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Internal policy (RA)

Internal policy (RA)

Internal Policy & Control Procedure In Terms of SEBI (Research Analysts) Regulations, 2014

INTRODUCTION

SEBI, vide Notification No. LAD-NRO/GN/2014-15/07/1414 dated 1 September 2014, notified the SEBI (Research Analysts) Regulations, 2014, which became effective on or after the expiry of 29 November 2014, being the ninetieth day from the date of their publication in the Official Gazette.

These regulations were introduced by SEBI with the objective of fostering transparency in securities research and providing investors with more reliable and useful information for making investment decisions.

These Internal Policies and Procedures are being implemented in line with these regulations.

APPLICABILITY

This policy shall apply to SR Alpha Investment Advisers, hereinafter referred to as the “Research Analyst” or “RA”, being responsible for the preparation or publication of the contents of research reports, providing research reports, making buy, sell or hold recommendations, making overweight or underweight recommendations, giving price targets or offering opinions on securities that are listed or proposed to be listed on a stock exchange.

DEFINITIONS

The following terms shall have the meanings stated below. Other terms shall have the same meanings assigned to them under the SEBI (Research Analysts) Regulations, 2014.

1. Fund Manager

“Fund Manager” includes fund managers of a mutual fund, alternative investment fund, venture

capital fund or portfolio manager.

2. Merchant Banking, Investment Banking or Brokerage Services

“Merchant Banking, Investment Banking or Brokerage Services” includes:

Acting as an underwriter;

Participating in the selling or offering of securities for an issuer or otherwise acting in

furtherance of a public offer of the issuer;

Acting as an adviser in a merger or acquisition;

Providing or arranging venture capital, equity or debt;

Serving as a placement agent for an issuer or otherwise acting in furtherance of a private

offering by the issuer; and

Offering brokerage or market-making services.

3. Price Target

“Price Target” means the expectations of the Research Analyst regarding the future performance

of specific securities.

4. Public Appearance

“Public Appearance” means participation in a conference call, seminar, forum, including an

interactive or non-interactive electronic forum, radio, television, internet, web or print-media

broadcast, authorship of a print-media article or any other public-speaking activity through public

media in which the Research Analyst makes a recommendation or offers an opinion concerning securities or a public offer.

It shall not include a password-protected webcast, conference call or similar event conducted with

clients where all participants have previously received the research report or other documentation

containing the required disclosures and where the Research Analyst appearing at the event

correct or updates any disclosure that has become inaccurate, misleading or no longer applicable.

5. Public Offer

“Public Offer” includes an initial public offer, further public offer, offer for sale, disinvestment,

takeover, buy-back or delisting of securities.

6. Relative

“Relative” means a person defined under Section 2(77) of the Companies Act, 2013 who is

financially dependent on the independent Research Analyst or an individual Research Analyst

employed by the research entity.

7. Research Analyst

“Research Analyst” means a person primarily responsible for: Preparing or publishing the contents

of a research report; Providing a research report; Making buy, sell or hold recommendations;

Making overweight or underweight recommendations; Giving price targets; or Offering an opinion

concerning a public offer.

8. Research Entity

“Research Entity” means a Research Analyst or any other intermediary registered with SEBI that is

also engaged in merchant banking, investment banking, brokerage services, underwriting services

or similar activities and issues research reports or research analyses in its own name through

individuals employed by it as Research Analysts.

It also includes any other intermediary engaged in issuing research reports or research analyses.

9. Research Report

“Research Report” means any written or electronic communication that contains research analysis,

a research recommendation or an opinion concerning securities or a public offer and provides a

basis for an investment decision. It does not include the following communications:

Comments on general trends in the securities market;

Discussions concerning broad-based indices;

Commentaries on economic, political or market conditions;

Periodic reports or communications prepared for unit holders of mutual funds or alternative

investment funds or for clients of portfolio managers and Investment Advisers;

Internal communications that are not provided to current or prospective clients;

Communications constituting offer documents or prospectuses circulated in accordance with

regulations made by SEBI;

Statistical summaries of companies’ financial data;

Technical analysis relating to demand and supply in a sector or index; and

Any other communication specified by SEBI from time to time.

10. Significant News or Event

“Significant News or Event” means any news or event expected to have a material impact on, or

reflecting a material change in, the earnings, operations or financial condition of the subject company.

It shall not include unpublished price-sensitive information.

11. Subject Company

“Subject Company” means the company whose securities are the subject of a research report or public appearance.

