1.   Purpose

The purpose of this Anti‑Money Laundering (AML) Policy is to establish a framework to prevent the Research Analyst from being used, intentionally or unintentionally, for money laundering, terrorist financing, or any unlawful financial activities. This policy also establishes procedures for client onboarding, risk assessment, monitoring and record maintenance.

2.   Scope

This policy applies to all clients, prospective clients, services offered, communications, and financial transactions undertaken by the Research Analyst.

3.   Client Acceptance Policy

The Research Analyst shall onboard clients only after completion of the prescribed due diligence procedures. Anonymous or fictitious clients shall not be accepted. Enhanced due diligence shall be conducted for high‑risk clients.

4.   Client Due Diligence

The Research Analyst shall obtain and verify client details including identity, address, contact information, PAN and other relevant information prior to onboarding.

5.   Risk Categorisation

Clients shall be categorized into low, medium and high‑risk categories based on risk perception. Risk categorisation shall be reviewed periodically.

6.   Ongoing Monitoring

The Research Analyst shall monitor client relationships on an ongoing basis to identify unusual or suspicious activities.

7.   Suspicious Transaction Monitoring

Any unusual transactions, payments from third parties, or unusual client behaviour shall be treated as suspicious and reviewed.

8.   Record Maintenance

The Research Analyst shall maintain client records, communication and transaction records for the prescribed period.

9.   Confidentiality

Client information shall be kept confidential and shall not be disclosed except where required by law.

10.               Review of Policy

This policy shall be reviewed annually to ensure effectiveness and compliance.

Prakash Gaba
Date: 31^st March 2026.