1. Purpose

This policy is framed to ensure that Prakash Gaba, acting as an Individual Research Analyst, satisfies the fit and proper person criteria at all times while carrying out research analyst activities.

2. Applicability

This policy shall apply to Prakash Gaba, acting as an Individual Research Analyst.

3. Fit and Proper Criteria

Prakash Gaba shall, at all times:

• Maintain integrity, honesty and fairness in professional dealings
• Maintain good reputation and character
• Possess adequate qualifications and experience
• Maintain financial solvency
• Avoid conflicts of interest and unethical practices

4. Disqualification Criteria

Prakash Gaba shall not:

• Be declared insolvent or bankrupt
• Be convicted of any offence involving fraud or dishonesty
• Be debarred or restrained by any regulatory authority
• Be involved in activities detrimental to investor interest

5. Ongoing Compliance

Prakash Gaba shall ensure continuous compliance with fit and proper requirements. Any material change affecting fit and proper status shall be evaluated and appropriate action shall be taken.

6. Declaration

Prakash Gaba shall periodically confirm compliance with fit and proper criteria.

7. Review

This policy shall be reviewed on an annual basis.

Prakash Gaba

Date: 31^st March 2026