12. Third-Party Research Report

“Third-Party Research Report” means a research report produced by a person or entity other

than SR Alpha Investment Advisers.

MANAGEMENT OF CONFLICT OF INTEREST AND DISCLOSURE REQUIREMENTS

SR Alpha Investment Advisers shall maintain an arm’s-length relationship between its research activities and its other activities.

Research activities shall be carried out by SR Alpha Investment Advisers through its authorised and qualified Research Analyst personnel.

1. LIMITATIONS ON TRADING BY RESEARCH ANALYSTS

The Research Analyst shall not:

Deal or trade in securities recommended or followed by the Research Analyst during the

period of 30 days before and five days after the publication of a research report;

Deal or trade in securities reviewed by the Research Analyst in a manner contrary to the

recommendation made by the Research Analyst; or

Purchase or receive securities of an issuer before the issuer’s initial public offering where the

issuer is principally engaged in the same type of business as companies followed or

recommended by the Research Analyst.

The above restrictions on dealing or trading in securities shall not apply in the case of significant news or an event concerning the subject company or an unanticipated and significant change in the personal financial circumstances of the Research Analyst.

2. LIMITATIONS ON PUBLICATION OF RESEARCH REPORTS, PUBLIC APPEARANCES AND CONDUCT OF BUSINESS

Research reports issued by the Research Analyst shall be based on adequate documentary research evidence.

The Research Analyst shall not provide any promise or assurance of a favourable review in a research report to a company or industry as consideration for commencing or influencing a business relationship or for receiving compensation or any other benefit.

3. DISCLOSURES IN RESEARCH REPORTS

The Research Analyst shall disclose all material information about itself in its research reports, including:

  • Business activities;
  • Disciplinary history;
  • Terms and conditions on which research reports are offered; and
  • Details relating to ownership and material conflicts of interest.

The Research Analyst shall disclose:

  • Whether SR Alpha Investment Advisers, its associates or relatives have any financial interest in the subject company and, where applicable, the nature of such financial interest;
  • Whether SR Alpha Investment Advisers, its associates or relatives have actual or beneficial ownership of 1% or more of the securities of the subject company as at the end of the month immediately preceding the date of publication of the research report or the date of public appearance;
  • Details of actual or beneficial ownership of 1% or more of the securities of the subject company as at the end of the month immediately preceding the publication date or date of public appearance;
  • Details of any material conflict of interest existing at the time of publication of the research report or public appearance;
  • Details of compensation received by SR Alpha Investment Advisers or its associates from the subject company during the preceding 12 months;
  • Whether SR Alpha Investment Advisers or its associates managed or co-managed a public offering of the subject company during the preceding 12 months;
  • Whether SR Alpha Investment Advisers or its associates received compensation for investment-banking, merchant-banking or brokerage services from the subject company during the preceding 12 months;
  • Whether SR Alpha Investment Advisers or its associates received compensation for products or services other than those stated above from the subject company during the preceding 12 months;
  • Details of any compensation or other benefits received by SR Alpha Investment Advisers or its associates from the subject company or a third party in connection with the research report;
  • Whether SR Alpha Investment Advisers or its associates received any compensation from the subject company during the preceding 12 months;
  • Whether the subject company was a client of SR Alpha Investment Advisers during the 12 months preceding the distribution date of the research report and the nature of services provided;
  • Whether the Research Analyst served as an officer, director or employee of the subject company;
  • Whether the Research Analyst was engaged in market-making activities in the securities of the subject company; and
  • Any other disclosures in research reports or public appearances specified by SEBI under any other regulations.
  • The Research Analyst shall make the required disclosures concerning the receipt of compensation during a public appearance.

    Research reports shall reflect factual information concerning the subject company and shall be based on reliable information.

    The reports shall contain definitions of the terms used for making recommendations, and such terms shall be used consistently.

    Where a research report contains a rating or price target for a period of at least one year, it shall include a graph showing the daily closing price of the relevant securities for the assigned period or for three years, whichever is shorter.

    Research reports shall not be issued selectively in advance to internal trading personnel or to a particular client or group of clients before other clients entitled to receive the research report.

    Where the Research Analyst appears in public media and makes a recommendation, the Research Analyst shall disclose its name, registration status and details of financial interest at the time of:

    Making the recommendation;

Offering an opinion in a personal capacity;

Responding to questions from an audience or journalists in a personal capacity; or

Communicating a research report or its substance through public media.

