Compliance | Qubit Prime - SEBI Research Analyst

Investor Rights

Investor Charter

As per SEBI Circular No. SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/81 dated June 2, 2025

A. Vision and Mission

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.

B. Details of Business Transacted

To publish research report based on the research activities of the RA
To provide an independent unbiased view on securities
To offer unbiased recommendation, disclosing the financial interests in recommended securities
To provide research recommendation, based on analysis of publicly available information and known observations
To conduct audit annually
To ensure that all advertisements are in adherence to the provisions of the Advertisement Code for Research Analysts
To maintain records of interactions with all clients including prospective clients (prior to onboarding), where any conversation related to the research services has taken place

C. Details of Services Provided (No Indicative Timelines)

Onboarding of Clients - Sharing of terms and conditions of research services; completing KYC of fee paying clients
Disclosure to Clients - Disclosing material information for informed decisions including business activity, disciplinary history, terms and conditions, associates, risks and conflicts of interest; disclosure of AI tool usage; disclosure of third-party research conflicts; disclosure of conflicts with other activities
To distribute research reports and recommendations to clients without discrimination
To maintain confidentiality with respect to publication of the research report until made available in the public domain
To respect data privacy rights of clients and protect against unauthorized use of confidential information
To disclose timelines for services and ensure adherence
To provide clear guidance and adequate caution notice for complex and high-risk financial products/services
To treat all clients with honesty and integrity
To ensure confidentiality of client information unless required by law or client has provided consent

D. Grievance Redressal Mechanism

With Research Analyst: Grievance shall be redressed not later than 21 days of receipt.

SCORES 2.0 - scores.sebi.gov.in - Two-level review: first by RAASB, second by SEBI
Email to RAASB - Designated email of the Research Analyst Administration and Supervisory Body
Smart ODR - smartodr.in - Online conciliation or arbitration if resolution is unsatisfactory

Physical complaints: Office of Investor Assistance and Education, SEBI Bhavan, Plot No. C4-A, 'G' Block, Bandra-Kurla Complex, Bandra (E), Mumbai - 400 051

E. 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 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 timely redressal
Right to Exit from financial product or service in accordance with agreed terms and conditions
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 access services in a suitable manner even if differently abled
Right to provide feedback on financial products and services used
Right against coercive, unfair, and one-sided clauses in financial agreements

F. Expectations from Investors

✓ Do's

Always deal with SEBI registered Research Analyst and ensure valid registration certificate
Check SEBI registration at sebi.gov.in
Pay attention to disclosures in research reports before investing
Pay fees through banking channels only; maintain duly signed receipts. May use CeFCoM of RAASB if opted by RA
Check research recommendation before buying/selling securities or applying in public offer
Ask all questions and clear doubts before acting on recommendation
Seek clarification for complex and high-risk products
Be aware of your right to stop availing services as per agreed terms
Be aware of your right to provide feedback
Know you are not bound by any clause contravening regulatory provisions
Inform SEBI about Research Analyst offering assured or guaranteed returns

✕ Don'ts

Do not provide funds for investment to the Research Analyst
Don't fall prey to luring advertisements or market rumors
Do not get attracted to limited period discount or other incentives, gifts, etc.
Do not share login credentials and passwords of your trading, demat, or bank accounts with the Research Analyst

Client Terms

Most Important Terms & Conditions

As per SEBI Circular dated February 17, 2025 - forming part of the Terms and Conditions for providing research services.

Standardised by Industry Standards Forum (ISF) in consultation with RAASB and SEBI.

These terms and conditions, and consent thereon are for the research services provided by the Research Analyst (RA) and RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client. Thus, the clients are advised not to permit RA to execute any trade on their behalf.

The fee charged by RA to the client will be subject to the maximum amount prescribed by SEBI/RAASB from time to time (applicable only for Individual and HUF Clients).

2.1 Current fee limit: ₹1,51,000/- per annum per family for all research services of the RA.
2.2 The fee limit does not include statutory charges.
2.3 Fee limits do not apply to non-individual clients / accredited investors.

RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one quarter. In case of pre-mature termination of RA services by either party, the client shall be entitled to seek refund of proportionate fees only for the unexpired period.

Fees to RA 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 recognised RAASB).

The RA is required to abide by the applicable regulations/circulars/directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavour to promptly inform the client of any conflict of interest that may affect the services being rendered.

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 RA.

The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA's research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of research report.

Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on investments made based on the recommendations in the research report. Any reliance placed on the research report shall be as per the client's own judgement and assessment.

The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.

For any grievances:

Step 1 - Contact the RA: saloni@smaheshwari.in | +91 98330 00005
Step 2 - SEBI SCORES platform at scores.sebi.gov.in
Step 3 - Online Dispute Resolution at smartodr.in

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

The RA 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 RA.

Regulatory

Mandatory Disclosures

Website-level regulatory disclosures required under SEBI (Research Analysts) Regulations, 2014. Client-specific terms are covered in the MITC above.

⚠️ Investment in securities market are subject to market risks. Read all the related documents carefully before investing.

