TRADYNAL

Investor Charter for Research Analysts

This Investor Charter provides important information to investors regarding the nature of research services, investor rights and responsibilities, services provided by the Research Analyst, grievance redressal mechanism, investor safety information, complaint disclosure and applicable regulatory references.

A. Vision and Mission Statements for Investors

Vision

To provide investors with independent, transparent and research-based information that assists them in understanding securities and making informed investment decisions.

Mission

To provide research and analytical services in a transparent, professional and responsible manner, while maintaining appropriate disclosures, protecting investor interests and communicating material information relevant to the research services provided.

B. Details of Business Transacted by the Research Analyst with Respect to Investors

• TRADYNAL provides independent research and analytical services to investors.
• Research services may cover equity research, index research, equity derivatives, commodity derivatives and other permitted research areas.
• Research reports and recommendations are prepared based on information and analysis considered relevant by the Research Analyst.
• Research services may include fundamental, technical and quantitative analysis, as applicable.
• Research communication may include research reports, market updates, analytical observations and other permitted research-related communication.
• Research recommendations are subject to applicable disclosures and market risks.
• TRADYNAL does not provide execution services or distribution services as part of its research analyst activity.
• Investors are advised to independently evaluate research information and consider their own objectives, financial position and risk appetite before making investment decisions.

C. Details of Services Provided to Investors

1. Onboarding of Clients

• Client onboarding is undertaken through the applicable KYC and consent process.
• Relevant client information and declarations may be collected as applicable.
• Applicable terms, fees, disclosures and risk information are communicated to clients.

2. Disclosure to Clients

• Applicable regulatory disclosures are made available to investors.
• Information relating to risks associated with securities markets is communicated to clients.
• Applicable conflict-of-interest and research-related disclosures are provided.
• Fees and applicable service terms are communicated before availing the research services.
• Investors are informed about the nature and scope of research services.

3. Research Services

• Equity research and analysis.
• Index and market analysis.
• Equity derivatives research.
• Commodity derivatives research.
• Fundamental, technical and quantitative research, as applicable.
• Periodic research communication and updates, where applicable.
• Research reports and recommendations subject to applicable disclosures and terms.

Research services are provided subject to applicable regulatory requirements, client terms, disclosures and market conditions.

D. Grievance Redressal Mechanism and How to Access It

1. First Level – TRADYNAL

Investors may first approach TRADYNAL for resolution of any complaint or grievance relating to the research services provided.

Investors may contact TRADYNAL through the grievance/contact details provided on this website.

2. Second Level – SEBI SCORES

If the grievance is not resolved satisfactorily, investors may approach SEBI through the SCORES platform, subject to the applicable process and requirements.

SEBI SCORES(opens in a new tab)

3. Online Dispute Resolution – SMART ODR

Investors may also use the applicable Online Dispute Resolution mechanism for resolution of disputes, subject to the applicable framework and eligibility.

SMART ODR(opens in a new tab)

E. Rights of Investors

• Right to receive relevant information about the Research Analyst and the research services offered.
• Right to receive applicable disclosures before availing research services.
• Right to receive information regarding applicable fees and service terms.
• Right to receive research services in accordance with applicable regulatory requirements.
• Right to receive information relating to material conflicts of interest, where applicable.
• Right to raise complaints or grievances regarding the services received.
• Right to access the applicable grievance redressal mechanism.
• Right to receive fair and transparent treatment.
• Right to information regarding risks associated with research recommendations.
• Right to discontinue the research service in accordance with the applicable terms and conditions.

F. Responsibilities of Investors

Do's

• Provide complete and accurate information during onboarding and KYC.
• Read applicable terms, disclosures and risk information carefully.
• Understand the nature and scope of the research services being availed.
• Consider your own investment objectives, financial situation and risk appetite before taking investment decisions.
• Independently evaluate research reports and recommendations.
• Keep your contact and KYC information updated.
• Maintain records of relevant communication, reports and transactions.
• Use only official communication channels for contacting TRADYNAL.
• Raise grievances through the prescribed mechanism whenever required.

Don'ts

• Do not share passwords, OTPs, trading account credentials, card details or other confidential financial information.
• Do not assume that research recommendations guarantee profits or returns.
• Do not make investment decisions solely on the basis of past performance.
• Do not transfer funds to unauthorised persons claiming to represent TRADYNAL.
• Do not rely on unauthorised or misleading communication using the TRADYNAL name.
• Do not ignore applicable risk disclosures and investment risks.
• Do not treat research information as a guarantee of future market performance.

G. Important Investor Safety Information

• Investment in securities markets is subject to market risks.
• Research reports and recommendations do not provide any assurance or guarantee of returns.
• Past performance is not indicative of future results.
• Investors should independently assess their financial situation, investment objectives and risk appetite.
• Investors should verify that communications are received through authorised TRADYNAL channels.
• Investors should not share OTPs, passwords, trading credentials, bank credentials or other confidential information.
• Investors should exercise caution against fraudulent persons or entities falsely claiming association with TRADYNAL.
• Any research recommendation should be considered together with the applicable risk disclosures and other relevant information.

H. Investor Complaint Disclosure

TRADYNAL maintains and discloses applicable investor complaint information in accordance with the requirements applicable to Research Analysts.

Investors may contact TRADYNAL for any complaint or grievance relating to the research services provided. Applicable complaint status and disclosure information may be updated periodically.

I. Regulatory References

The Investor Charter and related disclosures are provided with reference to the applicable regulatory framework governing Research Analysts and investor protection requirements.According to Circular No.: SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81.

• SEBI regulatory framework applicable to Research Analysts.
• Applicable SEBI circulars and directions relating to Research Analysts.
• Applicable investor protection and grievance redressal requirements.
• Applicable disclosure and conduct requirements.

View SEBI Investor Charter Circular(opens in a new tab)

The particulars given in this Disclosure Document have been prepared in accordance with the applicable SEBI (Research Analysts) Regulations, 2014, as amended from time to time, and the applicable SEBI Master Circular for Research Analysts.

1. About the Research Analyst

Afjal Mansuri is registered with the Securities and Exchange Board of India (SEBI) as an Individual Research Analyst and operates under the brand name TRADYNAL.

SEBI Registration No.: INH000028608

Research Analyst: Afjal Mansuri, Proprietor of TRADYNAL

Registered Office: Bharat Palace, Dug Road, Pachpahar, Bhawani Mandi, KOTA, RAJASTHAN – 326502

2. Qualification and Experience

The Research Analyst has obtained the applicable NISM certification required for carrying out Research Analyst activities and maintains the qualifications and certifications required under the applicable SEBI regulatory framework.

3. Business Activity

TRADYNAL provides research and analytical services in securities markets. Research services may cover listed Indian equities, equity derivatives, index derivatives, commodity derivatives and related market segments, based on applicable research methodology and analysis.

Research may include fundamental analysis, technical analysis, quantitative analysis, equity research, index research, F&O research, commodity research, market analysis and related research communication.

The Research Analyst does not provide execution or distribution services as part of its Research Analyst activity. Clients are responsible for taking their own investment decisions and executing transactions through their chosen authorised intermediary.

4. Disciplinary History

As on the date of this disclosure, the Research Analyst has no disciplinary history or material penalties, directions, legal proceedings or findings of inspections or investigations against the Research Analyst that are required to be disclosed under the applicable regulatory framework.

5. Use of Artificial Intelligence Tools

Where Artificial Intelligence (AI) or technology-based tools are used in the preparation, analysis, processing or presentation of research, the Research Analyst shall remain responsible for the security, confidentiality and integrity of client data and for the research service based on the output of such tools, in accordance with applicable regulatory requirements.

Any material use of AI tools relevant to the research service shall be disclosed to clients as required under the applicable SEBI regulatory framework.

