Client Agreement / Terms of Use

This agreement is entered into between client (hereinafter referred to as "You" / “Member” / “User”) and SPT Investment Advisory Services Private Limited, a SEBI Registered Investment Adviser (SEBI Registration Number INA000000326, registration type being non-individual, valid till perpetuity, BASL Membership ID 1842), having its office at A504, Kohinoor Square, NC Kelkar Road, Shivaji Park, Dadar (W), Mumbai 400 028, contact number +91 22 4444 2720, email id client@email.sptulsian.com, Principal officer being Mr. S P Tulsian and Compliance Officer being Mr. Vinod Ameria. The associated SEBI Office is SEBI Bhavan BKC, Plot No. C4-A, ‘G’ block, Bandra Kurla Complex, Bandra (East), Mumbai 400051, Maharashtra, with telephone number +91 22 2644 9000 / 4045 9000 and toll free helpline 1800 22 7575.

This agreement pertains to subscription on the website, sptulsian.com, including the mobile app (hereinafter referred to as the "Site"), is operated by SPT Investment Advisory Services Private Limited (hereinafter referred to as "We" / "Us" / "Our") to service Members, for the plan or package, as selected on the Site, for a fixed duration of period mentioned on the Site. The term "Member or Members" means and includes all registered users of the Site who have paid due consideration for the use of the Site and its services. The term "You" / "User" / "Users" / "Viewer" / "Viewers" means and includes all those persons who gain access to the Site and includes all Members (as defined hereinabove). We may introduce additional subdomains or URL for ease of access to Members and the same shall also be covered by this Agreement pertaining to the subscription on the ‘Site’.

By accepting this Agreement, the User acknowledges that they have read and understood the terms and conditions set forth herein and agrees to be bound by them. The User has also understood the fee structure, mechanism for charging and payment of fee, and acknowledges that receipt of all investment advice from Us will be through the Site /digital/electronic means and not physically in person.

We declare that we shall neither render any investment advice nor charge any fee until the User has signed this agreement. We do not manage funds and securities on behalf of the User. We only receive fees from the User, towards the subscription to the Site.

Investments are subject to risk. We do not assure returns or minimum returns or target return or percentage accuracy or service provision till achievement of target returns or any other nomenclature that gives the impression that investment advice is risk-free and/or not susceptible to risks and or that it can generate returns with any level of assurance.

SEBI’s Investment Adviser Regulations entitle Investment Advisers to charge fees from client in either of two modes: (A) Assets under Advice (AUA): maximum fees of 2.5% of AUA per annum per client (B) Fixed fee: maximum fees of Rs.1.51 lakh per annum per family of client. We charge Subscription fees to Members fees under the Fixed fee mode, for the package selected on our Site, having a validity as per the chosen plan.

We provide purely listed stocks advisory services only, to our clients, by charging Subscription/Membership Fees, as our Professional charges and do not offer any execution or distribution services, of any nature whatsoever to our clients. Clients are required to handle their funds on their own, with their respective stockbrokers and they themselves are responsible for executing the trades at their own end.

1. Acceptance of Agreement

   You agree to the terms and conditions outlined in Terms of Use (“Agreement”), with respect to our Site. This Agreement constitutes the entire and only agreement between us and you, and supersedes all prior or contemporaneous agreements, representations, warranties and understandings with respect to the Site, the content, services provided by or through the Site, and the subject matter of this Agreement. However, we reserve our rights to carry out the periodical changes, to our Site, which we deem fit and required for the benefits and larger interests of our members.

2. Use of Information

   The information, statements, recommendations, opinions and materials contained on the Site are for private use only and not intended for use in any commercial activity or purpose.

   We reserve the right, and you authorize us, to the use and assignment of all information regarding Site uses by you and all information provided by you in any manner consistent with our Privacy Policy.

3. Equity Risk

   You understand and agree that any action taken or decision made based on the information, statements and/or opinions contained, provided, posted, made or expressed on the Site will be taken or made by you at your own risk without any recourse whatsoever to us. You further acknowledge that the Site is not responsible for any losses or damages incurred as a result of your trading or investment activities.

   Equity investments are risky in nature, where substantial portion of investments may get eroded, including loss of capital. Hence, same should be made within the risk tolerance and financial capacity of the member.

