Legal & Compliance

RA Identity & Registration

Verify this registration on SEBI's own database of registered intermediaries: siportal.sebi.gov.in/intermediary/sebi-check or the full list at sebi.gov.in.

SEBI Disclosure Checklist — Research Reports & Public Appearances

Personal financial interests in securities — No. Ownership interest — No. Financial interest of associates/firm — No. Receipt of compensation — No. Other potential conflicts of interest — No. We submit that no material disciplinary action has been taken on the Research Analyst by any regulatory authority impacting equity research activities.

Detailed disclosures — Ownership and Material Conflicts of Interest:

1. Financial Interest Disclosure — No. Discloses any financial interest the Research Analyst, their associate, or relative has in the subject company, including the nature of such interest.
2. Ownership Disclosure — No. Discloses whether the Research Analyst, their associates, or relatives have actual/beneficial ownership of 1% or more securities of the subject company at the end of the month immediately preceding publication of the research report or the date of public appearance.
3. Other Material Conflicts of Interest — No. Discloses any other material conflict of interest of the Research Analyst, their associate, or relative at the time of publication of the research report or at the time of public appearance.

Receipt of Compensation Disclosures:

4. Compensation from Subject Company — No. Whether the Research Analyst or their associates have received any compensation from the subject company in the past 12 months.
5. Management or Co-management of Public Offerings — No. Whether the Research Analyst or their associates have managed or co-managed the public offering of securities for the subject company in the past 12 months.
6. Compensation for Investment Banking or Other Services — No. Whether the Research Analyst or their associates have received any compensation for investment banking, merchant banking, or brokerage services from the subject company in the past 12 months.
7. Compensation for Non-Investment Banking Services — No. Whether the Research Analyst or their associates have received any compensation for products or services other than investment banking, merchant banking, or brokerage services from the subject company in the past 12 months.
8. Compensation or Benefits from Third Parties — No. Whether the Research Analyst or their associates have received any compensation or other benefits from the subject company or third party in connection with the research report.

Additional Required Disclosures:

9. Past 12 Months Compensation — No. Reiterates whether the Research Analyst or their associates have received any compensation from the subject company in the past 12 months.
10. Client Relationship Disclosure — No. Whether the subject company was a client during the 12 months preceding distribution of the research report, and the types of services provided.
11. Position within Subject Company — No. Whether the Research Analyst has served as an officer, director, or employee of the subject company.
12. Market Making Activities — No. Whether the Research Analyst has been engaged in market-making activity for the subject company.
13. SEBI-Specified Disclosures — No. Any other disclosures as specified by SEBI under any other regulations.

History, Present Business and Background

SEBI License/Registration Holder "Varun Bhargav Proprietor of Profit X Research," SEBI Registered Research Analyst No. INH000014508. The Research Analyst was registered on 16 January 2024, and is engaged in offering research and recommendation services.

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

Disciplinary history: there are no pending material litigation or legal proceedings against the Research Analyst. As of 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.

Details of its associates: No associates.

Disclosures with Respect to Research and Recommendation Services

• The Research Analyst or any of its officers/employees does not trade in securities that are the 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, including any material information or facts that might compromise its objectivity or independence in the carrying on of Research Analyst services. Such conflicts of interest shall be disclosed to the client as and when they arise.
• The Research Analyst or its employees or its associates have not received any compensation from the company which is the subject matter of recommendation.
• The Research Analyst or its employee or its associates have not managed or co-managed the public offering of any company.
• The 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.
• The Research Analyst or its employee or its associates have not received any compensation for products or services other than the above from the subject company.
• The Research Analyst or its employee or its associates have not received any compensation or other benefits from the Subject Company or a 3rd party in connection with the research report/recommendation.
• The subject company was not a client of the Research Analyst or its employee or its associates during the twelve months preceding the date of recommendation.
• The Research Analyst's employees or its associates have not served as an officer, director, or employee of the subject company. The Research Analyst has not been engaged in market-making activity for the subject company.

SEBI Risk Disclosure — Derivatives (F&O)

AI Tools Use Disclosure

"I, Varun Bhargav, Proprietor of Profit X Research, hereby clarify and declare that we do not use any Artificial Intelligence (AI) tools or automated systems for research report preparation, stock analysis, recommendations, or any services provided by Profit X Research. All research and analysis are conducted through independent human expertise and professional judgment. In case of any occasional or minimal use of AI tools for general information processing or content drafting (non-research related), such usage does not influence or form the basis of our research or client recommendations. This disclosure is made in compliance with regulatory guidelines and for full transparency. Our research and analysis activities are conducted strictly through human expertise, manual research processes, and conventional analytical methodologies, fully complying with SEBI regulations."

This statement governs client-facing research recommendations specifically. If our use of AI-assisted tooling ever changes in a way that affects this declaration, this page will be updated accordingly.

Individual Code of Conduct for Research Analysts

Varun Bhargav, Proprietor of Profit X Research, being a SEBI Registered Research Analyst under Registration Number INH000014508 dated 16 January 2024, adheres to the following Code of Conduct in accordance with Regulation 24(2) of the SEBI (Research Analyst) Regulations, 2014:

1. Honesty and Integrity: I shall uphold the highest standards of honesty and integrity in all my activities and dealings.
2. Diligence and Thoroughness: I shall conduct research and analysis with diligence and thoroughness, ensuring that all reports are based on comprehensive analysis.
3. Conflict of Interest Management: I shall effectively manage any conflicts of interest that may arise, ensuring the impartiality and objectivity of research analysis and reports. Any conflicts of interest shall be disclosed appropriately.
4. Prevention of Insider Trading and Front Running: I shall refrain from engaging in any form of insider trading or front running based on information contained in my research reports.
5. Confidentiality and Data Protection: I shall maintain the confidentiality of research reports and any sensitive information until such reports are made public. Confidentiality protocols shall be strictly followed.
6. Adherence to Professional Standards: I shall adhere to high professional standards in the preparation and dissemination of research reports, ensuring accuracy, objectivity, and transparency.
7. Regulatory Compliance: I shall fully comply with all regulatory requirements applicable to my business activities as a research analyst, including but not limited to SEBI regulations and guidelines.
8. Responsibility of Management: As the proprietor of Profit X Research, I bear primary responsibility for ensuring that all members of the organization uphold these standards and adhere to proper procedures in conducting research activities.

