Disclosure

This document gives the information a prospective client needs to make an informed decision before engaging research services.

1. History, present business and background

Devesh Varshney is registered with SEBI as a Research Analyst, registration No. INH000027371, granted on 19 May 2026, and offers research and recommendation services.

2. Terms and conditions of research services Pending review

Research services consist of research reports and recommendations, including model portfolios. The research analyst does not manage client funds, does not place orders, and does not hold client credentials. Every order is placed by the client in their own account.

The research analyst never guarantees returns on any recommendation. Investment in stocks, indices or other securities is always subject to market risk. Past performance is no guarantee of future results. The research analyst is not responsible for any loss to investors.

3. Disciplinary history

There are no pending material litigations or legal proceedings against the research analyst.

As on date, no penalties or directions have been issued by SEBI under the SEBI Act or the regulations made under it against the research analyst in relation to research analyst services.

4. Associates

No associates.

5. Disclosures in respect of research and recommendation services

• The research analyst and relatives may hold positions in securities that are the subject of a recommendation. Any such financial interest is disclosed in the relevant research report. The research analyst does not deal in a recommended security contrary to the recommendation, and observes the dealing restrictions under Regulation 16. Pending review
• There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products or securities, including any material information or facts that might compromise objectivity or independence in carrying on research analyst services. Any such conflict will be disclosed to the client as and when it arises.
• The research analyst, employees or associates have not received any compensation from any company which is the subject of a recommendation.
• The research analyst, employees or associates have not managed or co-managed the public offering of any company.
• The research analyst, employees or associates have not received any compensation for investment banking, merchant banking or brokerage services from any subject company.
• The research analyst, employees or associates have not received any compensation for products or services other than the above from any subject company.
• The research analyst, employees or associates have not received any compensation or other benefits from a subject company or a third party in connection with any research report or recommendation.
• No subject company was a client of the research analyst, employees or associates during the twelve months preceding the date of the recommendation.
• The research analyst, employees or associates have not served as an officer, director or employee of any subject company.
• The research analyst has not been engaged in market-making activity for any subject company.

6. Use of artificial intelligence

AI tools may be used to assist with collecting and processing data and with analysis. All research reports and recommendations are reviewed and approved by Devesh Varshney, who remains fully responsible for them.

7. Standard warning

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

8. Disclaimer

“Registration granted by SEBI, enlistment as RA with Exchange and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.”