Advertisement Policy

  1. Purpose

The purpose of this Advertisement Policy is to ensure that all communications, advertisements, and promotional materials issued by the Research Analyst are fair, balanced, and not misleading. This policy establishes internal controls to ensure compliance with regulatory expectations and maintain transparency in communication with clients.

  1. Scope

This policy shall apply to all forms of communication issued by the Research Analyst, including:

  • Website content
  • Social media posts
  • Emails
  • Presentations
  • Marketing materials
  • Research reports used for marketing
  • WhatsApp messages
  • Public interviews or statements
  1. Advertisement Principles

All advertisements issued by the Research Analyst shall adhere to the following principles:

  • Advertisements shall be truthful and fair
  • Advertisements shall not contain misleading statements
  • Advertisements shall not guarantee returns
  • Advertisements shall not contain exaggerated claims
  • Advertisements shall not misrepresent services
  • Advertisements shall not create unrealistic expectations
  1. Prohibited Advertisements

The following shall not be permitted:

  • Guaranteed return statements
  • Misleading performance claims
  • Selective performance disclosure
  • Unsubstantiated claims
  • Misrepresentation of credentials
  • Comparison with other intermediaries without basis
  • Statements that may influence investors unfairly
  1. Performance Advertisement Guidelines

Where performance is disclosed:

  • Performance shall be accurate
  • Performance shall not be misleading
  • Appropriate disclaimers shall be included
  • Past performance shall not be presented as guarantee
  1. Mandatory Risk Disclosure

All advertisements shall include appropriate risk disclosure. The risk disclosure shall be clearly visible and not hidden.

  1. Use of Testimonials

Testimonials, if used, shall:

  • Be genuine
  • Not be misleading
  • Not guarantee returns
  • Not create unrealistic expectations
  1. Approval Process

All advertisements must be approved by BSE prior to release.

  1. Record Maintenance

The Research Analyst shall maintain:

  • Advertisement copies
  • Communication records
  • Approval records

Records shall be maintained for regulatory review.

  1. Monitoring

The Research Analyst shall periodically review advertisements to ensure compliance.

  1. Review of Policy

This policy shall be reviewed on annual basis

Prakash Gaba
Date: 31st March 2026

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