   Our calls are given for Equity cash segment only and must not be applied for Derivative (Futures and Option) instrument. Derivative (Future & Option) instruments are very high risk instrument in nature, where losses are not only restricted to the capital/margin and may exceed much beyond the capital/margin amount. It is also advised not to take position or to exit from your investment and trading positions, which exceed your risk appetite, financial tolerance and comfort level, as and when it happens.

4. Payments

   You represent and warrant that if you are purchasing something or some service from us or from Merchants that (i) any credit information you supply is true and complete, (ii) charges incurred by you will be honoured by your credit card company / bank, and (iii) you will pay the charges incurred by you at the posted prices, including any applicable taxes. For your own safety you may be asked to complete additional verifications such as 'Verified by Visa' or '3D Secure' to verify your identity. Additionally, there is no money back policy in case you do not find the Site useful or are dissatisfied with our service. Our refund policy is as per SEBI guidelines. Once an order is placed and processed, it cannot be cancelled. All orders are final and any dispute or cancellation will be resolved at our sole discretion. Since we provide a B2C service as stated in Point 2 above, no GST input credit will be available for GST paid as applicable for all B2C services. You will receive invoice with our PAN and GST number but will NOT have your GST number to avail of input credit. You cannot use our services for commercial usage (kindly contact us on info@sptulsian.com for additional information on commercial or business usage of our services).

5. Returns Not Guaranteed

   We do not commit, guarantee, assure, indicate or promise any returns that you may be able to generate based on our recommendations or following our advice provided on our Site. You act solely based on your individual risk-bearing ability and your perception of the equities market. Investments in stock market are subject to market risk. Please read and understand the financial terms carefully before investing.

6. Confidentiality

   We do not ask for and direct you not to share your login credential / username and password of your trading and demat accounts with us or any of our Merchants or any person representing to act on our behalf. We do not handle your trades and will NEVER ask you for your trading and demat account username or password related confidential financial information.

7. Fees

   Subscription charges changes will always be made on prospective basis. Subscription charges provide Members access to the Site. The price in effect when we receive your order will be the price that is charged for subscription. Upgrade offers and special promotions are subject to change. We are not responsible for typographic errors. The subscription charges are pre-payable for all orders. We reserve the right to amend our fees from time to time and fees applicable at time of making payment will apply. The validity of the advisory services is as per the chosen plan and client can renew the services prior to expiry to avoid interruption in services. The terms applicable at time of renewal will apply for the said renewal payment and services.
   
   We do not accept payment in cash. There is no trial offer for our services. Our refund policy is as per SEBI guidelines. Once an order is placed and processed, it cannot be cancelled. All orders are final and any dispute or cancellation will be resolved at our sole discretion. We also reserve our right to disallow anyone from becoming a member on the site to maintain site decorum or any other reason as deemed fit by us. In case the membership is disapproved, the payment will be refunded to the customer.

8. User Information

   User represents and warrants that all information provided, including but not limited to PAN number, name, address, email address, phone number, date of birth, is true, accurate, and complete. If for any means, the Know Your Customer (KYC) norms have not been complied with, user will complete it accurately, including a Video KYC, if required.

9. Terms of Service

   Multiple login with the same username and password is not allowed on the Site. We may impose restriction on an Account if it is found that the account is being used from more than normal number of devices a typical Member would use. In extreme cases, account may be terminated without any refund for violation of this single personal use rule.

   Change to the username, once provided at the time of registration, is not allowed. Some subscription plans come with a pre-specified query quota (exact number available during Registration process). You can use this quota for posting queries in Stock Query section within the duration of your subscription. You can also purchase additional Stock Query Posting quota and get as many queries you need to post. Recharged queries are valid for the duration of the order, just like the queries that came with the original order.