6. Terms and Conditions on which Research is Issued

The Research Analyst exercises due diligence in checking the correctness and authenticity of information used in research reports. Research is based on information believed to be reliable and on the Research Analyst's own analysis.

Research services are issued only to clients who have accepted the applicable Terms and Conditions of Research Services, including the Most Important Terms and Conditions (MITC), where applicable.

7. Ownership, Financial Interest and Conflict of Interest

Unless specifically disclosed in a particular research report or public appearance, the Research Analyst shall make applicable disclosures regarding financial interests and material conflicts of interest.

• The Research Analyst shall disclose any financial interest in the subject company where required.
• The Research Analyst shall not allow personal financial interests or commercial considerations to compromise the independence and objectivity of research.
• The Research Analyst shall not have an actual or potential material conflict of interest that is not appropriately disclosed where disclosure is required.
• Client interests shall take primacy in research recommendations.
• Information received from clients shall be kept confidential and shall not be used for personal interest.
• Actual or potential conflicts shall be identified, managed and disclosed in accordance with the applicable Conflict of Interest Policy and SEBI requirements.

8. Compensation and Other Relationships

Unless specifically disclosed in the relevant research report or public appearance:

• The Research Analyst does not receive compensation from a subject company for providing a research recommendation.
• The Research Analyst does not manage or co-manage a public offering of securities of the subject company.
• The Research Analyst does not receive compensation for investment banking, merchant banking or brokerage services from the subject company.
• The Research Analyst does not receive compensation for any other products or services from the subject company in a manner that creates an undisclosed conflict.
• The Research Analyst does not receive compensation or other benefits from the subject company or any third party in connection with the research report, except where appropriately disclosed.
• The Research Analyst does not serve as an officer, director or employee of the subject company and does not engage in market-making activity for the subject company, except where specifically disclosed.

Any exception to the above will be disclosed in the relevant research report or public appearance, as applicable.

9. Other Disclosures

• The Research Analyst does not recommend any particular stock broker or other intermediary and does not receive consideration from an intermediary for such recommendation.
• Research recommendations are intended to be distributed to eligible clients in accordance with the applicable regulatory framework and without unfair discrimination.
• The Research Analyst shall maintain appropriate independence between research activities and other activities.
• Personal trading by the Research Analyst and persons covered by the applicable regulatory requirements shall be governed by the applicable Personal Trading Policy.
• The Research Analyst shall comply with applicable trading restrictions relating to securities that are the subject of research recommendations.
• The Research Analyst shall not trade, directly or indirectly, in securities that are the subject of a research recommendation within the applicable restricted period, including the prescribed period of 30 days before and 5 days after publication of the research report, subject to applicable regulatory provisions.
• The Research Analyst shall not engage in insider trading, front-running or any activity that may compromise the integrity or independence of research.
• Where third-party research is used or reviewed, applicable checks and disclosures regarding material conflicts shall be made.

10. Standard Warning and Disclaimer

11. Investor Responsibility

Investors should carefully read the applicable research reports, risk disclosures, Terms and Conditions, MITC and other relevant documents before availing research services or acting on any research recommendation. Investment decisions remain the sole responsibility of the investor.

As per Regulation 2 of the SEBI (Research Analysts) Regulations, 2014, as amended from time to time.

Research Analyst – Regulation 2(1)(u)

"Research analyst" means a person who, for consideration, is engaged in the business of providing research services and includes a part-time research analyst.

Research Services – Regulation 2(1)(wa)

Research services means the following services provided by a research analyst:

1. preparation or publication of the research report or content of the research report; or
2. providing or issuing research report or research analysis; or
3. making 'buy/sell/hold' recommendation; or
4. giving price target or stop loss target; or
5. offering an opinion concerning public offer; or
6. recommending model portfolio; or
7. providing trading calls; or
8. any other service of similar nature or character,

with respect to securities that are listed or proposed to be listed in a stock exchange, whether or not any such person has the job title of 'research analyst', to the clients or other persons or group of persons or general public.

Trading Calls – Regulation 2(1)(zc)

"Trading calls" means intraday, ultra-short duration, non-delivery based (other than hedging) recommendation or any recommendation related to securities that are not personalized or investor specific.

Consideration – Regulation 2(1)(fa)

"Consideration" means any form of economic benefit including non-cash benefit, received or receivable, directly or indirectly, in any form whether from client or otherwise for providing research services.

Family – Regulations 2(1)(fb) and 2(1)(fc)

• Family of an individual research analyst includes the individual research analyst, spouse, children and parents.
• Family of client includes the individual client, dependent spouse, dependent children and dependent parents.

Securities Covered

Research is provided on "securities" as defined under the applicable securities laws, which may include shares, scrips, stocks, bonds, debentures and other marketable securities; derivatives; units of collective investment schemes and mutual funds; security receipts; Government securities; other instruments declared as securities by the Central Government; and rights or interests in securities.

Services Offered by TRADYNAL

Afjal Mansuri, Proprietor of TRADYNAL, provides research and analytical services in listed Indian securities and applicable derivatives based on fundamental, technical and quantitative analysis.

The research services of TRADYNAL may include:

• Equity Research
• Index F&O Research
• Equity F&O Research
• Commodity F&O Research
• Fundamental analysis
• Technical analysis
• Quantitative analysis
• Research reports and research analysis
• Buy/Sell/Hold recommendations, where applicable
• Price target and stop-loss levels, where applicable
• Trading calls, where applicable
• Market and sectoral analysis
• Index and derivatives analysis
• Research-based model portfolios, where applicable

Research services are provided subject to the applicable Terms and Conditions, disclosures, risk disclosures, client consent and the applicable SEBI regulatory framework.

What a Research Analyst does NOT do

• Execute trades or operate client trading, demat or bank accounts.
• Accept funds or securities from clients for investment.
• Offer assured, guaranteed or fixed returns.
• Provide distribution services as part of Research Analyst activity, subject to applicable regulatory requirements.
• Take custody of client funds or securities.
• Ask clients to share trading passwords, demat passwords, bank passwords, OTPs, PINs or other confidential authentication credentials.

Conflict of Interest

TRADYNAL shall identify, avoid, manage and disclose actual or potential conflicts of interest in accordance with its applicable Conflict of Interest Policy and the SEBI regulatory framework.

• The client's interest shall take primacy in research recommendations.
• Research shall be prepared independently and objectively.
• Personal interests, financial interests or commercial considerations shall not be allowed to compromise research independence.
• Material conflicts of interest shall be appropriately disclosed in research reports, public appearances or other applicable communications.
• Personal trading and applicable trading restrictions shall be governed by the applicable Personal Trading Policy and SEBI requirements.

Research Methodology

Depending on the nature of the research service, TRADYNAL may use fundamental analysis, technical analysis, quantitative analysis, market data, financial information, company information and other relevant publicly available or appropriately sourced information.

Research recommendations are based on the Research Analyst's analysis and are subject to market risks. Past performance, if referred to, is not indicative of future results.

Investor Responsibility

Investors should read the applicable research report, risk disclosures, Terms and Conditions, MITC and other relevant documents carefully before making any investment decision. Investors should consider their own financial position, objectives and risk appetite and should independently evaluate the information provided.

Third Schedule read with Regulation 24(2) of the SEBI (Research Analysts) Regulations, 2014, as amended from time to time.

Afjal Mansuri, Proprietor of TRADYNAL, SEBI Registered Individual Research Analyst (Reg. No. INH000028608), shall abide by the following Code of Conduct at all times. The Code of Conduct requires a Research Analyst to act honestly and in good faith, exercise due skill, care and diligence, address conflicts of interest, maintain confidentiality, observe professional standards and comply with applicable regulatory requirements.

1. Honesty and Good Faith

The Research Analyst shall act honestly and in good faith in all professional dealings and while providing research services to clients and other persons.

2. Diligence

The Research Analyst shall act with due skill, care and diligence and shall ensure that research reports are prepared after appropriate and thorough analysis.