This Code of Conduct is designed to foster trust, integrity, and professionalism in the field of research analysis, thereby promoting investor confidence and market integrity.

Internal Policy & Control Procedure

Internal Policy & Control Procedure in terms of Securities and Exchange Board of India (Research Analysts) Regulations, 2014. SEBI vide its Notification No. LAD-NRO/GN/2014-15/07/1414 dated September 1, 2014 has notified the SEBI (Research Analysts) Regulations, 2014 ("SEBI Regulations"). These regulations have been introduced by SEBI with the objective of fostering transparency in security research and provide investors with more reliable and useful information to make investment decisions. According to these regulations, Research Analyst(s) or Research Entity are required to put in place a comprehensive policy framework as prescribed in Chapter III of the SEBI Regulations. To ensure compliance with SEBI Regulations, Mr. Varun Bhargav ("Research Analyst"), SEBI License/Registration Holder "Varun Bhargav Proprietor of Profit X Research" SEBI Registered Research Analyst No. INH000014508, is required to adopt and adhere to such regulations, subject to the following internal policies and control procedures:

A. Applicability

This policy shall be applicable to the Research Analyst and all his employees engaged as research analysts, i.e. a person primarily responsible for preparation or publication of the content of the research report; or providing a research report or making 'buy/sell/hold' recommendation or giving price target or offering an opinion concerning public offer with respect to securities that are listed or proposed to be listed in a Stock Exchange, whether or not such person has the job title of a 'research analyst'. It also includes an associated person who reports directly or indirectly to the Research Analyst.

B. Definitions

Various terms shall have the following definitions and other terms shall have the same meaning assigned to them in the SEBI Regulations.

• "Associate" means associate as defined in Securities and Exchange Board of India (Intermediaries) Regulations, 2008 — any person controlled, directly or indirectly, by the intermediary, or any person who controls, directly or indirectly, the intermediary, or any entity or person under common control with such intermediary, and where such intermediary is a natural person, includes any relative of such intermediary, and where such intermediary is a body corporate, includes its group companies (as defined in the Monopolies and Restrictive Trade Practices Act, 1969, or any re-enactment thereof) or companies under the same management.
• "Price Target" means expectations of the Research Analyst on the future performance of specific securities.
• "Public Appearance" means any participation in a conference call, seminar, forum (including interactive and non-interactive electronic forum), radio or television or internet or web or print media broadcast, authoring a print media article or other public speaking activity in public media in which a Research Analyst makes a recommendation or offers an opinion concerning securities or public offer; provided that it does not include a password-protected webcast, conference call or such other events with clients, if all event participants previously received the research report or other documentation containing the required applicable disclosures, and the Research Analyst appearing at the event corrects and updates during the public appearance any disclosure in the Research Report that is inaccurate, misleading or no longer applicable.
• "Public Offer" includes initial public offer, further public offer, offer for sale, disinvestment, takeover, buy-back or delisting of securities.
• "Research Analyst" means a person who is primarily responsible for: 1. Preparation or publication of the content of the research report; or 2. Providing research report; or 3. Making 'buy/sell/hold' recommendation; or 4. Giving price target; or 5. Offering an opinion concerning public offer, with respect to securities that are listed or to be listed in a stock exchange, whether or not such person has the job title of 'research analyst', and includes any other entities engaged in issuance of research report or research analysis. It also includes any associated person who reports directly or indirectly to such a research analyst in connection with activities provided above.
• "Relative" means a person as defined in sub-section (77) of section 2 of the Companies Act, 2013, and who is financially dependent on the independent research analyst or individual research analyst employed by the research entity.
• "Research Entity" means an intermediary registered with SEBI who is also engaged in merchant banking or investment banking or brokerage services or underwriting services and issues a research report or research analysis in its own name through individuals employed by it as research analyst, and includes any other intermediary engaged in issuance of research report or research analysis.
• "Research Report" means any written or electronic communication that includes research analysis or research recommendation or an opinion concerning securities or public offer, providing a basis for investment decision, and does not include the following communications: comments on general trends in the securities market; discussions on broad-based indices; commentaries on economic, political or market conditions; periodic reports or other communications prepared for unit holders of a mutual fund or alternative investment fund or clients of portfolio managers and investment advisers; internal communications not given to current or prospective clients; communications constituting offer documents or a prospectus circulated per regulations made by the Board; statistical summaries of financial data of companies; technical analysis relating to demand and supply in a sector or index; or any other communication which SEBI may specify from time to time.
• "Significant news or event" means any news or event which is expected to have a material impact on, or that reflects a material change to, the subject company's earnings, operations or financial condition, other than unpublished price-sensitive information.
• "Subject company" means the company whose securities are the subject of a Research Report or a public appearance.