   Answering, refraining from answering or deleting any question or comment posted in the Stock Query column of the Site is at the sole discretion of our Editor and CEO and cannot be challenged. We shall not be held responsible for this. We may, at our sole discretion, impose a limit on the number of queries a user may post as we deem fit. This may be in the form of hourly, daily, monthly or subscription period-based limit for the number of queries a user may post. Any query that is deleted, for whatever reason, will still consume limit from the query quota allotted. No Stock Query posting is allowed on Saturdays and Sundays and Market Holidays, and rule may be updated from time to time. Since Stock Query is only attended to by Mr. S P Tulsian, if Mr. S P Tulsian is not available (e.g. due to ill health or personal commitment or is travelling or any other commitment) then Stock Query posting will be disabled for that duration as well. Based on the feedback we get for queries of a particular Member, his Stock Query limit may be adjusted appropriately, for example, if someone is spoiling decorum on the site and other Members express the same by voting on his/her queries, then limit for Stock Query posting may be reduced or terminated, as deemed fit by us, at our sole discretion. We may update rules to allow or restrict transfer of queries between members. There will be a processing charge for the same, if permitted, which will be based on the number of queries being transferred. Subscription charges or any part of it will not be adjusted towards change or reduction of Stock Query quota allotted to the Member. Additionally, the recharged queries are added to your current order and hence will lapse with the expiry of the current order. The recharge page will show you when your current order is expiring so can plan accordingly. No carry forward of query quota is permitted to subsequent orders and no refund shall be issued for unused queries which lapse when order expires.

   We may reward users for referral of new members to our website (who have never registered or been a member before). Any such points earned will be redeemable on future renewals or payments on the website. There is no cash value for the points accumulated. The terms of usage of the points will be as mentioned in each of the sections of the site and may be updated from time to time, at our sole discretion.

   The subscription is for the use by the registered individual only and the service is a pure advisory service only. Hence we do not seek any rights of Power of Attorney from our clients in any form whatsoever. We do not manage your shares or securities or funds in any manner whatsoever so in the case of death or disability of the client, the wilful owner of the assets may refer to the subscription for decision making as an interim measure. Further, there is no assets held with us which requires transfer or nomination of any kind whatsoever.

   All information is updated on the website only and alerts are additional benefits given to Members. Alerts may be sent in various forms and we may impose limits on the number of channels or combination of channels that Member can subscribe to for alerts. In either case, we do not hold responsibility for timely delivery of any alerts but do best efforts to deliver them as soon as possible. If you do not receive any of the alerts for our recommendations or columns for any reason, we will not be held liable or accountable for any monetary or non-monetary loss suffered by you. Any delay in the receipt of the alerts is also not our responsibility. Alerts may be changed or cancelled without notice and subscription should not be considered as right of alerts. Subscription only entails user access to site and does not guarantee any alerts in any form. Subscription charges or any part of it will not be adjusted towards non-receipt or delay in receipt of the alerts.

   We may impose additional charges for notifications send via SMS or Whatsapp message and members will need to have a separate notification credit balance in subscription account to get SMS / Whatsapp messgae. This notification balance will be valid for current subscription only. If member renews account before older expires, the credit balance will be carried forward. Once an account expires, the balance will lapse and member will need to recharge the credit account if member reactivates account later, to receive SMS / Whatsapp message. Our SMS and Whatsapp alerts are subject to guidelines of Telecom Regulatory Authority of India (TRAI) and Department of Telecom (DoT) as well as to the terms and conditions of third-party merchants, services of whom we avail of. By signing up for these alerts, you expressly consent to receive alerts from us, even if your mobile number is registered under the Do Not Disturb (DND) registry, subject to applicable laws and regulations. To ensure uninterrupted delivery of alerts, you agree to save our designated sender numbers as trusted contacts and not block or intentionally unsubscribe from such alerts while the service remains active.

10. Miscellaneous

    We reserve the right to add, alter, modify, withdraw, replace, wholly or in part, any of the contents and/or columns and/or sections by any other contents and/or columns and/or sections, whether similar or not, or withdraw it altogether without any prior notice. Members and Viewers understand and agree we shall not be liable in any manner whatsoever to them or to any third party for any such amendment, modification, alteration, editing, deletion, suspension or discontinuance of the Site. Any such modification would be carried out at our discretion and not entail Members for a refund of the subscription fees paid by them previously. In case of dispute with any party, our decision will be binding and final. This agreement may be amended by mutual consent of the parties. We may choose modifications without consent to comply with any regulatory updates / changes / compliances as applicable from time to time. 

11. Conflict of Interest

    We shall disclose our holding or position, if any, in our recommendations or securities which are a subject matter of advice. We do not have affiliations with other third-party financial market intermediaries such as brokers. Our associate company Tulsian PMS Limited offers portfolio management services.