4. OTHER CONDITIONS

  • The Research Analyst shall possess the applicable NISM certification or any other certification for Research Analysts specified by SEBI.
  • The Research Analyst shall maintain and preserve the following records for a minimum period of five years:

Research recommendations provided;

Rationale for arriving at research recommendations; and

Records of public appearances.

  • SR Alpha Investment Advisers shall immediately inform SEBI in writing if any information or particulars submitted to SEBI are subsequently found to be false or misleading in any material respect or where there is any change in the information already submitted.
  • SR Alpha Investment Advisers shall conduct an annual audit of compliance with the SEBI (Research Analysts) Regulations, 2014 through a member of the Institute of Chartered Accountants of India or the Institute of Company Secretaries of India.

SR ALPHA INVESTMENT ADVISERS

SEBI-Registered Research Analyst

Registration No.: INH000025975

Disclaimer

SR ALPHA INVESTMENT ADVISERS is SEBI registered Research Entity in terms of SEBI (Research Analyst) Regulations, 2014 with SEBI Research Analyst No: INH000025975. We engage in the business of providing fundamental and technical reports including charts and other technical tools to identify market pattern aiming to provide an overview of the previous trading pattern and expectation from the future market.

“Investment in securities market are subject to market risks. Read all the related documents carefully before investing.” The information and views in the reports, our website https://www.thetradingmitra.com / & all the services (“Research Information”) We provide are believed to be reliable, but we do not represent or warrant its accuracy, completeness or reliability of the information contained in our Research Information, investors and clients are advised to independently evaluate the market conditions/ risks involved, before making any trading/investment decisions.

The report / information / opinions have been prepared by us and are subject to change without any notice. The report and information contained herein is strictly confidential and meant solely for the selected recipient and may not be altered in any way, transmitted to, copied or distributed, in part or in whole, to any other person or to the media or reproduced in any form, without prior written consent of us. The information provided in the Report is from publicly available data, which we believe and reliable.

While reasonable endeavors have been made to present reliable data in the Report so far as it relates to current and historical information, we are not guarantee the accuracy or completeness of the data in the Report. Accordingly, we or our partner’s / relatives of our partner’s shall not be in any way responsible for any loss or damage that may arise to any person from any inadvertent error in the information contained, views and opinions expressed in this publication.

Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. The price, value of and income from any of the securities or financial instruments mentioned in this report can fall as well as rise. The Report also includes analysis and views of our research team.

The Report is purely for information purposes and does not construe to be investment recommendation/advice or an offer or solicitation of an offer to buy/sell any securities. The opinions expressed in the Report are our current opinions as of the date of the Report and may be subject to change from time to time without notice.

We or any persons connected with us do not accept any liability arising from the use of this document. Investors should not solely rely on the information contained in this Report and must make investment decisions based on their own investment objectives, judgment, risk profile and financial position.

The recipients of this Report may take professional advice before acting on this information. As we/ our partners are presently engaged in various financial services business and so might have financial, business or other interests in other entities including the subject company/ies mentioned in this Report. However, we have encourages independence in preparation of research report and strives to minimize conflict in preparation of research report. We/ Our Partner’s and their relatives did not receive any compensation or other benefits from the subject company/ies mentioned in the Report or from a third party in connection with preparation of the Report.

Accordingly, we/ Our Partner’s and their relatives do not have any material conflict of interest at the time of publication of this Report. It is confirmed that for giving these recommendations, we have not received any compensation from the companies mentioned herein in the preceding twelve months.

We/ Our Partner’s and their relatives collectively do not own 1% or more of the actual / beneficial ownership of equity securities of the subject company/ies mentioned in the report as of the last day of the month preceding the publication of the research report. We submit that no material disciplinary action has been taken on me by any regulatory authority impacting Equity Research activities.

By accessing https://www.thetradingmitra.com, you have read, understood and agree to be legally bound by the terms of the following disclaimer and user agreement: https://www.thetradingmitra.com is not responsible for any errors, omissions, representations or any links on any of our pages.

https://www.thetradingmitra.com does not endorse any advertisers on our web pages. Please verify the veracity of all information on your own before undertaking any alliance. This website contains articles contributed by several individuals.