C. Management of Conflict of Interest and Disclosure Requirements

The Research Analyst shall maintain an arms-length relationship between research activities and other activities.

a) Limitations on trading by research analysts:

1. Personal trading activities of individuals employed as research analysts, if any, shall be monitored, recorded and, wherever necessary, subject to a formal approval process.
2. The Research Analyst or individuals employed as research analysts, if any, or their associates shall not: deal or trade in securities recommended/followed by the Research Analyst within 30 days before and 5 days after publication of a Research Report; deal or trade in securities that the Research Analyst reviews in a manner contrary to his given recommendation; purchase or receive securities of the issuer before the issuer's initial public offering, if the issuer is principally engaged in the same types of business as companies that the Research Analyst follows or recommends. However, the above restrictions to deal/trade in securities shall not be applicable in case of significant news or event concerning the subject company, or based upon an unanticipated significant change in the personal financial circumstances of the Research Analyst or individuals employed as research analysts, if any, subject to prior written approval from the Research Analyst.

b) Limitations on Publication of Research Report, Public Appearance, Conduct of Business etc.:

3. The Research Analyst shall not publish or distribute research report or research analysis or make public appearance regarding a subject company for which he has acted as a manager or co-manager at any time falling within a period of:
4. 40 days immediately following the day on which securities are priced if the offering is an initial public offering; or
5. 10 days immediately following the day on which securities are priced if the offering is a further public offering.
6. In case the Research Analyst is acting as an underwriter of any initial public offering, he shall not publish or distribute a research report or make a public appearance regarding that issuer for 25 days from the date of offering.
7. In case the Research Analyst has acted as manager or co-manager of a public offering of securities of a company, he shall not publish or distribute a research report or make public appearance concerning that company within 15 days prior to, and 15 days after, expiration/waiver/termination of a lock-up agreement or any other agreement that the Research Analyst has entered into with the subject company that restricts or prohibits the sale of securities held by the subject company after completion of the public offering of securities.
8. The Research Analyst shall not participate in business activities designed to solicit investment banking or merchant banking or brokerage services business, such as sales pitches and deal road shows.
9. The Research Analyst shall have adequate documentary basis, supported by research, for preparing a research report.
10. The Research Analyst shall not provide any promise or assurance of favourable review in the Research Report to a company or industry or sector or group of companies or business group as consideration to commence or influence a business relationship or for the receipt of compensation or other benefits.
11. The Research Analyst shall not issue a Research Report that is not consistent with the views of the individuals employed as research analyst regarding a subject company.

c) Disclosures in Research Report: The Research Analyst shall disclose all material information, including the business activity, disciplinary history, the terms and conditions on which the Research Report is offered, details of associates and such other information as is necessary to take an investment decision, including the following:

12. The Research Analyst shall disclose the following in the Research Report and in public appearance with regard to ownership and material conflicts of interest: whether the Research Analyst or his associate or his relative has any financial interest in the subject company and the nature of such financial interest; whether the Research Analyst or his associates or relatives have actual/beneficial ownership of 1% or more securities of the subject company at the end of the month immediately preceding the date of publication of the Research Report or date of the public appearance; whether the research analyst or his associate or his relative has any other material conflict of interest at the time of publication of the Research Report or at the time of public appearance.
13. The Research Analyst shall disclose the following in the Research Report with regard to receipt of compensation: whether he or his associates have received any compensation from the subject company in the past 12 months; whether he or his associates have managed or co-managed public offering of securities for the subject company in the past 12 months; whether he or his associates have received any compensation for investment banking or merchant banking or brokerage services from the subject company in the past 12 months; whether he or his associates have received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past 12 months; whether he or his associates have received any compensation or other benefits from the subject company or third party in connection with the Research Report.
14. The Research Analyst shall disclose the following in the Research Report with regard to receipt of compensation: whether he or his associates have received any compensation from the subject company in the past 12 months; whether the subject company is or was a client during the 12 months preceding the date of distribution of the research report, and the types of such services provided.
15. Whether the Research Analyst has served as an officer, director or employee of the subject company.
16. Whether the Research Analyst has been engaged in market-making activity for the subject company.
17. Such other disclosures in the Research Report or public appearance as specified by SEBI under any other regulations.

d) Contents of Research Report:

17. The Research Analyst shall ensure that facts in the Research Reports are based on reliable information and shall define the terms used in making recommendations, and these terms shall be consistently used.
18. If the Research Analyst employs a rating system, it must clearly define the meaning of each such rating, including the time horizon and benchmarks on which a rating is based.
19. If a Research Report contains either a rating or price target for the subject company's securities and the Research Analyst has assigned a rating or price target to the securities for at least 1 year, such Research Report shall also provide the graph of daily closing price of such securities for the period assigned or for a 3-year period, whichever is shorter.
20. The Research Analyst shall disclose the registration status and details of financial interest in the subject company, if he makes public appearance.
21. The Research Report shall not be made available selectively to internal trading personnel or a particular client or class of clients in advance of other clients who are entitled to receive the Research Report.
22. In case of distribution of any third party research report, the Research Analyst shall review such third party research report for any untrue statement of material fact or any false or misleading information. The Research Analyst shall also disclose any material conflict of interest of such third party research provider, or shall provide a web address that directs a recipient to the relevant disclosures.

D. Maintenance of Records

23. The Research Analyst shall maintain the following records: Research Report duly signed and dated; Research recommendation provided; Rationale for arriving at research recommendation; Record of public appearance.
24. All records shall be maintained either in physical or electronic form and preserved for a minimum period of 5 years. Provided that where records are required to be duly signed and are maintained in electronic form, such records shall be digitally signed.
25. The Research Analyst shall conduct annual audit in respect of compliance with the SEBI Regulations from a member of the Institute of Chartered Accountants of India or the Institute of Company Secretaries of India.

E. Other Conditions

26. The Research Analyst shall be the compliance officer responsible for monitoring compliance with the provisions of the Securities and Exchange Board of India Act, 1992, these SEBI Regulations and circulars issued by SEBI.
27. The Research Analyst shall ensure that his employees or partners, as may be applicable, comply with the certification and qualification requirements under Regulation 7 at all times.