12. Jurisdiction

    This Agreement shall be treated as though it were executed and performed in Mumbai, India, and shall be governed by and construed in accordance with the local laws (without regard to conflict of law principles). Any cause of action by you with respect to the Site (and/or any information or services related thereto) must be instituted within one (1) week after the cause of action arose or be forever waived and barred. All actions shall be subject to the limitations set forth in Points 9 and 10 above. The language in this Agreement shall be interpreted as to its fair meaning and not strictly for or against either party. All legal proceedings arising out of or in connection with this Agreement shall be subject to Mumbai jurisdiction only. You expressly submit to the exclusive jurisdiction of said courts.

    Should any part of this Agreement be held invalid or unenforceable, that portion shall be construed consistent with applicable law and the remaining portions shall remain in full force and effect. To the extent that anything in or associated with the Site is in conflict or inconsistent with this Agreement, this Agreement shall take precedence. Our failure to enforce any provision of this Agreement shall not be deemed a waiver of such provision nor of the right to enforce such provision.

    We and User agree to undertake online conciliation and / or online arbitration by participating in the ODR Portal and / or undertaking dispute resolution.

Terms of Use

By using our Site, you agree to comply with and be bound by the following terms of use. Please review the following terms carefully. If you do not agree to these terms, you should not review information or use services of this Site.

1. Copyright

   The content, text, layout, organization, graphics, design, video, compilation, digital conversion and other matters related to the Site are protected under applicable copyrights, trademarks and other proprietary (including but not limited to intellectual property) rights. The copying, redistribution, use or publication by you of any such matters or any part of the Site, except as allowed by Point 3 below, is strictly prohibited. You do not acquire ownership rights to any content, document, information or other materials viewed through the Site. The posting of information on the Site does not constitute a waiver of any right in such information. Option to read articles on site in multiple languages is by an automated tool and hence may be prone to conversion errors (all articles written in English only).

2. Trademarks

   All the Site items are our trademarks or registered trademarks or property. All rights reserved.

3. Limited Right to Use

   The viewing, printing or downloading of any content, text, information, opinion, material, graphic, form or document from the Site grants you only a limited, non-exclusive license for use, solely by you (individual), for your own personal use and not for re-publication, distribution, assignment, sub-license, sale, preparation of derivative works or other use or commercial purpose. Since membership is for individual's personal use, it cannot be taken by a corporate or shared by people. No part of any content, form or document may be reproduced in any form or incorporated into any information retrieval system, electronic or physical, other than for your personal use (but not for resale or redistribution). Any violation intentionally or unintentionally will result in account termination without refund for any subscription fees already paid.

4. Alteration and Modification

   We reserve the unqualified and unlimited right to amend, modify, alter, edit, delete, suspend or discontinue, temporarily or permanently, the Site or any portion thereof and/or the information, statistics, services, and/or materials contained and provided on the Site or any part thereof, with or without prior notice. Members and Viewers understand and agree we shall not be liable in any manner whatsoever to them or to any third party for any such amendment, modification, alteration, editing, deletion, suspension or discontinuance of the Site. Any such modification would be carried out at our discretion and not entail Members for a refund of the subscription fees paid by them previously, either partly or entirely.

5. Indemnification

   You agree to indemnify, defend and hold us and our partners, attorneys, staff and affiliates (collectively, "Affiliated Parties") harmless from any liability, loss, claim and expense, including reasonable attorney's fees, related to your violation of this Agreement or use of the Site.

6. Non-transferable

   Your right to use the Site is not transferable. Any password or right given to you to obtain information, content, document or messages (via any channel such as SMS, Email, Mobile App, Browser Notifications, Whatsapp, Telegram and other) is not transferable. Any violation in the same will be considered as a breach of Agreement and liable to immediate account termination without any refund of the active subscription.

7. Disclaimer and Limits

   The information contained and provided on this Site is of a general nature and it is not our intention to provide any professional advice, solicitation or offer to sell, recommend or purchase securities or act upon the same to Members and/or Viewers of the Site.

   All information, statements, opinions, statistics, services and materials contained, provided and posted on the Site are contained, provided and posted on an "as-is," "as available," basis and all warranties, express or implied, are disclaimed. You must exercise due caution and must verify any and all information sought to be relied upon and/or seek independent professional advice before entering into any commercial or business relationship or transaction with any person or entity, and /or any other party or make any investment or enter into any financial obligation based solely on any information, statement or opinion which is contained, provided, posted or expressed on the Site.

   The Site contains information, statements, opinions, statistics, and materials that have been obtained from sources believed to be reliable and an effort has been made to provide accurate information. However, We make no guarantees whatsoever regarding the timeliness, completeness, accuracy, adequacy, fullness, functionality or reliability of the information, statements, opinions, and materials contained, provided and posted on any section of the Site.

