, NEFT/RTGS/IMPS, UPI, or CeFCoM. Cash is strictly prohibited. Payment is accepted only from an account in the client's own name matching KYC; no third-party payments. Fees shall not exceed SEBI's cap (currently ₹1,51,000/family/annum for individual/HUF clients). Structured/split payments to evade this cap or reporting thresholds are treated as red flags.
• 7. Monitoring & Red Flags: Ongoing, risk-proportionate monitoring watches for: third-party payments, refusal to complete KYC or explain fund source, payment structuring, high-risk-jurisdiction clients, profile-transaction mismatches, and insistence on non-banking payment modes. Flags are logged (date, concern, action taken) and escalated to the Principal Officer immediately.
• 8. FIU-IND Reporting: Where warranted, a Suspicious Transaction Report (STR) is filed with FIU-IND in the prescribed format/timeline. The client relationship continues normally pending/after filing; the client is never informed of a report ("tipping off" is prohibited under PMLA), save that the relationship may be suspended in exceptional circumstances.
• 9. Record Retention: KYC, CDD, screening, transaction, and STR-related records are maintained sufficient to permit reconstruction of transactions, per Rules 3 and 9, PML Rules, for a minimum 5 years from transaction date or relationship termination (whichever is later), or longer if under legal/regulatory proceedings, per Regulation 25(2).
• 10. Technology & New Products: Name-screening against designated lists uses reasonably available tools, updated as lists change. Any new product, payment mode, or delivery channel undergoes an ML/TF risk assessment before launch, with a risk-based mitigation approach applied.
• 11. Outsourcing: Where any activity (e.g., payment gateway, hosting) is outsourced, Dhan Research exercises due diligence in provider selection and remains fully responsible for AML/CFT compliance regardless.
• 12. Training & Awareness: Any associates/staff engaged are made aware of this Policy, applicable red flags, and their duty to report suspicious activity to the Principal Officer; training records are maintained as evidence.
• 13. Investor Education: Clients are informed at onboarding that Dhan Research does not accept cash or third-party payments and complies fully with AML/CFT law.
• 14. Governance & Review: This Policy is owned by the Principal Officer/Designated Director, reviewed at least annually or upon any change to PMLA/PML Rules/SEBI's AML/CFT Master Circular, and version-controlled as dated above.