Conflict of Interest Policy

Securities and Exchange Board of India ("SEBI") vide its Circular No. CIR/MIRSD/5/2013 dated August 27, 2013 has notified General Guidelines for intermediaries, recognised stock exchanges, recognised clearing corporations, depositories and their associated persons in securities market ("Guidelines") with the objective of avoiding or dealing with or managing conflict of interest by them. According to these Guidelines, all intermediaries including the Research Analyst(s) or Research Entity are required to put in place a Conflict of Interest Policy ("Policy"). To ensure compliance with the said Guidelines, Mr. Varun Bhargav ("Research Analyst"), SEBI License/Registration Holder "Varun Bhargav Proprietor of Profit X Research" SEBI Registered Research Analyst No. INH000014508, is required to adopt and adhere to such Guidelines.

A. Applicability: this Policy shall be applicable to the Research Analyst and all his employees engaged as research analysts. It shall also be applicable to an associated person who reports directly or indirectly to the Research Analyst.

B. Purpose: the purpose of this Policy is to set out the approach to identify and manage conflicts of interest which may arise during the course of business activities. This Policy aims at: identifying circumstances which may give rise to conflicts of interest entailing a material risk of damage to clients' interests; establishing appropriate procedures and systems to manage those conflicts; and ensuring the maintenance of such procedures and systems in an effort to prevent actual damage to clients' interests through conflicts identified.

C. Policy — the Research Analyst shall:

29. lay down policies and internal procedures to identify and avoid or to deal or manage actual or potential conflict of interest;
30. develop an internal code of conduct governing operations and formulate standards of appropriate conduct in the performance of their activities, and ensure to communicate such policies, procedures and code to all concerned;
31. develop measures to prevent or limit any person from exercising inappropriate influence over the way in which the services are carried out;
32. at all times maintain high standards of integrity in the conduct of his business;
33. ensure fair treatment of his clients and not discriminate amongst them;
34. ensure that his personal interest does not, at any time, conflict with his duty to his clients, and the client's interest always takes primacy in his advice, investment decisions and transactions;
35. make appropriate disclosure to the clients of possible source or potential areas of conflict of interest which would impair his ability to render fair, objective and unbiased services;
36. endeavor to reduce opportunities for conflict through prescriptive measures such as through information barriers to block or hinder the flow of information from one department/unit, if any, to another;
37. place appropriate restrictions on transactions in securities while handling a mandate of an issuer or client in respect of such security so as to avoid any conflict;
38. not deal in securities while in possession of material non-published information;
39. not communicate material non-published information while dealing in securities on behalf of others;
40. not in any way contribute to manipulate the demand for or supply of securities in the market or to influence prices of securities;
41. not have an incentive structure that encourages sale of products not suiting the risk profile of his clients;
42. not share information received from clients or pertaining to them, obtained as a result of their dealings, for his personal interest.

Appointment of Compliance Officer

Mr. Varun Bhargav would be the Compliance Officer under this Code. The compliance officer is responsible for monitoring the compliance of the provisions of the Act, these regulations and circulars issued by the Board. The Compliance Officer shall maintain a record for the purpose of adherence to the Code of Conduct. The Compliance Officer shall assist all the analysts and its associates, if any, in addressing any clarifications regarding the Regulations and the Company's Code of Conduct. In order to discharge his functions effectively, the Compliance Officer shall be adequately empowered and provided with adequate infrastructure to effectively discharge his function. In the performance of his duties, the Compliance Officer shall have access to all information and documents relating to the Securities of the Companies under research. The Compliance Officer shall act as the focal point for dealings with SEBI in connection with all matters relating to the compliance and effective implementation of the Regulations and this Code.

Correspondence and Clarification: all correspondence and queries concerning this Code should be sent to the Compliance Officer, Mr. Varun Bhargav, Email — profitxresearch@gmail.com, Mobile +91-9516598552. Place: Vidisha (MP). Registered Address: A 230 Balaji Paradise, Vidisha, PIN 464001.

AML Policy

Adopted and signed by Mr. Varun Bhargav, Proprietor, Profit X Research, effective 01/04/2024, in accordance with the Prevention of Money Laundering Act, 2002 (PMLA) and applicable SEBI requirements.

Prevention of Money Laundering Act, 2002 (PMLA) forms the core of the legal framework put in place by India to combat money laundering and related crimes. PMLA and the Rules notified thereunder came into force from 1st July 2005. Under PMLA, all entities registered with SEBI are required to furnish information of all suspicious transactions, whether or not made in cash, to FIU-IND. Under Section 3 of PMLA, projecting proceeds of crime as untainted property is an offence of money laundering liable to punishment under Section 4 of the PMLA.

Money Laundering involves disguising financial assets so that they can be used without detection of the illegal activity that produced them. Financial Intelligence Unit-India (FIU-IND) is the central national agency of India responsible for receiving, processing, analysing and disseminating information on suspect financial transactions. Section 2(1)(g) of the PMLA Rules defines a "suspicious transaction" — whether or not made in cash — as one which, to a person acting in good faith: gives rise to a reasonable ground of suspicion that it may involve the proceeds of crime; or appears to be made in circumstances of unusual or unjustified complexity; or appears to have no economic rationale or bonafide purpose; or gives rise to a reasonable ground of suspicion that it may involve financing of activities relating to terrorism.

As per the provisions of the Act, every intermediary registered under Section 12 of the SEBI Act, 1992 shall maintain a record of all transactions, the nature and value of which are prescribed under the PMLA Rules, including: all cash transactions of a value more than Rs 10 lakhs (or its foreign-currency equivalent); all series of cash transactions integrally connected to each other, valued below Rs 10 lakhs, taking place within one calendar month; and all suspicious transactions, whether or not made in cash, including inter-alia credits or debits into or from any non-monetary account such as a demat account maintained by the registered intermediary.