   We or representative of the company or associated parties may have interest / holdings in some of the calls given on the website. This disclosure applies to all sections of the website given on the date of call unless mentioned otherwise explicitly. Calls given are based on fundamentals and/or technical and/or recent new flows and/or trends, as observed in the stock market, globally and in the stock.
   
   The information and services may contain bugs, errors, problems or other limitations. We and our affiliated parties have no liability whatsoever for your use of any information or service. In particular, but not as a limitation thereof, we and our affiliated parties are not liable for any indirect, special, incidental or consequential damages (including damages for loss of business, loss of profits, litigation, or the like), whether based on breach of contract, breach of warranty, tort (including negligence) or otherwise, even if advised of the possibility of such damages. This Site and the information would not be provided without such limitations. No advice or information, whether oral or written, obtained by you from us through the Site shall create any warranty, representation or guarantee not expressly stated in this Agreement.

   All responsibility or liability for any damages caused by viruses contained within the electronic file containing the content, form or document is disclaimed. We will not be liable to you for any incidental, special or consequential damages of any kind that may result from use of or inability to use our Site.
   
   The Member or Viewer of the Site undertakes to indemnify us and our partners for any loss suffered on account of use or misuse of content or services sold on the Site.

8. Third-Party Services

   We allow access to or advertise third-party merchant sites ("Merchants") from which you may purchase certain goods or services. You understand that we do not operate or control the products or services offered by Merchants. Merchants are responsible for all aspects of order processing, fulfilment, billing and customer service. We are not a party to the transactions entered into between you and Merchants. You agree that use of such Merchants is at your sole risk and is without warranties of any kind by us, expressed, implied or otherwise including warranties of title, fitness for purpose, merchantability or non-infringement. Under no circumstances, are we liable for any damages arising from the transactions between you and merchants or for any information appearing on merchant sites or any other site linked to our Site.

9. Third-Party Merchant Policies

   All rules, policies (including privacy policies) and operating procedures of Merchants will apply to you while on such sites. We are not responsible for information provided by you to Merchants. We and the Merchants are independent contractors and neither party has authority to make any representations or commitments on behalf of the other.

10. Links to other Websites

    The Site contains links to other websites. We are not responsible for the content, accuracy or opinions express in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Inclusion of any linked website on our Site does not imply approval or endorsement of the linked website by us. If you decide to leave our Site and access these third-party websites, you do so at your own risk.

11. Information, Media Clippings and Press Releases

    The Site contains information, media clippings and press releases about us, our organization and employees. While this information was believed to be accurate as of the date prepared, we disclaim any duty or obligation to update this information, media clippings or any press releases. Information about companies other than ours contained in the media clippings, press release or otherwise, should not be relied upon as being provided or endorsed by us.

12. Privacy Policy

    Our Privacy Policy, as it may change from time to time, is a part of this Agreement. We are committed to protecting your privacy and utilize technology that gives you the most secure online experience.

1. Information Collection

   We collect information from our users at several different points on our website. SPT Investment Advisory Services Private Limited is the sole owner of the information collected.

2. Registration

   A user is required to give contact information including name, email address, mobile number, address, PAN, Aadhar, KYC Information as required from time to time. We may also download a user's KYC information from service providers as approved by SEBI (not limited to KRA, CKYC, Aadhar, etc.) as the case may be, in which case, the client may be exempted to upload scans of such documents. We use this information for regulatory compliances, to ensure account security and uniqueness and to contact a user in case a problem occurs or for providing information about our services and internal training, customer service and marketing. In addition, if registered users provide payment information (such as credit card number, expiration date etc.) the information is used exclusively for billing purposes only. Also, the user is required to furnish other information related to his or her financial status, which will enable us to assess the risk appetite for the user. The user agrees to provide all true and complete information to the best of the user's knowledge. Providing incorrect or false information, intentionally or unintentionally, may result in account termination without any refund for subscription fees paid earlier, as also, liable for all regulatory penalties and liabilities, if any.

3. Information Use

   All user profiles are stored and kept in our database. SPT Investment Advisory Services Private Limited does not use stored KYC user data (PAN and Aadhar) and settings for marketing purposes for third parties. We do not share your KYC profile (PAN, Aadhar) with other third parties. As required by various governing bodies, the user information is stored on our Site, even after the expiry of the subscription package of the user.