The views are exclusively their own and do not necessarily represent the views of the website or its management. The linked sites are not under our control and we are not responsible for the contents of any linked site or any link contained in a linked site, or any changes or updates to such sites. https://www.thetradingmitra.com is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by us of the site. There are risks associated with utilizing internet and short messaging system (SMS) based information and research dissemination services. Subscribers are advised to understand that the services can fail due to failure of hardware, software, and Internet connection. While we try our best that the messages are delivered in time to the subscribers Mobile Network, the delivery of these messages to the customer’s mobile phone/handset is the responsibility of the customer’s Mobile Network.

 SMS may be delayed and/or not delivered to the customer’s mobile phone/handset on certain days, owing to technical reasons and https://www.thetradingmitra.com cannot be held responsible for the same. https://www.thetradingmitra.com hereby expressly disclaims any implied warranties imputed by the laws of any jurisdiction. We consider ourselves and intend to be subject to the jurisdiction only of the registered office of SR Alpha Investment Advisers in India. If you don’t agree with any of our disclaimers above, please do not read the material on any of our pages.

This site is specifically for users in the territory of India. Although the access to users outside India is not denied, https://www.thetradingmitra.com shall have no legal liabilities whatsoever in any laws of any jurisdiction other than India. We reserve the right to make changes to our site and these disclaimers, terms, and conditions at any time. The content of the website cannot be copied, reproduced, republished, uploaded, posted, transmitted or distributed for any non-personal use without obtaining prior permission from SR Alpha Investment Advisers. We reserve the right to terminate the accounts of subscribers/customers, who violate the proprietary rights, in addition to necessary legal action.

 Please note that by surfing our website, submitting your details in our website you are authorizing SR Alpha Investment Advisers to contact you and send Promotional and Transactional communication even though you may be registered under National Do Not Call Registry established under the Telecom Unsolicited Commercial Communications Regulations 2007 or registered or may register under the National Customer Preference Register established under new regulation viz the Telecom Commercial Communications Customer Preference Regulations, 2010. Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

The Trading Mitra will not engage in any transaction in the securities that have been recommended to clients as Research Analyst for a period of thirty days prior to the recommendation and for 5 days after the date of such recommendation. No association or conflict exists that may affect the impartiality of advice.

Full disclosure will be provided if any conflict arises.

Nature of Advisory and Client Responsibility: We offer non-binding, non-executory advisory services. The final decision to act on any recommendation lies with the client. Clients are fully responsible for their own investment and trading decisions. Our role is limited to providing advice based on research and market analysis.

Personal Trading by the Research Analyst — Disclosure & Client Acknowledgement On behalf of the Research Analyst (SEBI-Registered Research Analyst):

  1. Personal Trading:
    The Research Analyst (“RA”) may, from time to time, transact in securities that are also the subject of the RA’s research reports or recommendations. Such personal trades are executed in accordance with the RA’s individual investment objectives, risk appetite, time horizon, target prices, and stop-loss levels, which may differ materially from those communicated in client advisories or research outputs.
  2. No Implied Advice from Personal Trades:
    The RA’s personal trades do not constitute client-specific advice and should not be construed as a directive for clients to buy/sell/hold. Any difference between the RA’s execution and the parameters in research communications is solely due to the RA’s proprietary goals and constraints.
  3. Client Reliance on Formal Communications Only:
    Clients are strictly advised to act only on the basis of the research report/advice formally communicated by the RA through the designated channels and/or upon the triggering of target or stop-loss levels stated therein. Mimicking or acting upon the RA’s personal trades, outside of a corresponding formal recommendation, is done entirely at the client’s own discretion and risk.
  4. Fiduciary Conduct & Conflict Management:
    While SEBI regulations permit a Research Analyst to trade in covered securities subject to applicable disclosures and internal controls, the RA maintains a fiduciary duty to ensure that client interests are not compromised. The RA adheres to prescribed codes of conduct, disclosure requirements, and conflict-management procedures to mitigate potential conflicts arising from personal trading.
  5. Client Acknowledgement & Indemnity:
    By engaging with the RA’s research services, the client acknowledges and agrees that (i) any decision to imitate or rely on the RA’s personal trades—absent a formal recommendation from the RA—is taken solely at the client’s risk, and (ii) the client shall bear full responsibility for all outcomes of such actions and shall indemnify and hold the RA harmless from any loss, claim, liability, or consequence arising therefrom. This disclosure forms an integral part of the RA’s Terms of Engagement and should be read in conjunction with the RA’s Research Analyst Disclosures and Code of Conduct.