3. Conflict of Interest

The Research Analyst shall effectively identify, address, manage and disclose actual or potential conflicts of interest which may affect the impartiality or independence of research analysis and research reports.

• Client interests shall take primacy in research recommendations.
• Personal, financial or commercial interests shall not compromise the independence and objectivity of research.
• Material conflicts of interest shall be appropriately disclosed wherever applicable.
• Information received from clients shall be handled confidentially and shall not be used for personal interest.

4. Insider Trading or Front Running

The Research Analyst and employees, if any, shall not engage in insider trading or front running of the Research Analyst's own research reports or otherwise act in a manner that compromises the integrity of research.

5. Confidentiality

The Research Analyst and employees, if any, shall maintain confidentiality of research reports, client information and other confidential information until such information is made public or disclosure is otherwise permitted or required under applicable law or regulation.

6. Professional Standard

The Research Analyst and employees, if any, engaged in research analysis shall observe high professional standards while preparing and communicating research reports and recommendations.

7. Compliance

The Research Analyst shall comply with all applicable laws, regulations, SEBI requirements, circulars, directions and other regulatory requirements applicable to the conduct of its business activities.

8. Responsibility of Proprietor

As proprietor of TRADYNAL, the Research Analyst bears primary responsibility for ensuring the maintenance of appropriate standards of conduct, implementation of applicable policies and adherence to proper procedures.

9. Independence of Research

Research shall be prepared independently and objectively. The Research Analyst shall take reasonable steps to ensure that research analysis and recommendations are not improperly influenced by external pressure, commercial considerations or personal interests.

10. Personal Trading

Personal trading by the Research Analyst and persons covered by applicable regulatory requirements shall be governed by the applicable Personal Trading Policy. Applicable restrictions relating to securities that are the subject of research recommendations shall be followed.

The Research Analyst shall observe the applicable restriction on dealing or trading in securities that are the subject of a research recommendation, including the prescribed restricted period of 30 days before and 5 days after publication of the research report, subject to applicable regulatory provisions.

11. Client Fair Treatment

The Research Analyst shall provide fair treatment to clients and shall not discriminate amongst clients in a manner inconsistent with applicable regulatory requirements. Research recommendations and relevant disclosures shall be communicated in accordance with the applicable regulatory framework.

12. No Assured Returns

The Research Analyst shall not provide any assurance, guarantee or promise of assured, fixed or guaranteed returns or profits from research recommendations.

13. Research Integrity

• Research reports shall be prepared using information and analysis considered relevant and reliable.
• Material information and applicable disclosures shall be appropriately considered.
• The Research Analyst shall not knowingly make misleading statements or manipulate research findings.
• Recommendations shall be subject to applicable risk disclosures and market risks.

14. Client Information and Data

Client information obtained during onboarding or while providing research services shall be handled with appropriate confidentiality and security. The Research Analyst shall not misuse client information for personal or unauthorised purposes.

15. Grievance and Regulatory Cooperation

The Research Analyst shall maintain an appropriate grievance redressal mechanism and shall cooperate with SEBI, RAASB, BSE or other competent regulatory authorities in accordance with applicable requirements.

16. Review and Monitoring

The Code of Conduct and related internal policies shall be reviewed periodically and whenever there are material changes in applicable laws, SEBI regulations, circulars or the nature of TRADYNAL's research activities.

Adoption

This Code of Conduct is adopted by TRADYNAL and shall be reviewed at least annually and whenever required by applicable regulatory or business changes.

TRADYNAL is committed to prompt, fair and transparent redressal of every investor grievance. Clients and prospective clients may use the following steps to raise and escalate a grievance relating to research services.

Escalation Matrix

Investors should first approach TRADYNAL through the designated grievance/contact details before filing a complaint with SEBI.

Step 1 – Contact the Research Analyst

For any grievance relating to TRADYNAL's research services, clients may contact Afjal Mansuri, Proprietor & Research Analyst:

• Email: tradynal@gmail.com
• Phone: +91 9587326502
• Address: Bharat Palace, Dug Road, Pachpahar, Bhawani Mandi, KOTA, RAJASTHAN – 326502

Please mention your name, registered mobile/e-mail, research plan or service subscribed and complete details of the grievance. Every grievance shall be acknowledged, recorded and addressed promptly and in any case within the applicable regulatory timeline, which shall not be later than 21 calendar days from receipt of the grievance.

Step 2 – SEBI SCORES 2.0

If the grievance is not resolved within the applicable timeline or you are not satisfied with the resolution, you may lodge a complaint through SEBI's Complaints Redress System (SCORES).

SEBI SCORES 2.0(opens in a new tab)

Complaints against Research Analysts are subject to the applicable review mechanism, including review by the designated body/RAASB and subsequent review by SEBI, as applicable.

Step 3 – Online Dispute Resolution (SMART ODR)

If you are still not satisfied, you may use the applicable Online Dispute Resolution mechanism for resolution of the dispute through online conciliation and/or arbitration, subject to the applicable framework and eligibility.

SMART ODR(opens in a new tab)

Physical Complaints to SEBI

Investors may also approach SEBI through the applicable physical complaint mechanism:

Office of Investor Assistance and Education
Securities and Exchange Board of India
SEBI Bhavan, Plot No. C4-A, 'G' Block
Bandra-Kurla Complex, Bandra (East)
Mumbai – 400 051

SEBI Toll-Free Helpline: 1800 22 7575 / 1800 266 7575

Complaint Data

TRADYNAL shall maintain and publish applicable investor complaint information in accordance with the requirements prescribed for Research Analysts and the applicable SEBI regulatory framework. Complaint data shall be updated periodically in the prescribed format and within the applicable timeline.

Important Information for Investors

• Investors should first approach TRADYNAL for resolution of a grievance relating to its research services.
• Investors should retain copies of relevant communication, research reports, payment records and other documents relating to the grievance.
• Investors should provide complete and accurate information while submitting a grievance.
• TRADYNAL does not require investors to share trading passwords, demat passwords, bank passwords, OTPs, PINs, UPI PINs or other confidential authentication credentials for grievance resolution.
• Grievances shall be handled fairly, transparently and without discrimination.

Grievance Escalation and Conflict of Interest

TRADYNAL shall handle investor grievances independently and fairly. Any actual or potential conflict of interest that could affect the impartial handling of a grievance shall be appropriately identified and managed in accordance with the applicable Conflict of Interest Policy and regulatory requirements.

Format as per Annexure E of the SEBI Master Circular for Research Analysts dated February 06, 2026. Complaint data is updated by the 7th of every month.

A. Data for the month ending 30 September 2026

Number of complaints received during the month against the RA due to impersonation by some other entity: 0

* 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 total number of complaints resolved in the current month.

B. Trend of monthly disposal of complaints

C. Trend of annual disposal of complaints

Registered with SEBI on 20 July 2026. Years before registration are not applicable.

Investor Complaint and Impersonation Disclosure

TRADYNAL maintains applicable records of investor complaints received through direct communication, SEBI SCORES and other applicable sources. Any complaint received shall be recorded, reviewed and addressed in accordance with the applicable SEBI regulatory framework.

Investors are advised to verify communications received in the name of TRADYNAL and should not share trading account passwords, demat passwords, bank credentials, OTPs, PINs or other confidential authentication information with any person.

TRADYNAL is a SEBI Registered Research Analyst and provides research services to clients under the applicable SEBI regulatory framework. By accessing this website or availing research services, you confirm that you have read and understood this disclosure.

Nature of the service

1. The Research Analyst provides research services only. The Research Analyst does not provide portfolio management, distribution services or execution of trades, and does not handle client funds or securities.
2. Recommendations are not personalised to any individual's financial situation or risk profile. Before investing, consider your own financial condition, objectives and risk appetite and consult a SEBI-registered Investment Adviser if you need personalised investment advice.
3. Investments in securities are subject to market risks, including loss of capital. Derivatives (futures and options) are complex, leveraged, high-risk products and may result in losses exceeding the amount invested.
4. No assurance, guarantee or promise of returns, profits, accuracy or target achievement is given. Any assured, guaranteed or fixed-return scheme is prohibited by law and is never offered by TRADYNAL.