Client Due Diligence Process

As an organization providing Research Analyst services, execution of trades is entirely at the client's own discretion and clients do not share any executional, transactional, or securities-account data with us — identifying the beneficial owner or controlling party of a client's securities account is the responsibility of the broker handling that account. We adhere to SEBI KYC Registration Agency (KRA) Regulations to verify each client's identity — as registered members of KRA agencies including CVL KRA, NDML KRA and BSE KRA, we validate and download client information from the KRA system, and update it whenever a client's KYC status changes.

a. Policy for Acceptance of Clients

• No account is opened in a fictitious/benami name or on an anonymous basis.
• An account is not opened where we are unable to apply appropriate client due diligence measures or collect the basic KYC detail (PAN card number).
• The client is not permitted to act on behalf of another person/entity for service delivery.
• We do not accept clients whose identity matches a person/entity banned or debarred by SEBI/Stock Exchanges — verifiable at bseindia.com/investors/debent.aspx and nseindia.com/regulations/member-sebi-debarred-entities.
• We conduct a risk assessment against the UN Security Council Sanctions lists and do not on-board any client present on them — see un.org/sc/committees/1267 and un.org/sc/committees/1988.

b. Maintenance of Records, Audit & Reporting

All client records are maintained for a minimum period of 10 years, or until any regulatory action concerning them is resolved. Audit of RA activities is conducted by an independent professional as allowed by regulation, with observations actioned on a priority basis. The only transaction encountered while delivering our service is collection of fees — since we have no access to clients' execution/transaction data — and fee collection is through our bank account only; no cash transaction is allowed for fee payment. Any suspicious transaction is immediately notified to the Compliance Officer, and the Principal Officer is responsible for timely, confidential submission of CTR and STR to FIU-IND (no nil reporting is made where there is nothing to report), transmitted by speed/registered post/fax to: Director, FIU-IND, Financial Intelligence Unit India, 6th Floor, Hotel Samrat, Chanakyapuri, New Delhi – 110021.

Role of Staff & Review

The Principal Officer communicates this policy to employees, receives and clarifies reports of suspicious dealing, and ensures onboarding staff — who carry primary compliance responsibility since they deal face-to-face with clients — follow KYC/CDD procedures for every new business and renewal. A copy of this policy is provided to all relevant staff, and an internal awareness session is conducted yearly in the first week of April. Management reviews this policy and its procedures as and when SEBI/PMLA regulatory guidelines change.

Signed: Mr. Varun Bhargav, for Varun Bhargav, Proprietor of Profit X Research, SEBI Registered Research Analyst Registration No. INH000014508 — 01/04/2024.

Annual Audit Report Status

As required under SEBI's Research Analyst Regulations, the annual compliance audit status for each financial year is disclosed below.

Privacy Policy

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Definitions of Terms Used in Recommendations

• Buy — Buy means that the stock recommended is to be bought either at Market or at price or within the price band mentioned in the recommendation. Stock to be bought at Market or Current Market Price (CMP) must be bought immediately or near the closing time of market at closing price. Stock with a limit price order, or where a buying price or price band is mentioned, can be bought at the price or within the price band mentioned.
• Sell / Target — Sell or target price is the price at which the stock must be sold. For stocks which have reached their target price, or are trading above target price, they must be sold upon reaching the target price or price band mentioned.
• Hold — Hold means that a stock may be held and no exit is required. A Hold recommendation is given if the stock has not achieved its mentioned target or hit the mentioned stop-loss price. A Hold recommendation can also be given in case the Research Analyst is of the opinion that even after reaching the target price, the stock may go beyond the target price due to a change in circumstances.
• Stop Loss Price — Stop loss is a price at which the stock must be exited or sold due to an adverse situation or market move contrary to the recommendation. When the stop-loss price is reached, the stock can be exited immediately or near the close of the trading session at a price near the closing price. The second scenario is mentioned given the fact that sometimes the stop-loss price is reached due to intraday volatility of the market but it recovers towards the end of the session, showing the strength of the stock, in which case the stock can be held. This mechanism helps the Investor avoid a wrong exit/premature exit from the stock. It must be noted, however, that if the stock is trading below/at the stop-loss level near the closing trading time, then it must be exited.

Standard Warning & Disclaimers

• Disclaimer — the securities quoted are for illustration only and are not recommendatory.
• Disclaimer — Registration granted by SEBI, ENLISTMENT WITH RAASB/BSE and certification from NISM in no way guarantee the performance of the Research Analyst or provide any assurance of returns to investors.
• Disclaimer — past performance is not indicative of future results.
• Disclaimer — "Past results should not be seen as a sign or promise of what will happen in the future, and we don't explicitly or implicitly guarantee future results. The cost, worth, and potential earnings from any securities or financial instruments can decrease as well as increase."
• Disclaimer — Non-Advisory Nature: the information and content presented are provided for general informational purposes only and should not be construed as professional financial or investment advice.
• Disclaimer — Educational Content: the content is meant for educational and knowledge-sharing purposes only.
• Disclaimer — I/we are a SEBI Research Analyst, NOT an investment adviser. Content on this website (www.profitxresearch.com) or on any social/digital/offline/online platforms/Apps is provided for information purposes only. The content displayed on the website or on any social/digital/offline/online platforms/apps does not constitute a personal recommendation or any investment advice, or take into account the particular investment objective, financial situation or need of individual/groups. Profit X Research accepts no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential loss or damage) arising from any use of any information on this website, or on any social/digital/offline/online platforms/Apps whatsoever.