End of Contractual Relationship — Research Analyst Services

  1. Scope and Tenure:
    The Research Analyst’s (“RA”) responsibility is limited strictly to the tenure and scope of the subscribed research plan as set out in the engagement letter/subscription order.
  2. Automatic Cessation:
    Upon expiry of the plan term, the RA’s professional obligations—including issuance of further research updates, follow-on commentary, trade tracking/management, or clarifications—cease automatically without any further notice.
  3. No Post-Expiry Deliverables Without Renewal:
    No research updates or support will be provided after expiry unless the client renews the research subscription. The client is solely responsible for ensuring timely renewal to continue receiving research communications.
  4. No Discretion/Execution:
    For clarity, the RA does not execute, manage, or monitor client trades and does not provide portfolio management or suitability assessment. All investment decisions rest with the client.

Risk Disclosure & Client Responsibility

  1. High-Risk Product:
    Derivatives are complex, leveraged instruments and carry a high degree of risk. Prices can be volatile and losses may exceed the initial outlay.
  2. Nature of Service (Research, Not Advice):
    Any communication from the RA in relation to derivatives constitutes impersonal research/commentary and not client-specific advice, suitability assessment, or a recommendation tailored to the client’s financial circumstances.
  3. Client Understanding & Education Material:Advisory in any Segment including Equity and Derivatives: Clients availing derivative segment advisory must acknowledge that derivatives carry high risk. It is the client’s responsibility to fully understand the product, associated risk, and implications of leverage. We recommend clients to open education material on Zerodha Varsity https://zerodha.com/varsity/ and strongly advised them to read and thoroughly understand the contents before acting on any equity or derivative recommendation. We have no association, linkage, or commercial arrangement with Zerodha Varsity. The reference to Zerodha Varsity is made purely for educational purposes. We shall not be held responsible for losses due to client’s negligence or misinterpretation. Client is responsible to maintain the required margin required. It’s the responsibility of client not the RA.
  1. Margins, Leverage & Compliance:
    The client is solely responsible for maintaining required margins, understanding leverage implications, monitoring positions, and complying with broker/exchange requirements. These responsibilities rest with the client, not the RA.
  2. No Liability for Client Negligence/Misinterpretation:
    The RA shall not be responsible for losses arising from the client’s negligence, misunderstanding, misinterpretation, or improper use of research content, including but not limited to errors in execution, margin shortfalls, or failure to manage risk.
  3. Independent Judgment & Professional Advice:
    Clients should exercise independent judgment and, where needed, seek advice from a qualified Investment Adviser (IA) regarding suitability, risk tolerance, and asset allocation. The RA’s role is limited to publishing research under the SEBI (Research Analysts) Regulations.

Execution Discipline & Risk Awareness

Clients acknowledge that any research-linked action should mirror the parameters indicated in the research communication (including, where stated, quantity sizing and timing). Any deviation by the client—such as partial or delayed execution—may lead to outcomes that differ from the research view. The RA shall not be responsible for losses arising from incorrect, partial, or untimely execution by the client.

Market Risk Disclosure

Clients understand that financial markets are inherently volatile and that equities and derivative instruments involve a high degree of risk. While the RA exercises professional judgment and due diligence in publishing research, no returns or profits are guaranteed. Research on derivative instruments is suitable only for investors who already understand such products and possess adequate risk capacity. Losses in leveraged products can exceed the capital deployed.

Nature of Service & Client Responsibility

The RA provides impersonal research and does not offer client-specific suitability assessments or execution/portfolio management. Clients act on the research at their own discretion and are solely responsible for determining suitability, risk, and position sizing in light of their personal circumstances, including maintaining margins and complying with broker/exchange requirements

Acknowledgement of Disclosures & Indemnity

By accessing the RA’s research, the client confirms having read and understood all declarations, disclosures, disclaimers, and terms accompanying the research service. The client accepts full responsibility for decisions taken on the basis of such research and agrees to indemnify the RA against claims, losses, or liabilities covered under the engagement terms, disclosures, and disclaimers.