Research and information

5. Research is prepared with due care from sources believed to be reliable; however, the completeness or timeliness of third-party data cannot be warranted. Opinions reflect the Research Analyst's judgement on the date of the report and may change without notice.
6. The Research Analyst, associates or relatives may hold positions in securities covered by research, subject to the applicable Personal Trading Policy and disclosures made in each report.
7. Any view shared with a client on a specific existing position is research opinion only and is not personalised investment advice.
8. Simulated, hypothetical or back-tested results, where used, do not represent actual trading and are not indicative of future results.

Confidentiality of research

9. Research reports and recommendations are meant only for the subscribed client. Forwarding, copying, publishing or sharing them with any other person, in any form or medium, is not permitted and may lead to termination of services and applicable legal action.

Social media and public content

10. Content posted on social media, YouTube, Telegram or other public channels is for education and illustration only and is not a research recommendation unless specifically identified and issued as research in accordance with the applicable regulatory framework. Securities quoted in general educational content may be for illustration only and may not be recommendatory.

Technology

11. Research may be delivered electronically through E-mail, WhatsApp or other authorised communication channels. Delivery may be delayed or fail because of network, device or platform issues beyond the Research Analyst's control. Please report non-receipt promptly through the grievance process.

Beware of fraud

12. The Research Analyst will never ask for your trading, demat or bank login credentials or OTPs, and will never ask you to transfer funds for investment. Fees are accepted only through the payment modes stated in the applicable Terms and Conditions and are not collected in cash or into a third-party account. Investors should verify the registration details through official SEBI sources and use only the official TRADYNAL contact details.

Conflict of Interest

TRADYNAL shall identify, avoid, manage and disclose actual or potential conflicts of interest that may affect the impartiality or independence of research analysis and research reports.

• The client's interest shall take primacy in research recommendations.
• Personal, financial or commercial interests shall not be allowed to compromise the independence and objectivity of research.
• Material financial interests or other material conflicts, where applicable, shall be disclosed in the relevant research report or public communication.
• Personal trading shall be governed by the applicable Personal Trading Policy and regulatory requirements.
• The applicable trading restriction, including the prescribed 30 days before and 5 days after publication restriction for securities that are the subject of a research recommendation, shall be followed subject to applicable regulatory provisions.
• The Research Analyst shall not engage in insider trading, front-running or any activity that may compromise the integrity of research.

Investor responsibility

Investors should carefully read all applicable research reports, risk disclosures, Terms and Conditions, MITC and other relevant documents before investing or availing research services. Investors should independently evaluate the risks and suitability of any investment decision.

Jurisdiction

13. This website and the research services are governed by the laws of India, subject to the applicable jurisdiction of the courts at Kota, Rajasthan, without prejudice to the investor's right to use applicable SEBI grievance redressal mechanisms, including SCORES and the SMART ODR mechanism.

Futures and options (F&O) research is a high-risk service. Please read this risk disclosure carefully before acting on any derivatives recommendation.

Key risks of derivatives trading

1. Leverage risk

Derivatives provide leveraged exposure. Small movements in the underlying asset can result in significant gains or losses.

2. Loss risk

Trading in derivatives can result in substantial losses. In certain situations, losses may exceed the initial margin deposited.

3. Time decay risk (Options)

Options are time-sensitive instruments. Option buyers may lose the entire premium if the expected market movement does not occur before expiry.

4. Volatility risk

Unexpected market events and rapid price fluctuations can significantly impact derivative positions.

5. Liquidity risk

Certain contracts may experience lower liquidity, making it difficult to enter or exit positions at desired prices.

6. Gap risk

Markets may open significantly higher or lower due to overnight developments, resulting in losses beyond anticipated levels.

Risk disclosures on derivatives

• 9 out of 10 individual traders in the equity Futures and Options Segment incurred net losses.
• On an average, loss makers registered net trading loss close to ₹50,000.
• Over and above the net trading losses incurred, loss makers expended an additional 28% of net trading losses as transaction costs.
• Those making net trading profits incurred between 15% to 50% of such profits as transaction cost.

Source: SEBI study dated January 25, 2023 on "Analysis of Profit and Loss of Individual Traders dealing in equity Futures and Options (F&O) Segment", wherein aggregate level findings are based on annual Profit/Loss incurred by individual traders in equity F&O during FY 2021-22. SEBI publishes updated studies from time to time.

What this means for you

• Derivatives are leveraged. A small price move can cause a loss larger than the margin you deploy.
• Every F&O recommendation should be considered together with its applicable entry, target, stop-loss and time frame, where provided. Decide your own position size and never trade with money you cannot afford to lose.
• Recommendations are research, not personalised investment advice, and carry no assurance of returns.
• Options can expire worthless. Intraday and expiry-day trades can carry particularly high risk.

SEBI investor advisory

SEBI has highlighted the risks associated with individual trading in the equity Futures & Options segment. Investors are advised to carefully assess their financial situation, investment objectives and risk tolerance before participating in derivatives trading.

Research disclaimer

Any derivative-related research, analysis, market commentary or recommendations provided by TRADYNAL:

• are subject to market risks;
• do not assure or guarantee profits or returns;
• may not be suitable for every investor;
• should be evaluated independently before acting upon.

Investor responsibility

Before trading derivatives, investors should:

• understand the product and associated risks;
• use appropriate risk-management practices;
• trade only with capital they can afford to risk;
• seek professional advice where necessary;
• carefully read the applicable research report, risk disclosures and other related documents.

Conflict of Interest

TRADYNAL shall identify, avoid, manage and disclose actual or potential conflicts of interest that may affect the independence or objectivity of derivative-related research.

• The client's interest shall take primacy in research recommendations.
• Personal, financial or commercial interests shall not compromise the independence of research.
• Material conflicts of interest shall be appropriately disclosed where applicable.
• Personal trading in securities covered by research shall be governed by the applicable Personal Trading Policy and regulatory requirements.
• The applicable trading restriction, including the prescribed 30 days before and 5 days after publication restriction for securities that are the subject of a research recommendation, shall be followed subject to applicable regulatory provisions.

Important caution for F&O investors

Futures and options involve leverage and may result in rapid losses. Investors should understand the contract, margin requirements, expiry, liquidity, volatility and applicable costs before entering into any derivatives transaction. No research recommendation should be treated as a guarantee of profit.

Content published via the official social media handles, channels and videos of TRADYNAL, represented by Afjal Mansuri, SEBI Registered Research Analyst (Reg. No. INH000028608), is intended strictly for illustration, knowledge and informational purposes only.

Short Version (Profile Bio / Video Description)

Nature of social media content

• Posts, visuals, opinions, or discussions shared on social-media platforms do not constitute a buy / sell / hold recommendation on any security or financial instrument.
• Viewers and users are strongly advised to consult a SEBI-registered Investment Adviser or other appropriate professional before acting on any information shared online.
• Securities mentioned or displayed are for illustration and educational purposes only and are not recommendations unless specifically identified and issued as research in accordance with the applicable regulatory framework.
• Past performance, if any, is not indicative of future results.
• There is no avenue for claiming damages / losses incurred based on the recommendations in the research report, where applicable.
• Investors should make investment decisions according to their own financial situation, objectives and risk tolerance.

Protection against social media scams

Common scam tactics to watch for:

Conflict of Interest

TRADYNAL shall identify, avoid, manage and disclose actual or potential conflicts of interest that may affect the independence or objectivity of any research-related communication.