मानक चेतावनी एवं अस्वीकरण

• 2 अस्वीकरण – SEBI द्वारा प्रदत्त पंजीकरण, RAASB/BSE के साथ नामांकन और NISM से प्राप्त प्रमाणन किसी भी प्रकार से अनुसंधान विश्लेषक के प्रदर्शन की गारंटी नहीं देते हैं और न ही निवेशकों को किसी भी प्रतिफल का आश्वासन प्रदान करते हैं।
• 3 अस्वीकरण – उद्धृत प्रतिभूतियाँ केवल उदाहरण के लिए हैं और ये सिफारिशी नहीं हैं।
• अस्वीकरण – गैर-सलाहकारी प्रकृति: प्रस्तुत जानकारी और सामग्री केवल सामान्य सूचनात्मक उद्देश्यों के लिए प्रदान की जाती है और इसे पेशेवर वित्तीय या निवेश सलाह के रूप में नहीं समझा जाना चाहिए।
• शैक्षिक सामग्री: सामग्री केवल शैक्षिक और ज्ञान-साझाकरण उद्देश्यों के लिए है।
• अस्वीकरण – हम एक सेबी अनुसंधान विश्लेषक हैं, निजी वित्तीय सलाहकार नहीं। इस वेबसाइट (www.profitxresearch.com) या किसी भी सामाजिक/डिजिटल/ऑफलाइन/ऑनलाइन प्लेटफॉर्म/एप्स पर प्रदान की गई सामग्री केवल जानकारी के उद्देश्य के लिए है। PROFIT X RESEARCH किसी भी हानि या क्षति के लिए जिम्मेदार नहीं होगा।
• अस्वीकरण – अतीत के परिणामों को भविष्य में क्या होगा, इसका संकेत या वादा नहीं माना जाना चाहिए, और हम भविष्य के परिणामों की खुले तौर पर या अनुमानित रूप में कोई गारंटी नहीं देते हैं। किसी भी प्रतिभूतियों या वित्तीय साधनों से लागत, मूल्य, और संभावित आय में कमी आ सकती है जैसे कि वृद्धि भी हो सकती है।

Terms & Conditions

This agreement is between Varun Bhargav, Proprietor of Profit X Research, registered with SEBI as a Research Analyst under Registration No. INH000014508, and the client. By subscribing to the research services, the client acknowledges and agrees to the following terms and conditions.

1. Availing the Research Services

By accepting delivery of the research service, the client confirms that they have elected to subscribe at their sole discretion. The Research Analyst confirms that research services shall be rendered in accordance with the applicable provisions of the RA Regulations.

2. Obligations on Research Analyst

The Research Analyst and the client shall be bound by the SEBI Act and all applicable rules and regulations of SEBI, including the RA Regulations and relevant Government notifications, as may be in force from time to time.

3. Client Information and KYC

• The client shall furnish all required details in full, in the standard form with supporting documents, as mandated by SEBI.
• The Research Analyst shall collect, store, and check KYC records with the KYC Registration Agency (KRA) as specified by SEBI.

4. Standard Terms of Service

By subscribing, the client acknowledges and agrees to the following:

"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 judgment 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 investments made based on the recommendations in the research report."

5. Declarations from the Research Analyst

• Duly registered with SEBI under Registration No. INH000014508 and compliant with SEBI (Research Analyst) Regulations, 2014.
• No material adverse disciplinary history or conflicts of interest compromising the integrity of recommendations.
• Maximum fee charged shall not exceed ₹1.51 lakh per annum per family of clients.
• Recommendations provided do not assure returns.

6. Consideration and Mode of Payment

• The client agrees to pay the fees as mutually decided, along with any applicable statutory charges.
• Payments shall be made through specified secure modes — NEFT, IMPS, UPI, Cheque, or approved payment processors.
• The Research Analyst may collect up to 3 months' advance payment based on mutual agreement.
• Plan duration: 1 Month = 30 calendar days; 3 Months = 90 calendar days.

7. Risk Factors

Disclaimer: Registration granted by SEBI, and certification from NISM in no way guarantee the performance of the Research Analyst or provide any assurance of returns to investors.

8. Conflict of Interest

The Research Analyst adheres to SEBI guidelines for disclosure and mitigation of conflicts of interest, with full disclosures provided in each research report — see the Conflict of Interest Policy above.

9. Termination of Service and Refund of Fees

The Research Analyst reserves the right to suspend or terminate services in the event of suspension or cancellation of its SEBI registration. If the certificate of registration is suspended for a period exceeding sixty (60) days or is cancelled, the Research Analyst shall refund subscription fees on a pro-rata basis for the period from the effective date of such suspension/cancellation to the end of the subscription period.

10. Grievance Redressal and Dispute Resolution

For any support-related grievances, including non-receipt of reports or deficiencies in service, email profitxresearch@gmail.com. If unresolved, escalate to the designated grievance officer. All grievances are addressed within 7 business days or per the latest SEBI RA Regulations. Full process: see Grievance Redressal below.

11. Use of Research Reports

All research reports and related information are confidential and intended solely for the subscriber. Unauthorized distribution, reproduction, or use is strictly prohibited. Clients (paid or unpaid) and any third party have no right to forward or share calls, SMS, reports or any information provided by us — doing so can result in serious legal action. Clients must independently assess all recommendations; the Research Analyst assumes no responsibility for losses incurred.