4. Communications from the Site

   We sent alerts / communications by various channels such as SMS, Email, Mobile App Notifications, Browser Notifications, etc. to our Viewers and Members. Viewers and Members can change their alert preferences after logging in on the website. Only alerts related to your account cannot be disabled since these are important information to keep account in good standing. You can choose to remove your mobile number / email id etc. from the account to not hear from us again on those channels, but we highly recommend you keep these to enable us to contact you if there are any issues in your account.

5. Legal Disclaimer for sharing User Information

   Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law, wherein we have a good-faith belief that such action is necessary to comply with a current regulations in force, judicial proceeding, a court order or legal process served on our website. SPT Investment Advisory Services, at its sole discretion, reserves the right to make exceptions to this policy, in extraordinary circumstances (such as a bomb or suicide threat, or instances of suspected illegal activity) on a case-by-case basis. We also make reasonable efforts to protect user information from hacks and other illegal activities and cannot be held liable for any leakage resulting from such incidents.

6. Aggregate Information (non-personally identifiable)

   We may share broadly aggregated demographic information with our partners and / or advertisers. An example of this kind of information is the number of pages served each day, week, or month. This information is not linked to personally identifiable information in any way.

7. Third Party Intermediaries

   We use multiple external third party online payment gateway to bill users for services. This company does not share or use personally identifiable information for any secondary purpose. The payment is stored with the payment gateway and we do not ask for any payment related details, such as credit card number directly from our users.

8. Links

   This web site contains links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site, to read the privacy statements of each and every web site that they visit. This privacy statement applies solely to information collected by this web site.

9. Your Consent

   By using our website, you consent to the collection and use of the information described in this Privacy Policy by SPT Investment Advisory Services Private Limited.

Statutory Disclosures

1. SPT Investment Advisory Services Private Limited, having its registered office at A504, A Wing, Kohinoor Square, NC Kelkar Marg, Shivaji Park, Dadar (W), Mumbai – 400 028, is a SEBI Registered Investment Advisor (SEBI Registration Number: INA000000326), owns and operates www.sptulsian.com. We have been operating this website since 2007 and got SEBI registration in 2013, when the Investment Advisor regulations were first introduced by SEBI. We provide purely listed stocks advisory services only, to our clients, through this website only, by charging Subscription/Membership Fees, as our Professional charges and do not offer any execution or distribution services, of any nature whatsoever to our clients. Clients are required to handle their funds on their own, with their respective stock brokers and they themselves are responsible for executing the trades at their own end. We do not have any affiliation with any other intermediaries and we do not advise any broker to our clients for executing their trades as well.

Disciplinary History: SEBI has not imposed any penalties against the company or its directors for any economic offence and/or for violation of any securities laws, either in respect to advisory services being offered by us, or any other matter related to capital market, as on date.

As per SEBI Circular dated 13 Dec 2021, below is the summary of the complaints received against the Investment Advisor during the previous month:

To view all complaints data, please click here.

2. In case of queries or complaint, you can:

a) Contact our customer support team from the Contact Us page for a quick resolution.
b) Write to the Compliance Officer from the Contact Us page.
c) File a complaint to the company from the Contact Us page if not satisfied with the reply of the team and/or the Compliance Officer.
d) File complaints on SCORES – Easy & quick. Steps for the same are – Register on SCORES portal. Mandatory details for filing complaints on SCORES are Name, PAN, Address, Mobile Number, Email ID.

Benefits: Effective communication and speedy redressal of grievances. In case the client is not satisfied with the SCORES reply/resolution, they can escalate the matter to the Smart ODR portal as well.

3. SPT Investment Advisory Services Private Limited does not receive any consideration by way of remuneration or compensation or in any other form whatsoever, received or receivable by it or any of its associates or subsidiaries, as we are not providing any distribution or execution services, or as professional fees, in respect of the stocks or securities for which the investment advice is provided to the client.

4. SPT Investment Advisory Services Private Limited does not recommend the services of a stock broker or other intermediary to their clients and hence are not in receipt of any consideration by way of remuneration or compensation or in any other form whatsoever. The respective client has to avail the services of such intermediary of their own.

5. SPT Investment Advisory Services Private Limited discloses to the client, its holding or position, as also of its Associates and Directors, if any, in the financial products or securities which are the subject matter of our advice.