Registration Disclaimer

Registration granted by SEBI and Enlistment with RAASB/BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

Conflict of Interest Policy

The Research Analyst and associates may from time to time hold long or short positions in, and buy or sell securities covered in research reports. Any actual or potential conflict of interest is disclosed in the relevant research report as required under Regulation 16 of the SEBI (Research Analysts) Regulations, 2014. The Research Analyst has not received any compensation from companies subject to research recommendations, nor managed or co-managed their public offerings, unless explicitly disclosed in the report.

AI Tools

This Research Analyst does not use Artificial Intelligence (AI) tools in the preparation of research reports or research services. All research is prepared manually by the registered Research Analyst as required to be disclosed under Regulation 19(vii) of the RA Regulations.

Applicable Regulations

Governed by the SEBI (Research Analysts) Regulations, 2014 (as amended, including the Third Amendment dated December 16, 2024), the SEBI Master Circular for Research Analysts dated June 27, 2025, and all circulars and guidelines issued by SEBI and RAASB thereunder.

Escalation

Grievance Redressal / Escalation Matrix

As required under SEBI (Research Analysts) Regulations, 2014

Details of Designation	Contact Person Name	Address where the physical address location	Contact No.	Email Id	Working Hours
Customer Care	Saloni Maheshwari	House No. 65, Sector 7, Panchkula, Haryana 134109	+91 98330 00005	saloni@smaheshwari.in	10 AM - 5 PM
Head of Customer Care	Saloni Maheshwari	House No. 65, Sector 7, Panchkula, Haryana 134109	+91 98330 00005	saloni@smaheshwari.in	10 AM - 5 PM
Compliance Officer	Saloni Maheshwari	House No. 65, Sector 7, Panchkula, Haryana 134109	+91 98330 00005	saloni@smaheshwari.in	10 AM - 5 PM
Principal Officer	Saloni Maheshwari	House No. 65, Sector 7, Panchkula, Haryana 134109	+91 98330 00005	saloni@smaheshwari.in	10 AM - 5 PM

External Escalation

Platform	Purpose	Website	Helpline
SEBI SCORES	First-level review by RAASB, second-level by SEBI	scores.sebi.gov.in	1800 22 7575
Smart ODR	Online conciliation / arbitration if SCORES unsatisfactory	smartodr.in	-

Accessibility Grievance Mechanism

Grievance Redressal Mechanism - Accessibility Compliance (SEBI Circular dated July 31, 2025)

In compliance with the SEBI circular, Qubit Prime (Saloni Maheshwari) has established a dedicated grievance redressal mechanism to address accessibility-related complaints from Persons with Disabilities (PwDs).

1. Dedicated Channels

Email: saloni@smaheshwari.in
Helpline: +91 98330 00005 (Mon-Fri, 10:00 AM - 5:00 PM)
SEBI SCORES: scores.sebi.gov.in

2. Process & Timelines

Acknowledgement within 2 working days.
Resolution within 15 working days.
Complex issues will be communicated clearly with revised timelines.

3. Escalation

Nodal Officer: Saloni Maheshwari
Email: saloni@smaheshwari.in
Further: SEBI SCORES

Transparency

Investor Complaints

Trend of Monthly Disposal of Complaints

Published by the 7th of each month as mandated by SEBI. Last updated: [07 May 2026]

Data for the month ending: [April, 2026]

Formats for investor complaints data to be disclosed monthly by RAs on their website/mobile application

Sr. No.	Received From	Avg. Resolution time^ (in days)
1	Directly from Investors	N/A
2	SEBI (SCORES)	N/A
3	Other Sources (if any)	N/A
	Grand Total	N/A

Number of complaints received during 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) divided by total complaints resolved in the current month.

Trend of Monthly Disposal of Complaints

Sr. No.	Month	Carried forward from previous month	Received	Resolved*	Pending#
1	May 2026	0	0	0	0
	Grand Total	0	0	0	0

* Inclusive of complaints of previous months resolved in the current month. # Inclusive of complaints pending as on the last day of the month.

Trend of Annual Disposal of Complaints

Sr. No.	Year	Carried forward from previous year	Received	Resolved*	Pending#
1	2026-27	0	0	0	0
	Grand Total	0	0	0	0

* Inclusive of complaints of previous years resolved in the current year. # Inclusive of complaints pending as on the last day of the year.

Compliance

Annual Compliance Audit Reports

As required under Regulation 25(3) of the SEBI (Research Analysts) Regulations, 2014. Audit is conducted annually by an independent auditor and the report is submitted to RAASB within one month of completion.

Audit Period	Financial Year	Auditor	Submission Date	Status	Report
No audit reports yet. First annual compliance audit will be due after completion of the first financial year of operation.

Note: Annual compliance audit is conducted by a member of ICAI / ICSI / ICMAI holding valid NISM certification. Reports will be published here and submitted to RAASB within one month of completion, as required under Regulation 25(3) of the SEBI (Research Analysts) Regulations, 2014.