Most Important Terms and Conditions (MITC)

1. RA cannot execute/carry out any trade on the client's behalf.
2. Fee capped at the SEBI/RAASB-prescribed maximum — currently ₹1,51,000 per annum per family for Individual/HUF clients (excludes statutory charges; does not apply to non-individual clients/accredited investors).
3. Advance fee limited to one year; pro-rata refund for the unexpired period on premature termination.
4. Payment via cheque, online bank transfer, UPI, etc. — cash is not allowed. Optional Centralised Fee Collection Mechanism (CeFCoM), managed by BSE Limited, is available.
5. RA follows SEBI/RAASB rules on disclosure and mitigation of conflicts of interest, and will promptly inform clients of any conflict affecting services rendered.
6. Assured/guaranteed/fixed-return schemes of any kind are prohibited by law and will never be offered.
7. The RA cannot guarantee returns, profits, accuracy, or risk-free investment outcomes.
8. Investments are subject to market risk; there is no recourse for losses based on recommendations; reliance is the client's own judgment.
9. SEBI registration, RAASB enlistment, and NISM certification do not guarantee RA performance or assure client returns.
10. For grievances — Step 1: contact the RA directly (mobile +91-9329587840) or via the Grievance Redressal / Escalation Matrix below. Step 2: if unresolved, SEBI's SCORES platform at scores.sebi.gov.in. Step 3: Online Dispute Resolution via the Smart ODR portal.
11. Clients must keep contact details (email, mobile) updated with the RA at all times.
12. The RA will never ask for login credentials or OTPs for your trading, demat, or bank accounts — never share these with anyone, including the RA.
13. We shall provide 0-X numbers of buy/sell/hold or stay-away calls based on technical and fundamental research during the validity period on a need basis (frequency of calls based on our research and not on customer demand or request or bias).
14. The fees paid towards any services/reports/mentorship or any other services are non-refundable in any condition (except as set out in the Refund & Cancellation Policy below).
15. Investors/Traders are advised to act according to their risk appetite — we are not providing investment advisory services, we are providing research analyst services.
16. All Buy/Sell/Hold or stay-away call updates will be received through WhatsApp and/or SMS and/or Email and/or Telegram, when provided.

Mandatory Notice

Clients are requested to review the Do's and Don'ts for dealing with Research Analysts specified in SEBI Master Circular No. SEBI/HO/MIRSD-POD1/P/CIR/2024/49 dated May 21, 2024 (or as updated by SEBI from time to time) — see the Investor Charter below.

Use of Artificial Intelligence

Per Regulation 24(7) of the SEBI (Research Analyst) Regulations, 2014: if AI tools are ever used in preparing services, the Research Analyst takes full responsibility for the security, confidentiality and integrity of client data used with such tools, and ensures compliance with applicable law. No service is rendered and no fee is charged until the client's consent to these Terms is received. See the AI Tools Use Disclosure above for the current, specific position.

Refund & Cancellation Policy

Based on Annexure A of the MITC and Clause 3 of the SEBI Circular dated February 17, 2025.

Cases where a refund will NOT be provided

• Services rendered as agreed and the client is merely dissatisfied, with no breach or deficiency in service.
• RA unable to deliver for reasons beyond its control (technical/operational issues) — no refund, though the service period may be extended at the RA's discretion.
• Force majeure events (natural disasters, pandemics, etc.), where excluded under the service agreement.
• Full subscription period already utilized.
• Partial utilization without formal written termination (minimum 10 days' written notice with reason required for a smooth deboarding).
• No refund for partially-utilized months — only full unutilized months qualify. Example: fee paid 1 Feb for 3 months, terminated 10 March → no refund for March; refund only for the fully-unutilized month of April.
• Losses from adverse market conditions or recommendations not resulting in profit.
• Client's breach of these Terms (fraud, misuse of reports, fraudulent KYC documents).
• Free trial or promotional services.
• Client found in violation of SEBI regulations (e.g. illegally sharing reports).
• Voluntary opt-out without valid reason/documentation.
• Non-refundable fees (e.g. administrative/onboarding charges), where designated as such in the agreement.

Cases where the client IS entitled to a refund

• Client's premature termination — pro-rata refund for the unexpired period, subject to the conditions above.
• RA's premature termination of services — pro-rata refund for the unutilized period.
• Regulatory action against the RA (SEBI/RAASB suspension or cancellation) — pro-rata refund, not subject to the "no partial month" restriction.
• Double payment or overcharging beyond the ₹1,51,000/annum/family cap — the excess is refunded.
• Clients on the Centralized Fee Collection Mechanism (CeFCoM) who discontinue — refund processed through CeFCoM.

Refund calculation & processing

• Pro-rata basis only, on the unexpired period.
• Refund requests must be submitted in writing (email or official channel).
• Processed within 30 days of approval.
• Credited to the same payment method used (bank transfer/UPI/digital only — no cash refunds).

Note: this document is periodically updated per SEBI/RAASB circulars. In case of any discrepancy, please contact profitxresearch@gmail.com before making payment.

Investor Charter — SEBI Annexure A (Research Analysts)

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 Investors

• To publish research reports based on the research activities of the RA.
• To provide an independent, unbiased view on securities.
• To offer unbiased recommendations, disclosing the financial interests in recommended securities.
• To provide research recommendations based on analysis of publicly available information and known observations.
• To conduct an 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 research services has taken place.

C. Details of Services Provided to Investors (No Indicative Timelines)

Onboarding of Clients: sharing of terms and conditions of research services; completing KYC of fee-paying clients.

Disclosure to Clients: to disclose information that is material for the client to make an informed decision, including details of its business activity, disciplinary history, the terms and conditions of research services, details of associates, risks and conflicts of interest, if any; to disclose the extent of use of Artificial Intelligence tools in providing research services; to disclose, while distributing a third-party research report, any material conflict of interest of such third-party research provider or provide a web address that directs a recipient to the relevant disclosures; to disclose any conflict of interest of the activities of providing research services with other activities of the research analyst.

• To distribute research reports and recommendations to clients without discrimination.
• To maintain confidentiality w.r.t. publication of the research report until made available in the public domain.
• To respect the data privacy rights of clients and take measures to protect unauthorized use of their confidential information.
• To disclose the timelines for the services provided by the research analyst to clients and ensure adherence to the said timelines.
• To provide clear guidance and adequate caution notice to clients when providing recommendations for dealing in complex and high-risk financial products/services.
• To treat all clients with honesty and integrity.
• To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of discharging legal obligations, or a client has provided specific consent to share such information.