• Social media content shall not be used to conceal or avoid applicable research disclosures.
• Any material conflict of interest relating to a research recommendation shall be disclosed in the relevant research communication, where applicable.
• Personal interests or financial interests shall not be allowed to compromise the independence and objectivity of research.
• Personal trading shall be governed by the applicable Personal Trading Policy and regulatory requirements.

Research recommendations through social media

• Public social media posts, comments, groups and direct messages are not a substitute for research reports issued to subscribed clients.
• Research recommendations, where provided, shall be issued only through the applicable authorised research-service communication channels after the client has accepted the applicable Terms and Conditions, including MITC.
• No assured, guaranteed or fixed returns are offered through any social media channel.
• TRADYNAL does not ask investors for trading, demat or bank passwords, OTPs, PINs or other confidential authentication credentials through social media.

Protect yourself from fake profiles, cloned websites and scam "tips"

Afjal Mansuri (SEBI Reg. No. INH000028608) cautions investors against fraudsters who may impersonate TRADYNAL by using its name, logo, website identity or SEBI registration number on fake websites, apps, social media profiles, Telegram/WhatsApp groups and phone calls, often promising assured or guaranteed returns.

Please remember

• TRADYNAL never promises assured, guaranteed or fixed returns, "jackpot" or "sure-shot" calls. Any such promise is a scam and is prohibited by law.
• TRADYNAL never asks for your trading, demat or bank login credentials, passwords, PINs or OTPs, and never trades on your behalf.
• TRADYNAL never asks you to transfer money for investment. Fees are accepted only through the applicable banking channels into TRADYNAL's own account, or through CeFCoM where applicable — never to a personal wallet or third-party account.
• Research services are provided only to subscribed clients through the authorised communication channels applicable to the research service.

Our only official channels

Any other website, number, group or profile claiming to represent TRADYNAL should be treated with caution. Investors should verify the Research Analyst's registration through the official SEBI website.

Verify registration on SEBI website(opens in a new tab)

If you suspect impersonation or fraud

1. Do not make any payment or share any personal, trading, banking or account information.
2. Inform TRADYNAL immediately at tradynal@gmail.com or +91 9587326502.
3. Lodge a complaint on SEBI SCORES(opens in a new tab) where applicable.
4. For suspected cyber fraud, report the incident through the National Cyber Crime Reporting Portal(opens in a new tab) or call the cybercrime helpline 1930.

Important investor safety reminder

TRADYNAL does not guarantee returns, profits or investment outcomes. Investors should independently verify communications, registration details and payment instructions before taking any action.

Terms & Conditions with MITC for Research Services

This document sets out the terms and conditions applicable to research services provided by TRADYNAL. By availing research services, the client acknowledges and agrees to the applicable terms, disclosures, fees, risks and responsibilities stated herein.

1. Nature of Research Services & No Trade Execution

TRADYNAL provides research and analytical services to clients based on applicable research methodologies and available information. The services may include equity research, index research, equity derivatives research and commodity derivatives research.

TRADYNAL does not execute trades on behalf of clients and does not operate or control the client's trading or investment account. Clients are responsible for placing and executing their own trades through their authorised broker.

2. Fees and Applicable Fee Limit

Research services are provided against applicable fees as communicated to the client before commencement of the service. Applicable taxes and statutory charges, wherever applicable, shall be payable in addition to the service fee.

3. Advance Fees and Refund on Premature Termination

TRADYNAL may receive applicable research service fees in advance for the selected service period. Any refund on premature termination shall be dealt with in accordance with the applicable terms, service period and regulatory requirements.

Clients should carefully review the selected plan, applicable fee and service period before making payment.

4. Payment Method

Payment for research services shall be made through the payment method communicated or authorised by TRADYNAL. Clients should make payments only through official payment channels.

Cash payments, unauthorised payment requests or payments to personal accounts of unknown persons should be avoided. TRADYNAL shall not be responsible for payments made through unauthorised channels.

5. Conflict of Interest

TRADYNAL shall maintain appropriate policies and disclosures relating to actual or potential conflicts of interest in accordance with applicable regulatory requirements.

Where applicable, relevant disclosures regarding conflicts of interest shall be made to clients as required under the applicable regulatory framework.

6. No Assured or Guaranteed Returns

TRADYNAL does not provide any assurance or guarantee of returns, profits or performance from any research report, recommendation or research service.

7. No Guarantee of Returns, Profit or Accuracy

Research information and recommendations are prepared using information and analytical methods considered relevant by the Research Analyst. However, no guarantee is provided regarding the accuracy, completeness or future performance of any research view or recommendation.

Market conditions may change and research outcomes may differ from expectations.

8. Market Risk and Client's Own Judgment

Any investment decision involves market risk and the client should use independent judgement before acting on any research report or recommendation.

Clients should consider their investment objectives, financial position, risk appetite and other relevant circumstances before making an investment decision.

Research services should not be considered as a substitute for the client's own evaluation of the risks and suitability of an investment.

9. Registration Does Not Guarantee Performance

SEBI registration of a Research Analyst does not guarantee the performance of the research services, accuracy of recommendations or returns from investments.

SEBI registration should not be interpreted as an endorsement or assurance of investment performance.

10. Grievance Redressal

Clients may raise complaints or grievances relating to research services through the applicable grievance redressal mechanism.

• Step 1 – TRADYNAL: Clients may first approach TRADYNAL for resolution of their grievance.
• Step 2 – SEBI SCORES: If the grievance is not resolved satisfactorily, the client may approach SEBI through the SCORES platform, subject to the applicable process.

SEBI SCORES(opens in a new tab)

• Step 3 – SMART ODR: Clients may also use the applicable Online Dispute Resolution mechanism, subject to the applicable framework.

SMART ODR(opens in a new tab)

TRADYNAL shall maintain and disclose applicable investor complaint information as required under the applicable regulatory framework.

11. Keep Contact Details Updated

Clients are required to keep their contact details, email address and other relevant information updated with TRADYNAL so that important service-related communications can be delivered appropriately.

12. Never Share Login Credentials or OTPs

Clients should never share passwords, OTPs, trading account credentials, bank credentials, card details or other confidential financial information with TRADYNAL or any unauthorised person.

13. TRADYNAL Research Services and Current Fee Schedule

The following research services and applicable fees are offered by TRADYNAL. Applicable taxes and statutory charges may be additional wherever applicable.

The applicable fee schedule may be revised in accordance with applicable regulatory requirements and the terms communicated to clients.

14. Client Responsibilities

• Provide accurate and complete information during onboarding and KYC.
• Read and understand the applicable Terms & Conditions before availing research services.
• Make payments only through authorised TRADYNAL payment channels.
• Keep contact and KYC information updated.
• Consider personal investment objectives, financial position and risk appetite before making investment decisions.
• Do not share OTPs, passwords, trading credentials or other confidential information.
• Do not represent yourself as an authorised representative of TRADYNAL without written authorisation.

15. Additional Terms

Research services shall be provided subject to applicable regulatory requirements, disclosures, policies and service terms applicable from time to time.

TRADYNAL may update or modify these Terms & Conditions where required due to regulatory changes, changes in services or other applicable requirements. Clients shall be informed of material changes wherever applicable.

16. Regulatory Reference

These Terms & Conditions are provided with reference to the applicable SEBI regulatory framework governing Research Analysts and investor protection requirements.

TRADYNAL shall comply with the applicable regulatory requirements, disclosures and conduct requirements applicable to its Research Analyst activities.

Clients should refer to the latest applicable SEBI regulations, circulars and directions for current regulatory requirements.

SEBI Official Website(opens in a new tab)

Fee Structure & Refund Policy

As per Regulation 15A of the RA Regulations and Para 1.9 of the SEBI Master Circular for Research Analysts dated February 06, 2026.