6. SPT Investment Advisory Services Private Limited discloses that 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 our objectivity or independence in carrying out investment advisory services. SPT Investment Advisory Services Private Limited shall disclose future conflicts, whenever the same shall arise.

7. SPT Investment Advisory Services Private Limited provides the required facts/reasoning for stocks recommended in the requisite section of the website.

8. SPT Investment Advisory Services Private Limited would like to state that equity investment in the stock market, in general, is a risky investment where significant capital erosion is possible. For leveraged positions, such as F&O, losses may even exceed the initial capital. Hence, invest in equities as per your risk appetite only.

9. We maintain all records of clients digitally as per applicable SEBI, PMLA and other applicable regulations and the same are retained for at least 5–10 years, as applicable under different regulations.

10. We undertake to abide by the Code of Conduct as specified in the Third Schedule of the SEBI (Investment Advisers) Regulations, 2013.

11. Audit reports

Grievance Redressal / Escalation Matrix

Statutory Most Important Terms and Conditions (MITC)

1. The Investment Adviser (IA) shall only accept payments towards its fees for Investment Advisory Services and is not permitted to accept funds or securities in its account on the client’s behalf.

2. The IA does not guarantee returns, accuracy, or risk-free investments. All advice is subject to market risks, and there is no assurance of any returns or profits.

3. Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the IA.

4. Investment advice, only related to securities shall fall under the purview of SEBI. In case of any services offered by IA related to products/services not under the purview of SEBI, IA shall make disclosure to the client and take appropriate declaration and undertaking from the client that such products/services and the services of IA in respect of such products/services do not come under regulatory purview of SEBI and that no recourse is available to the client with SEBI for grievances related to such products/services or services of IA in respect of such products/services.

5. This agreement is for the investment advisory services provided by the IA and IA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client without his/her/its specific and positive consent on every trade. Thus, the client is advised not to permit IA to execute any trade on his/her/its behalf without explicit consent.

6. The fee charged by IA to the client will be subject to the maximum of amount prescribed by SEBI/Investment Adviser Administration and Supervisory Body (IAASB) from time to time (applicable only for Individual and HUF Clients).

Note: (i) The current fee limit under Fixed Fee mode is Rs 1,51,000/- per annum per family of client. Under Assets under Advice (AUA) mode, maximum fee limit is 2.5 per cent of AUA per annum per family of client.

(ii) The IA may change the fee mode at any time with the client’s consent; however, the maximum fee limit in such cases shall be higher of fee limit under the fixed fee mode or 2.5 per cent of AUA per annum per family of client.

(iii) The fee limits do not include statutory charges.

(iv) The fee limits apply only for investment advice related to securities under purview of SEBI.

(v) The fee limits do not apply to a non-individual client / accredited investor.

7. IA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is maximum two quarters. In case of premature termination of the IA services by the client or the IA, the client shall be entitled to seek refund of proportionate fees only for unexpired period. However, IA is entitled to retain a maximum breakage fee of not greater than one-quarter fee.

8. Fees to IA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM), managed by BSE Limited (i.e. currently recognized IAASB). The IA is expected to know the client’s financial details for providing services. Hence, the client is required to share the financial information (e.g. income, existing investments, liabilities, etc.) with the IA.

9. The IA is required to carry out the client’s risk profiling and suitability analysis before providing services and thereafter on an ongoing basis. The services provided will be in line with the assessed risk profile. IA shall also communicate the assessed risk profile to the client.

10. As part of conflict of interest management, the client or the client’s family members will not be provided any distribution services by IA or any of its group entity/ family members. IA shall, wherever available, advice direct plans (non-commission based) of products only. The IA shall endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.

11. For any grievances,

Step 1: The client should first contact the IA using the detail on its website or following contact details:

a) Contact our customer support team from Contact Us for a quick resolution.

b) Write to the Compliance Officer (email available on Contact Us page).

c) File a formal complaint on the Contact Us page on sptulsian.com.

Step 2: If the resolution provided by IA is unsatisfactory, the client can lodge grievances through SEBI’s SCORES platform at scores.sebi.gov.in

Step 3: If the client remains dissatisfied with the outcome of the SCORES complaint, the client may consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in

12. The SEBI registration, enlistment with IAASB, and NISM certification do not guarantee the performance of IA or assure returns to the client.