D. Details of Grievance Redressal Mechanism and How to Access It

1. Investor can lodge a complaint/grievance against the Research Analyst in the following ways:

Mode of filing the complaint with the research analyst: in case of any grievance/complaint, an investor may approach the concerned Research Analyst, who shall strive to redress the grievance immediately, but not later than 21 days of the receipt of the grievance.

Mode of filing the complaint on SCORES or with Research Analyst Administration and Supervisory Body (RAASB): SCORES 2.0 (a web-based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in a time-bound manner) — scores.sebi.gov.in. Two-level review for complaint/grievance against a Research Analyst: first review done by the designated body (RAASB); second review done by SEBI. Email to the designated email ID of RAASB.

If the Investor is not satisfied with the resolution provided by the Market Participants, the Investor has the option to file the complaint/grievance on the SMARTODR platform for its resolution through online conciliation or arbitration. With regard to physical complaints, investors may send their complaints to: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, 'G' Block, Bandra-Kurla Complex, Bandra (E), Mumbai – 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 — including the right to receive information about all statutory and regulatory disclosures
• Right to Fair & True Advertisement
• Right to Awareness about Service Parameters and Turnaround Times
• Right to be informed of the timelines for each service
• Right to be Heard and Satisfactory Grievance Redressal
• Right to have timely redressal
• Right to Exit from a Financial product or service in accordance with the terms and conditions agreed with the research analyst
• Right to receive clear guidance and caution notice when dealing in Complex and High-Risk Financial Products and Services
• Additional Rights to vulnerable consumers — Right to get access to services in a suitable manner even if differently abled
• Right to provide feedback on the financial products and services used
• Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from the Investors (Responsibilities of Investors)

Do's

1. Always deal with a SEBI-registered Research Analyst.
2. Ensure that the Research Analyst has a valid registration certificate.
3. Check for the SEBI registration number. Please refer to the list of all SEBI-registered Research Analysts available on the SEBI website: sebi.gov.in.
4. Always pay attention towards disclosures made in the research reports before investing.
5. Pay your Research Analyst through banking channels only, and maintain duly-signed receipts mentioning the details of your payments. You may make payment of fees through the Centralized Fee Collection Mechanism (CeFCoM) of RAASB if the research analyst has opted for the mechanism (applicable for fee-paying clients only).
6. Before buying/selling securities or applying in a public offer, check for the research recommendation provided by your Research Analyst.
7. Ask all relevant questions and clear your doubts with your Research Analyst before acting on a recommendation.
8. Seek clarifications and guidance on research recommendations from your Research Analyst, especially if it involves complex and high-risk financial products and services.
9. Always be aware that you have the right to stop availing the service of a Research Analyst as per the terms of service agreed between you and your Research Analyst.
10. Always be aware that you have the right to provide feedback to your Research Analyst in respect of the services received.
11. Always be aware that you will not be bound by any clause, prescribed by the research analyst, which is contravening any regulatory provisions.
12. Inform SEBI about a Research Analyst offering assured or guaranteed returns.

Don'ts

1. Do not provide funds for investment to the Research Analyst.
2. Don't fall prey to luring advertisements or market rumors.
3. Do not get attracted to limited-period discounts or other incentives, gifts, etc. offered by a Research Analyst.
4. Do not share the login credential and password of your trading, demat or bank accounts with the Research Analyst.

Grievance Redressal / Escalation Matrix

View Grievance Redressal Methods as a standalone document ↗ (also downloadable as a PDF).

Step 1 — Contact us directly

Email your grievance to profitxresearch@gmail.com or call/WhatsApp our Compliance & Grievance Officer, Varun Bhargav, at +91-9329587840 or +91-9516598552. We aim to resolve every grievance immediately, and in any case within 21 days of receipt.

Step 2 — SEBI SCORES

If you're not satisfied with our resolution, escalate to SEBI's centralized, web-based grievance redressal system:

File a complaint on SEBI SCORES ↗

SCORES applies a two-level review: first by BSE Ltd. (our designated Research Analyst Administration and Supervisory Body — RAASB), then by SEBI itself.

Step 3 — Smart ODR

If the outcome from SCORES is still unsatisfactory, you may pursue Online Dispute Resolution through conciliation or arbitration:

Visit the Smart ODR portal ↗

Physical complaints

Office of Investor Assistance and Education,
Securities and Exchange Board of India,
SEBI Bhavan, Plot No. C4-A, 'G' Block,
Bandra-Kurla Complex, Bandra (E),
Mumbai – 400051

Impersonation & Fraud Warning

Accessibility of this process

If you need this grievance process explained or assisted in an alternate format because of a disability, write to our dedicated inbox: special.abled.profitxresearch@gmail.com.

Complaints Data — SEBI Annexure B

Formats for investors' complaints data disclosed monthly, as required by SEBI.

*Inclusive of complaints of previous months resolved in the current month. #Inclusive of complaints pending as on the last day of the month. ^Average resolution time is the sum total of time taken to resolve each complaint in days, in the current month, divided by the total number of complaints resolved in the current month.

Trend of Monthly Disposal of Complaints

Trend of Annual Disposal of Complaints

*Resolved includes complaints from previous months/years resolved in the current month/year. #Pending includes complaints pending as on the last day of the month/year.

Frequently Asked Questions

About our registration

About our research

Onboarding & consent

Safety

Book Orders & Feedback

• Order a paperback book ↗
• Contact & Feedback form ↗

Download the Original Source Documents

Everything above is reproduced in full from these underlying documents. If you'd like the original files themselves:

• Terms & Conditions / MITC (PDF) ↓
• SEBI Investor Charter (PDF) ↓
• Internal Policy & Conflict of Interest Policy (PDF) ↓