1. Fee limit

1. For clients who are individuals or Hindu Undivided Families (HUF), the Research Analyst charges a maximum of ₹1,51,000 (Rupees One Lakh Fifty-One Thousand only) per annum per family of client for all research services. The limit excludes statutory charges such as GST.
2. "Family of client" means the individual client, dependent spouse, dependent children and dependent parents (Regulation 2(1)(fc)).
3. The fee limit, advance-fee and refund provisions do not apply to non-individual clients and accredited investors, whose fees are governed by bilaterally negotiated terms.
4. The fee limit is revised by RAASB once in three years based on the Cost Inflation Index, in consultation with SEBI.

2. Plans offered

Plans and fees will be published here before any paid service begins. No fee is charged until the client has accepted the Terms and Conditions (including MITC).

Individual Research Services:

• Equity Research: ₹3,500 per month
• Index F&O Research: ₹4,000 per month
• Equity F&O Research: ₹3,500 per month
• Commodity F&O Research: ₹4,000 per month

All-in-One Research Plans:

• Monthly: ₹12,500 — regular combined value ₹15,000
• Quarterly: ₹35,000 — regular combined value ₹45,000
• Half-Yearly: ₹65,000 — regular combined value ₹90,000
• Annual: ₹1,20,000 — regular combined value ₹1,80,000

Applicable statutory charges and taxes, wherever applicable, shall be payable in addition to the applicable research service fee.

3. Advance fee

Fees may be charged in advance only if agreed by the client, and the advance shall not exceed fees for a period of one year.

4. Mode of payment

Fees are accepted only through online bank transfer (NEFT/RTGS/IMPS) and cheque, into the Research Analyst's own account. Cash is not accepted. Fees are never collected through a third party.

Clients may also pay through the optional Centralised Fee Collection Mechanism (CeFCoM) administered by BSE Limited.

5. Refund policy

1. If services are terminated before the end of the subscription period, by the client or by the Research Analyst, the client is refunded proportionate fees for the unexpired period.
2. No breakage fee is charged.
3. If the Research Analyst's registration is suspended for more than 60 days or cancelled, fees are refunded on a pro-rata basis from the effective date of suspension/cancellation to the end of the subscription period.
4. Refunds are made to the account from which the fee was received, within a reasonable time from the termination request.

6. Consent first

No fee is charged and no research service is rendered until the client's consent on the Terms and Conditions (including MITC) is received.

Privacy Policy

TRADYNAL respects the privacy of clients, investors and visitors to its website. This Privacy Policy explains, in simple terms, what information may be collected, why it may be used, how it is protected, and how you can contact TRADYNAL about privacy-related questions.

1. Information We May Collect

Depending on the service or interaction, TRADYNAL may collect information such as:

• Name and contact details such as email address and mobile number.
• Information submitted through the website enquiry or contact form.
• Information required for client onboarding, KYC, consent and applicable regulatory records.
• Communication and service-related information provided by a client.
• Basic technical information required for website operation, security and troubleshooting.

TRADYNAL seeks to collect information that is relevant to the purpose for which it is required.

2. No Unauthorised Sharing

Personal information is not intended to be sold or shared with unrelated third parties for their independent marketing purposes.

Information may be disclosed where necessary to provide a requested service, comply with applicable law or regulatory requirements, respond to a lawful request, protect the website and its users, or prevent fraud, misuse or security incidents.

3. Purpose Limitation

Information may be used for legitimate and relevant purposes, including:

• Responding to enquiries and requests for research services.
• Client onboarding, KYC, consent and service administration.
• Providing and communicating about research services and related documents.
• Maintaining records and fulfilling applicable regulatory, legal and compliance obligations.
• Improving website functionality, security and user experience.

Information should not be used for an unrelated purpose without appropriate basis or consent where consent is required.

4. Data Security Measures

TRADYNAL takes reasonable measures intended to protect information against unauthorised access, alteration, disclosure, misuse or loss.

• Access to information is limited to what is required for the relevant purpose.
• Reasonable administrative and technical safeguards may be used to protect information.
• Security and access practices may be reviewed and updated when required.

No internet transmission or electronic storage system can be guaranteed to be completely secure.

5. Service Updates & Communication

TRADYNAL may use contact details provided by a client or visitor to respond to enquiries, communicate service information, send updates, provide important notices, or communicate regarding an existing research service relationship.

Where promotional or non-essential communication is sent, reasonable options may be provided to stop or limit such communication, subject to applicable requirements.

6. Authorisation for Communication

By providing contact details and requesting information or services, you authorise TRADYNAL to contact you for purposes connected with your enquiry, onboarding, service delivery, regulatory communication or other legitimate business communication.

You should provide only information that is accurate and necessary for the relevant purpose.

7. Do Not Share Sensitive Credentials

For your security, do not send TRADYNAL your trading account password, demat account password, bank login credentials, OTP, PIN, UPI PIN, card PIN or similar authentication information.

If any person claiming to represent TRADYNAL asks for such credentials, do not share them and verify the communication through the official contact details published on the TRADYNAL website.

8. DND / Communication Preferences

If you do not wish to receive non-essential communications, you may request TRADYNAL to update your communication preference by contacting the official email address below.

Regulatory, contractual, transactional or service-related communications may still be sent, where they are necessary or required.

9. Surveys, Polls & Feedback

TRADYNAL may occasionally request feedback about its website or services. Participation in optional surveys or feedback activities is voluntary unless otherwise stated.

Information collected for feedback will be used for the stated purpose and handled in accordance with this Privacy Policy.

10. Website Links & Third-Party Services

The TRADYNAL website may contain links to regulatory websites, payment services, communication platforms or other third-party websites. These third-party practices are governed by their own policies.

Users should review the applicable third-party terms and privacy notices before submitting information to those services.

11. Data Retention

Information may be retained for as long as reasonably necessary for the purpose for which it was collected and for applicable legal, regulatory, accounting, audit, dispute-resolution and record-keeping requirements.

Different records may have different retention periods depending on the applicable requirement.

12. Your Responsibility

Clients and visitors should take reasonable care when sharing personal information online, use official TRADYNAL communication channels, keep their own account credentials confidential, and promptly inform TRADYNAL if they believe an unauthorised communication has occurred.

13. Changes to this Privacy Policy

TRADYNAL may update this Privacy Policy from time to time to reflect changes in its services, technologies, legal requirements or regulatory framework.

The updated version will be published on this page with the applicable effective date.

These terms govern use of the website only. Research services are governed by the Terms and Conditions of Research Services (including MITC) accepted by each client.

1. Acceptance

By accessing this website ("the Website"), operated by Afjal Mansuri, Proprietor of TRADYNAL, SEBI Registered Research Analyst (Reg. No. INH000028608), you agree to these Terms of Use. If you do not agree, please do not use the Website.

2. Licence to use content

1. Content on the Website is provided for personal, non-commercial information. You may not copy, modify, republish, frame, mirror, sell or commercially exploit any content, or remove any copyright or proprietary notice.
2. Research reports and recommendations in any client area are licensed only to the subscribed client and may not be shared (see the applicable Disclaimer).
3. You may not attempt to decompile, scrape or disrupt the Website or its security.

3. No offer of assured returns

Nothing on the Website is an offer of assured, guaranteed or fixed returns. Public pages contain general and educational information only and are not research recommendations.

4. Accuracy and availability

The Website is updated periodically. While care is taken, the Website may contain technical or typographical errors, and availability may be interrupted for maintenance or for reasons beyond the operator's control.

5. External links

Links to third-party websites, including SEBI, BSE, SCORES and SMART ODR, are provided for convenience. TRADYNAL is not responsible for the content of third-party websites, and a link does not imply endorsement.

6. Fees and refunds

Fees, advance fees and refunds are governed by the Terms and Conditions of Research Services and the Fee Structure and Refund Policy, in accordance with the applicable SEBI regulatory framework. On premature termination, applicable refunds shall be dealt with in accordance with the applicable fee and refund terms.