13. Clients are required to keep contact details, including email id and mobile number/s updated with the IA at all times.

14. The IA shall never ask for the client’s login credentials and OTPs for the client’s Trading Account, Demat Account and Bank Account. Never share such information with anyone including IA.

INVESTOR CHARTER IN RESPECT OF IAs

1. 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.

2. Details of business transacted by the Investment Adviser with respect to the investors

   • To enter into an agreement with the client providing all details including fee details, aspects of Conflict of interest disclosure and maintaining confidentiality of information.

   • To do a proper and unbiased risk – profiling and suitability assessment of the client.

   • To conduct audit annually.

   • To disclose the status of complaints on its website.

   • To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI Office details (i.e. Head office/ regional/ local Office) on its website.

   • To employ only qualified and certified employees.

   • To deal with clients only from official number

   • To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.

   • To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Investment Advisers

   • Not to discriminate in terms of services provided, among clients opting for same/similar products/services offered by investment adviser.

3. Details of services provided to investors (No Indicative Timelines)

   • Onboarding of Clients

     • Sharing of agreement copy

     • Completing KYC of clients

   • Disclosure to Clients

     • To provide full disclosure about its business, affiliations, compensation in the agreement.

     • To not access client’s accounts or holdings for offering advice.

     • To disclose the risk profile to the client.

     • To disclose any conflict of interest of the investment advisory activities with any other activities of the investment adviser.

     • To disclose the extent of use of Artificial Intelligence tools in providing investment advisory services.

   • To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.

   • To treat all advisory clients with honesty and integrity.

   • To make adequate disclosure to the investor of all material facts such as risks, obligations, costs, etc. relating to the products or securities advised by the adviser.

   • To provide clear guidance and adequate caution notice to clients when providing investment advice for dealing in complex and high-risk financial products/services.

   • 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.

   • To disclose the timelines for the various services provided by the investment adviser to clients and ensure adherence to the said timelines.

4. Details of grievance redressal mechanism and how to access it

1. Investor can lodge complaint/grievance against Investment Adviser in the following ways:

   Mode of filing the complaint with investment adviser

   In case of any grievance / complaint, an investor may approach the concerned Investment Adviser 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 Investment Adviser Administration and Supervisory Body (IAASB)

   1. SCORES 2.0 (a web based centralized grievance redressal system of SEBI for facilitating effective grievance redressal in time-bound manner)

      (https://scores.sebi.gov.in)

      Two level review for complaint/grievance against investment adviser:

      • First review done by designated body (IAASB)

      • Second review done by SEBI

   2. Email to designated email ID of IAASB

2. If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.

3. 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 - 400 051

5. 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 - Right to receive information about all the 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 Suitability of the Financial Products

• Right to Exit from Financial product or service in accordance with the terms of agreement with the investment adviser

• 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

6. Expectations from the investors (Responsibilities of investors)

• Do’s

1. Always deal with SEBI registered Investment Advisers.

2. Ensure that the Investment Adviser has a valid registration certificate.

3. Check for SEBI registration number.

   Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:

   https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=13)

4. Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments.

   You may make payment of advisory fees through Centralised Fee Collection Mechanism (CeFCoM) of IAASB if investment adviser has opted for the mechanism.

5. Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.

6. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.

7. Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.

8. Insist on getting the terms and conditions in writing duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.

9. Be vigilant in your transactions.

10. Approach the appropriate authorities for redressal of your doubts / grievances.

11. Inform SEBI about Investment Advisers offering assured or guaranteed returns.

12. Always be aware that you have the right to exit the service of an Investment Adviser

13. Always be aware that you have the right to seek clarifications and clear guidance on advice

14. Always be aware that you have the right to provide feedback to the Investment Adviser in respect of services received.

15. Always be aware that you will not be bound by any clause, prescribed by the investment adviser, which is contravening any regulatory provisions.

• Don’ts

1. Don’t fall for stock tips offered under the pretext of investment advice.

2. Do not provide funds for investment to the Investment Adviser.

3. Don’t fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers. Don’t let greed overcome rational investment decisions.

4. Don’t fall prey to luring advertisements or market rumors.

5. Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.

6. Don’t take decisions just because of repeated messages and calls by Investment Advisers.

7. Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.

8. Don’t rush into making investments that do not match your risk taking appetite and investment goals.

9. Do not share login credential and password of your trading, demat or bank accounts with the Investment Adviser.