SR Alpha Investment Advisers

SEBI Registered Research Analyst Registration Number: INH000025975

BSE Enlistment No: 7036

Payment Details

Account Name :- SR ALPHA INVESTMENT ADVISERS

Bank Name:- IDFC FIRST BANK

Account no:-  10278728541

IFSC code:- IDFB0042504

Account type – Current A/C

Branch name:- Byramji Town Branch Nagpur

UPI Id -sralphara@idfcbank

Send Screenshot on WhatsApp after Payment 80100 54067 with your

  1. Name
  2. Email
  3. WhatsApp Number and
  4. Name of the course subscribed

UPI : sralphara@idfcbank

Limited Seats | Batch Details Informed Upon Registration |
Enquiries – 80100 54067

Payment Details

Account Name :- SR ALPHA INVESTMENT ADVISERS

Bank Name:- IndusInd Bank

Account no:-  258010054067

IFSC code:- INDB0000547

Account type – Current A/C

Branch name:- Dhantoli Nagpur

 

Send Screenshot on WhatsApp after Payment 80100 54067 with your

  1. Name
  2. Email
  3. WhatsApp Number and
  4. Name of the course subscribed

Limited Seats | Batch Details Informed Upon Registration |
Enquiries – 80100 54067

Disclaimer

SR ALPHA INVESTMENT ADVISERS is SEBI registered Research Entity in terms of SEBI (Research Analyst) Regulations, 2014 with SEBI Research Analyst No: INH000025975. We engage in the business of providing fundamental and technical reports including charts and other technical tools to identify market pattern aiming to provide an overview of the previous trading pattern and expectation from the future market.

“Investment in securities market are subject to market risks. Read all the related documents carefully before investing.” The information and views in the reports, our website https://www.thetradingmitra.com / & all the services (“Research Information”) We provide are believed to be reliable, but we do not represent or warrant its accuracy, completeness or reliability of the information contained in our Research Information, investors and clients are advised to independently evaluate the market conditions/ risks involved, before making any trading/investment decisions.

The report / information / opinions have been prepared by us and are subject to change without any notice. The report and information contained herein is strictly confidential and meant solely for the selected recipient and may not be altered in any way, transmitted to, copied or distributed, in part or in whole, to any other person or to the media or reproduced in any form, without prior written consent of us. The information provided in the Report is from publicly available data, which we believe and reliable.

While reasonable endeavors have been made to present reliable data in the Report so far as it relates to current and historical information, we are not guarantee the accuracy or completeness of the data in the Report. Accordingly, we or our partner’s / relatives of our partner’s shall not be in any way responsible for any loss or damage that may arise to any person from any inadvertent error in the information contained, views and opinions expressed in this publication.

Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. The price, value of and income from any of the securities or financial instruments mentioned in this report can fall as well as rise. The Report also includes analysis and views of our research team.

The Report is purely for information purposes and does not construe to be investment recommendation/advice or an offer or solicitation of an offer to buy/sell any securities. The opinions expressed in the Report are our current opinions as of the date of the Report and may be subject to change from time to time without notice.

We or any persons connected with us do not accept any liability arising from the use of this document. Investors should not solely rely on the information contained in this Report and must make investment decisions based on their own investment objectives, judgment, risk profile and financial position.

The recipients of this Report may take professional advice before acting on this information. As we/ our partners are presently engaged in various financial services business and so might have financial, business or other interests in other entities including the subject company/ies mentioned in this Report. However, we have encourages independence in preparation of research report and strives to minimize conflict in preparation of research report. We/ Our Partner’s and their relatives did not receive any compensation or other benefits from the subject company/ies mentioned in the Report or from a third party in connection with preparation of the Report.

Accordingly, we/ Our Partner’s and their relatives do not have any material conflict of interest at the time of publication of this Report. It is confirmed that for giving these recommendations, we have not received any compensation from the companies mentioned herein in the preceding twelve months.

We/ Our Partner’s and their relatives collectively do not own 1% or more of the actual / beneficial ownership of equity securities of the subject company/ies mentioned in the report as of the last day of the month preceding the publication of the research report. We submit that no material disciplinary action has been taken on me by any regulatory authority impacting Equity Research activities.

By accessing https://www.thetradingmitra.com, you have read, understood and agree to be legally bound by the terms of the following disclaimer and user agreement: https://www.thetradingmitra.com is not responsible for any errors, omissions, representations or any links on any of our pages.

https://www.thetradingmitra.com does not endorse any advertisers on our web pages. Please verify the veracity of all information on your own before undertaking any alliance. This website contains articles contributed by several individuals.

The views are exclusively their own and do not necessarily represent the views of the website or its management. The linked sites are not under our control and we are not responsible for the contents of any linked site or any link contained in a linked site, or any changes or updates to such sites. https://www.thetradingmitra.com is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by us of the site. There are risks associated with utilizing internet and short messaging system (SMS) based information and research dissemination services. Subscribers are advised to understand that the services can fail due to failure of hardware, software, and Internet connection. While we try our best that the messages are delivered in time to the subscribers Mobile Network, the delivery of these messages to the customer’s mobile phone/handset is the responsibility of the customer’s Mobile Network.