7. Privacy

Personal data collected through the Website is handled as per the Privacy Policy. TRADYNAL does not request trading account passwords, demat passwords, bank passwords, OTPs, PINs, UPI PINs or other authentication credentials through the Website or enquiry process.

8. Changes to these terms

These Terms of Use may be revised by updating this page. Any change to the applicable voluntary clauses of the Terms and Conditions of Research Services will be notified to clients in accordance with applicable SEBI requirements.

9. Governing law

These Terms of Use are governed by the laws of India, subject to the applicable jurisdiction of the courts at Kota, Rajasthan, without prejudice to an investor's right to use applicable SEBI grievance redressal mechanisms, including SCORES and SMART ODR.

Regulatory Reference: Para 16 of the SEBI Master Circular for Research Analysts dated February 06, 2026 (General Guidelines for dealing with Conflicts of Interest) and Regulation 24(1).

1. Purpose

This policy sets out how Afjal Mansuri, Proprietor of TRADYNAL, SEBI Registered Research Analyst (Reg. No. INH000028608), identifies, avoids, manages and discloses actual or potential conflicts of interest, and the internal code governing conduct.

2. Commitments

The Research Analyst shall:

1. at all times maintain high standards of integrity in the conduct of business;
2. ensure fair treatment of clients and not discriminate amongst them;
3. ensure that personal interest does not, at any time, conflict with the duty to clients, and that the client's interest always takes primacy in research recommendations;
4. make appropriate disclosure to clients of possible sources or potential areas of conflict of interest which would impair the ability to render fair, objective and unbiased services;
5. reduce opportunities for conflict through appropriate measures such as information barriers and appropriate internal controls;
6. place appropriate restrictions on transactions in securities while handling a mandate of an issuer or client in respect of such security;
7. not deal in securities while in possession of material non-published information;
8. not communicate material non-published information while dealing in securities on behalf of others;
9. not in any way contribute to manipulation of the demand for or supply of securities in the market or influence prices of securities;
10. not have an incentive structure that encourages sale of products not suitable for the risk profile of clients;
11. not share information received from clients, or obtained as a result of dealings with them, for personal interest;
12. maintain appropriate records and disclosures relating to actual or potential conflicts of interest;
13. ensure that research recommendations are prepared independently and are not influenced by personal financial interests, commercial considerations or external pressure;
14. disclose material conflicts of interest wherever such disclosure is applicable to the research service, research report or public communication.

3. Specific safeguards for an individual RA

• Arm's-length relationship: research activity is kept separate from all other activities in accordance with the applicable regulatory requirements (Regulation 24(1)).
• No distribution: the Research Analyst does not provide distribution services, and applicable restrictions relating to distribution and research services shall be followed.
• Personal trading: personal trading shall be governed by the applicable Personal Trading Policy and Regulation 16 of the SEBI (Research Analysts) Regulations, 2014.
• 30-day / 5-day trading restriction: the Research Analyst, its associates and other persons covered by the applicable regulation shall not deal or trade, directly or indirectly, in securities that are the subject of a research recommendation within 30 days before and 5 days after publication of the research report on the subject company, subject to applicable regulatory provisions.
• Trading contrary to recommendation: the Research Analyst and persons covered by the applicable regulatory requirements shall not deal or trade directly or indirectly in securities that are reviewed in a manner contrary to the recommendation given.
• Personal holdings: personal holdings and transactions shall be managed so that they do not compromise the independence, objectivity or integrity of research.
• No favourable-review promises: no promise or assurance of favourable review shall be given to any company, sector or group as consideration for business or compensation.
• Association: TRADYNAL shall avoid direct or indirect association with persons who provide securities advice/recommendations without required SEBI registration or make impermissible return/performance claims, as applicable.
• Third-party research: where third-party research is used or reviewed, reasonable care shall be taken to identify misleading statements and applicable material conflicts shall be appropriately disclosed.

4. Identification and Management of Conflicts

Potential conflicts may arise from personal holdings, personal trading, relationships with issuers or companies, business relationships, compensation arrangements, outside interests, family interests or any other circumstance that may affect the independence of research.

Where an actual or potential conflict is identified, TRADYNAL may take appropriate measures, including disclosure, restriction of activity, segregation of information, recusal from a particular research activity or any other measure considered necessary under the applicable regulatory framework.

5. Disclosure

Conflicts are disclosed in the Standard Disclosures, in each research report and in every public appearance, as applicable under the regulatory framework and Regulation 19.

TRADYNAL will make appropriate disclosures where a conflict of interest could reasonably affect the objectivity or independence of the research or recommendation.

6. Client Information and Confidentiality

Information received from clients or obtained as a result of dealings with clients shall be handled confidentially and shall not be used for personal interest or in a manner that may adversely affect the interests of clients, except where disclosure is required or permitted under applicable law or regulation.

7. Review

This policy is reviewed at least annually and whenever applicable laws, regulations, SEBI circulars or the nature of TRADYNAL's research activities change.

Under the Prevention of Money Laundering Act, 2002, the PML (Maintenance of Records) Rules, 2005 and the SEBI Master Circular / applicable guidelines on Anti-Money Laundering (AML) Standards and Combating the Financing of Terrorism (CFT).

1. Introduction and applicability

This policy is adopted by Afjal Mansuri, Proprietor of TRADYNAL, SEBI Registered Research Analyst (Reg. No. INH000028608), to prevent the research business from being used, intentionally or unintentionally, for money laundering or terrorist financing. It is designed for the nature of TRADYNAL's research services and applicable regulatory requirements.

• The Research Analyst provides research services only. It does not hold, manage or handle client funds or securities and does not execute transactions for clients.
• The only money received from clients is the research fee, which is accepted only through authorised banking channels into the Research Analyst's own account.
• Clients are onboarded through the applicable KYC and client acceptance process and relevant information is obtained as required.

2. Objectives

1. Prevent the business from being used for money laundering (ML) or terrorist financing (TF).
2. Apply Client Due Diligence (CDD) before providing services, and Enhanced Due Diligence (EDD) where the applicable risk assessment requires it.
3. Screen clients against applicable sanctions lists and act on freezing orders where required.
4. Recognise, record and report suspicious transactions to FIU-IND where applicable.
5. Maintain records as required under the applicable PMLA, PML Rules, SEBI regulations and circulars.

3. Principal Officer and Designated Director

As an individual Research Analyst, the proprietor is responsible for overseeing the AML/CFT framework, client due diligence, record keeping, identification of suspicious activity and applicable regulatory reporting. The Research Analyst shall maintain appropriate records and respond to requests from SEBI, RAASB, FIU-IND or other competent authorities as applicable.

4. Client acceptance policy

1. No client is onboarded in a fictitious, anonymous or benami name.
2. No client is onboarded where the applicable fee is offered in cash or from an unauthorised third-party account.
3. No client is onboarded where applicable KYC/CDD cannot be applied, or where the information provided appears non-genuine, incomplete or insufficient and the client does not cooperate in providing the required information.
4. No client is onboarded where applicable sanctions screening identifies a prohibited or designated person or entity under applicable law, including relevant United Nations Security Council sanctions and other applicable Indian legal requirements.
5. The client's consent on applicable Terms and Conditions, including MITC where applicable, is obtained before research services begin.

5. Client Due Diligence (CDD)

1. Verify client identity using applicable KYC requirements and records, including name, PAN, address, contact details and the service subscribed.
2. For non-individual clients, identify and verify beneficial owner(s) as required under applicable PMLA Rules and SEBI requirements.
3. Understand the purpose and expected nature of the relationship and use of research services.
4. Speak to the client or verify the registered e-mail/mobile before starting services where appropriate.
5. Update KYC and CDD periodically and whenever there is a change in client circumstances or reasonable doubt about information previously obtained.