 SMS may be delayed and/or not delivered to the customer’s mobile phone/handset on certain days, owing to technical reasons and https://www.thetradingmitra.com cannot be held responsible for the same. https://www.thetradingmitra.com hereby expressly disclaims any implied warranties imputed by the laws of any jurisdiction. We consider ourselves and intend to be subject to the jurisdiction only of the registered office of SR Alpha Investment Advisers in India. If you don’t agree with any of our disclaimers above, please do not read the material on any of our pages.

This site is specifically for users in the territory of India. Although the access to users outside India is not denied, https://www.thetradingmitra.com shall have no legal liabilities whatsoever in any laws of any jurisdiction other than India. We reserve the right to make changes to our site and these disclaimers, terms, and conditions at any time. The content of the website cannot be copied, reproduced, republished, uploaded, posted, transmitted or distributed for any non-personal use without obtaining prior permission from SR Alpha Investment Advisers. We reserve the right to terminate the accounts of subscribers/customers, who violate the proprietary rights, in addition to necessary legal action.

 Please note that by surfing our website, submitting your details in our website you are authorizing SR Alpha Investment Advisers to contact you and send Promotional and Transactional communication even though you may be registered under National Do Not Call Registry established under the Telecom Unsolicited Commercial Communications Regulations 2007 or registered or may register under the National Customer Preference Register established under new regulation viz the Telecom Commercial Communications Customer Preference Regulations, 2010. Registration granted by SEBI and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

The Trading Mitra will not engage in any transaction in the securities that have been recommended to clients as Research Analyst for a period of thirty days prior to the recommendation and for 5 days after the date of such recommendation. No association or conflict exists that may affect the impartiality of advice.

Full disclosure will be provided if any conflict arises.

Nature of Advisory and Client Responsibility: We offer non-binding, non-executory advisory services. The final decision to act on any recommendation lies with the client. Clients are fully responsible for their own investment and trading decisions. Our role is limited to providing advice based on research and market analysis.

Personal Trading by the Research Analyst — Disclosure & Client Acknowledgement On behalf of the Research Analyst (SEBI-Registered Research Analyst):

  1. Personal Trading:
    The Research Analyst (“RA”) may, from time to time, transact in securities that are also the subject of the RA’s research reports or recommendations. Such personal trades are executed in accordance with the RA’s individual investment objectives, risk appetite, time horizon, target prices, and stop-loss levels, which may differ materially from those communicated in client advisories or research outputs.
  2. No Implied Advice from Personal Trades:
    The RA’s personal trades do not constitute client-specific advice and should not be construed as a directive for clients to buy/sell/hold. Any difference between the RA’s execution and the parameters in research communications is solely due to the RA’s proprietary goals and constraints.
  3. Client Reliance on Formal Communications Only:
    Clients are strictly advised to act only on the basis of the research report/advice formally communicated by the RA through the designated channels and/or upon the triggering of target or stop-loss levels stated therein. Mimicking or acting upon the RA’s personal trades, outside of a corresponding formal recommendation, is done entirely at the client’s own discretion and risk.
  4. Fiduciary Conduct & Conflict Management:
    While SEBI regulations permit a Research Analyst to trade in covered securities subject to applicable disclosures and internal controls, the RA maintains a fiduciary duty to ensure that client interests are not compromised. The RA adheres to prescribed codes of conduct, disclosure requirements, and conflict-management procedures to mitigate potential conflicts arising from personal trading.
  5. Client Acknowledgement & Indemnity:
    By engaging with the RA’s research services, the client acknowledges and agrees that (i) any decision to imitate or rely on the RA’s personal trades—absent a formal recommendation from the RA—is taken solely at the client’s risk, and (ii) the client shall bear full responsibility for all outcomes of such actions and shall indemnify and hold the RA harmless from any loss, claim, liability, or consequence arising therefrom. This disclosure forms an integral part of the RA’s Terms of Engagement and should be read in conjunction with the RA’s Research Analyst Disclosures and Code of Conduct.

End of Contractual Relationship — Research Analyst Services

  1. Scope and Tenure:
    The Research Analyst’s (“RA”) responsibility is limited strictly to the tenure and scope of the subscribed research plan as set out in the engagement letter/subscription order.
  2. Automatic Cessation:
    Upon expiry of the plan term, the RA’s professional obligations—including issuance of further research updates, follow-on commentary, trade tracking/management, or clarifications—cease automatically without any further notice.
  3. No Post-Expiry Deliverables Without Renewal:
    No research updates or support will be provided after expiry unless the client renews the research subscription. The client is solely responsible for ensuring timely renewal to continue receiving research communications.
  4. No Discretion/Execution:
    For clarity, the RA does not execute, manage, or monitor client trades and does not provide portfolio management or suitability assessment. All investment decisions rest with the client.

Risk Disclosure & Client Responsibility

  1. High-Risk Product:
    Derivatives are complex, leveraged instruments and carry a high degree of risk. Prices can be volatile and losses may exceed the initial outlay.
  2. Nature of Service (Research, Not Advice):
    Any communication from the RA in relation to derivatives constitutes impersonal research/commentary and not client-specific advice, suitability assessment, or a recommendation tailored to the client’s financial circumstances.
  3. Client Understanding & Education Material:Advisory in any Segment including Equity and Derivatives: Clients availing derivative segment advisory must acknowledge that derivatives carry high risk. It is the client’s responsibility to fully understand the product, associated risk, and implications of leverage. We recommend clients to open education material on Zerodha Varsity https://zerodha.com/varsity/ and strongly advised them to read and thoroughly understand the contents before acting on any equity or derivative recommendation. We have no association, linkage, or commercial arrangement with Zerodha Varsity. The reference to Zerodha Varsity is made purely for educational purposes. We shall not be held responsible for losses due to client’s negligence or misinterpretation. Client is responsible to maintain the required margin required. It’s the responsibility of client not the RA.
  1. Margins, Leverage & Compliance:
    The client is solely responsible for maintaining required margins, understanding leverage implications, monitoring positions, and complying with broker/exchange requirements. These responsibilities rest with the client, not the RA.
  2. No Liability for Client Negligence/Misinterpretation:
    The RA shall not be responsible for losses arising from the client’s negligence, misunderstanding, misinterpretation, or improper use of research content, including but not limited to errors in execution, margin shortfalls, or failure to manage risk.
  3. Independent Judgment & Professional Advice:
    Clients should exercise independent judgment and, where needed, seek advice from a qualified Investment Adviser (IA) regarding suitability, risk tolerance, and asset allocation. The RA’s role is limited to publishing research under the SEBI (Research Analysts) Regulations.

Execution Discipline & Risk Awareness

Clients acknowledge that any research-linked action should mirror the parameters indicated in the research communication (including, where stated, quantity sizing and timing). Any deviation by the client—such as partial or delayed execution—may lead to outcomes that differ from the research view. The RA shall not be responsible for losses arising from incorrect, partial, or untimely execution by the client.

Market Risk Disclosure

Clients understand that financial markets are inherently volatile and that equities and derivative instruments involve a high degree of risk. While the RA exercises professional judgment and due diligence in publishing research, no returns or profits are guaranteed. Research on derivative instruments is suitable only for investors who already understand such products and possess adequate risk capacity. Losses in leveraged products can exceed the capital deployed.

Nature of Service & Client Responsibility

The RA provides impersonal research and does not offer client-specific suitability assessments or execution/portfolio management. Clients act on the research at their own discretion and are solely responsible for determining suitability, risk, and position sizing in light of their personal circumstances, including maintaining margins and complying with broker/exchange requirements

Acknowledgement of Disclosures & Indemnity

By accessing the RA’s research, the client confirms having read and understood all declarations, disclosures, disclaimers, and terms accompanying the research service. The client accepts full responsibility for decisions taken on the basis of such research and agrees to indemnify the RA against claims, losses, or liabilities covered under the engagement terms, disclosures, and disclaimers.

SR Alpha Investment Advisers

SEBI Registered Research Analyst Registration Number: INH000025975

BSE Enlistment No: 7036

Payment Details

Account Name :- SR ALPHA INVESTMENT ADVISERS

Bank Name:- IDFC FIRST BANK

Account no:-  10278728541

IFSC code:- IDFB0042504

Account type – Current A/C

Branch name:- Byramji Town Branch Nagpur

UPI Id -sralphara@idfcbank

Registration Fees amount without courses – Rs 1,20,000
Registration Fees amount with courses – Rs. 2,00,000

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UPI : sralphara@idfcbank

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