6. Risk categorisation

Clients may be categorised as Low, Medium or High ML/TF risk based on applicable risk factors, including client location, nature of business/occupation, source of payment, manner of engagement and other relevant circumstances. The risk category may be reviewed and updated when circumstances change.

Clients of Special Category: applicable higher-risk categories may include non-resident clients, high-net-worth individuals, trusts, charities, NGOs and organisations receiving donations, clients with close family relationships or beneficial ownership involving politically exposed persons (PEPs), clients in high-risk jurisdictions identified by FATF or applicable authorities, and other categories requiring enhanced scrutiny.

EDD measures: additional documents, verification of source of payment, closer review of the relationship and approval by the responsible person may be required where enhanced due diligence is considered necessary.

7. Sanctions screening and freezing orders

1. Screen clients before onboarding and re-screen where required against applicable United Nations, UAPA and other relevant sanctions/designated-person lists as updated.
2. If a client matches a designated individual or entity, services shall not be provided and further action shall be taken in accordance with applicable law and regulatory directions.
3. Knowledge of every screening decision and relevant records shall be maintained as required.

8. Recognising suspicious transactions

Alerts may include:

• a client whose identity is difficult to verify or who will not cooperate;
• fees paid from unrelated third-party accounts, multiple accounts or overseas accounts without a reasonable explanation;
• requests to pay in cash or to route fees through unusual channels;
• a source of funds inconsistent with the client's apparent circumstances;
• a client asking the Research Analyst to handle funds, trade on their behalf or share research with unknown persons;
• a client in a high-risk jurisdiction or linked to sanctioned persons or entities;
• transactions or payment arrangements where requested documentation is not provided.

9. Reporting to FIU-IND

1. Any suspicious transaction, including an attempted or abandoned transaction where applicable, shall be assessed and recorded with the reasons and reported to FIU-IND where required under applicable law.
2. Cash transactions shall be handled in accordance with the applicable regulatory framework. TRADYNAL does not accept cash for research service fees.
3. Information relating to suspicious transaction reporting shall be kept confidential and shall not be disclosed to the concerned client except where permitted or required by law.

FIU-IND: Financial Intelligence Unit – India, Department of Revenue, Ministry of Finance, Government of India.

10. Record keeping

1. KYC, CDD and client identification records shall be preserved for the period required under applicable law and regulatory requirements, including applicable record-retention requirements.
2. Records of transactions, fee receipts and other relevant records shall be maintained for the applicable prescribed period and longer where required for an ongoing investigation, proceeding or regulatory requirement.
3. Records shall be maintained so that relevant transactions and client information can be reconstructed and produced to SEBI, RAASB, FIU-IND or other competent authorities when lawfully required.

11. Hiring, training and awareness

The Research Analyst shall remain updated on applicable AML/CFT requirements, SEBI circulars, PMLA requirements and FIU-IND updates and shall maintain appropriate awareness regarding KYC, CDD, suspicious transactions, sanctions screening and confidentiality requirements.

12. Conflict of Interest and AML/CFT Controls

TRADYNAL shall maintain appropriate controls to ensure that commercial, personal or other interests do not interfere with client identification, due diligence, risk categorisation, sanctions screening or suspicious transaction reporting.

• Client interests and regulatory obligations shall take priority over personal or commercial considerations.
• Information obtained during KYC, CDD and AML/CFT processes shall be handled confidentially and shall not be used for personal interest.
• No client shall receive preferential treatment in AML/CFT controls because of personal, commercial or other relationships.
• Any actual or potential conflict that could affect the objective application of AML/CFT controls shall be appropriately identified, managed and disclosed where required.

13. Monitoring and reporting

• Monitor client interactions and requests for signs of irregular or illicit use of research services.
• Report any suspicious client behaviour or requests to the appropriate authority where required.
• Maintain confidentiality and prevent tipping-off.
• File applicable reports with FIU-IND within the prescribed timelines where a reporting obligation arises.
• Maintain appropriate records of AML/CFT review, screening and reporting activities.

14. Client communication and third parties

TRADYNAL does not hold or manage client funds or securities. Research service fees are accepted through authorised payment channels into the Research Analyst's own account. Any third-party service provider used for KYC or related compliance functions shall be subject to applicable due diligence, confidentiality and regulatory requirements.

15. Policy review

This policy shall be reviewed annually, or upon significant regulatory updates, amendments to the PMLA/PML Rules, applicable SEBI AML/CFT requirements, or changes in the nature of TRADYNAL's business.

TRADYNAL is committed to making its website usable and accessible to everyone, including persons with disabilities and users who use assistive technologies. TRADYNAL aims to provide an inclusive digital experience and continually improve the accessibility, usability and readability of its website.

Our commitment

We strive to design and maintain the website in accordance with applicable digital accessibility requirements and recognised accessibility standards, including the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA and applicable SEBI directions relating to digital accessibility.

TRADYNAL also takes into consideration the Rights of Persons with Disabilities Act, 2016 and applicable requirements issued for regulated entities. SEBI's digital accessibility directions require regulated entities to ensure that their digital platforms and content adhere to accessibility standards including WCAG 2.1 or the latest version and applicable GIGW guidelines.

What we have done

• Designed the website with accessibility and ease of use in mind.
• Important website features are intended to be usable with keyboard navigation, with visible focus indicators where applicable.
• Text, headings, links and navigation are structured to support users of screen readers and other assistive technologies.
• Images used for meaningful content are provided with appropriate alternative text where applicable.
• Forms are designed with labels and clear instructions to make them easier to understand and complete.
• Colour contrast and readable typography are considered throughout the website.
• The website is designed to remain usable across different screen sizes, including mobile devices, tablets and desktop displays.
• Animations and motion are used with consideration for users who may prefer reduced motion.
• Content and navigation are reviewed periodically to identify opportunities for accessibility improvements.

Accessibility features

• Keyboard-accessible navigation and interactive elements.
• Clear headings and structured page sections.
• Descriptive link and button text wherever applicable.
• Form labels and accessible input instructions.
• Responsive layout for mobile, tablet and desktop displays.
• Readable text and appropriate spacing for improved usability.
• Support for users who use assistive technologies, subject to browser, device and assistive-technology compatibility.
• Reduced-motion considerations for users whose devices or browsers request reduced motion.

Known limitations

• Linked third-party websites, including regulatory and grievance platforms such as SEBI, SCORES and SMART ODR, are outside TRADYNAL's direct control.
• Third-party content, documents or services may have their own accessibility limitations.
• PDF documents or other downloadable documents, when provided, will be reviewed for accessibility and an accessible alternative or assistance may be provided where reasonably possible upon request.
• Accessibility may vary depending on the user's browser, operating system, device, assistive technology and internet connection.

Ongoing commitment

Accessibility is an ongoing commitment. TRADYNAL will continue to monitor the website and improve its content, structure, navigation and features wherever reasonably possible. The website may be updated from time to time to reflect changes in technology, accessibility practices and applicable regulatory requirements.

Feedback

If you experience any difficulty accessing content, navigating the website, using a form, reading information or using any website feature, please contact TRADYNAL and describe the issue. Your feedback will help us identify accessibility barriers and improve the website.

TRADYNAL aims to respond to accessibility-related concerns within a reasonable time and, where feasible, provide the required information or reasonable assistance.

Accessibility and Regulatory Compliance

TRADYNAL is committed to following applicable SEBI requirements relating to digital accessibility. SEBI issued directions in 2025 requiring regulated entities to comply with digital accessibility requirements, and subsequent SEBI communications have clarified and extended timelines relating to such requirements.

Conflict of Interest and Accessibility

TRADYNAL will seek to ensure that accessibility-related assistance, communication and information are provided fairly and without discrimination. Accessibility requirements shall not be compromised because of personal, commercial or other interests. Any actual or potential conflict that could affect the fair provision of accessibility support or information shall be appropriately identified and managed in accordance with TRADYNAL's applicable Conflict of Interest Policy.