• Execution of Agreement Before Commencement of Advisory Services

Investment Advisory services will begin only after the Client signs this Agreement and provides all required onboarding documents, including the completed risk profiling form.

• Client Risk Profiling & Suitability Assessment

The Client must complete and sign the Risk Profiling Form. Investment advice will be rendered only after assessing the Client’s profile for suitability and appropriateness as required under SEBI Regulations.

• MITC (Most Important Terms & Conditions)

The IA shall disclose the MITC document at the time of agreement. This document includes:

• Fee models & caps
• Key risk disclosures
• Complaint redressal mechanism
• Segregation rules
• Prohibition on assured returns
• Disclosure of Conflicts of Interest
  Any potential or actual conflict of interest—financial, personal, or related to group/family members—shall be disclosed promptly to the client as and when it arises.
• Disclosure for Accredited Investors

Accredited investors may agree to bilaterally negotiated terms for fees and services beyond standard SEBI limits.

Such agreements must be documented and acknowledged by both parties.

• Deposit Requirements Disclosure (As per SEBI Circular 2025)

As a registered IA, we maintain the required security deposit with SEBI for investor protection:

• ₹1 lakh for up to 150 clients
• ₹10 lakh for non-individual IAs, if applicable

This ensures regulatory oversight and risk coverage.

• Segregation of Advisory and Distribution Activities

SR Alpha Investment Advisor operates only as an Investment Adviser and does not distribute financial products.

For IAs with group/family distribution entities (not applicable in our case): Segregation of services and clients is mandatory to prevent conflicts of interest.

• Disclosure of Other Business Activities (For Part-Time IAs) (If applicable)

The IA shall disclose details of any part-time occupation or other professional engagement, ensuring there is no conflict of interest in rendering advisory services.

• Disclosure for Non-SEBI Products/Services

The IA does not offer any advice on products not regulated by SEBI (e.g., insurance, PMS, crypto).

Clients must acknowledge that SEBI’s grievance system does not apply to such products.

• Prohibition on Free Trials & Assured Returns

The IA does not offer:

• Free trials of advisory services
• Any kind of promised, fixed, or guaranteed returns
• All advice is provided on a best-effort and suitability-assessed basis only.
• No Power of Attorney Clause

The IA will not seek Power of Attorney (PoA) or request trading/dealing authority for implementing advice.

The client retains complete execution control.

• Advertisement Code Compliance

All promotional material and advertisements comply with SEBI’s Advertisement Code. We do not make false, misleading, exaggerated, or performance-based claims.

• Investor Charter Display

The SEBI-prescribed Investor Charter is publicly available on our website/mobile app. In case of no digital presence, the same will be shared via email/post on request.

• Complaint Status Disclosure

Monthly updates on investor complaints (received, resolved, pending) are displayed in the prescribed SEBI format on our homepage.

• Website and Contact Disclosure

The following information is available on our website/mobile app:

• SEBI Registration Number
• Office and Branch Addresses
• Contact Numbers
• Compliance Officer Information
• Grievance Redressal Mechanism
• Investor Charter
• Complaint Data
• Grievance Redressal Mechanism Disclosure

Clients can raise complaints through:

Email/Phone/Postal Address of IA

SEBI SCORES Portal: https://scores.sebi.gov.in

Complaint timelines and escalation hierarchy are provided in Annexure [Y].

• Mode of Communication and Advisory Delivery

The IA will deliver investment advice through secure and documented modes including email, digital platforms.Any change in communication mode shall be notified to clients in advance.

• Annual Compliance Audit Disclosure The IA undergoes a mandatory Annual Compliance Audit. Any adverse findings and actions taken (if applicable) shall be disclosed to SEBI and made available to clients upon request.
• Periodic Reporting to SEBI/IAASB

The IA complies with SEBI’s directive to submit half-yearly reports covering:

• Client base
• Complaints
• Fees collected
• Service mode
• Risk categorization
• Record Maintenance Disclosure

As per SEBI rules, the IA shall maintain records of client interactions (emails, audio calls, agreements) for a minimum of 5 years. However, in the case where a dispute has been raised, such records will be kept till its resolution or if SEBI desires that specific records be preserved, then such records will be kept till further intimation from the regulator.

• Disclosure of Change in Control

Prior approval will be sought from SEBI for any change in ownership/control. Clients will be informed with full disclosures about the acquirer’s credentials and obligations.

• Artificial Intelligence (AI) Usage Disclosure

Where any part of the advisory process involves the use of AI/ML tools:

• Clients will be informed during onboarding or upon significant change
• All AI outputs are reviewed by qualified humans
• AI will not override suitability or risk profiling
• Client data used in AI processes will be secure, confidential, and encrypted

This complies with SEBI’s directive dated April 30, 2025.

• Data Privacy & Confidentiality

The IA ensures all client data, financial and personal, is handled with utmost confidentiality, complying with data protection laws, and is not shared with any third party without explicit consent.

• Use of Brand/Trade Name Disclosure

SR Alpha Investment Advisor operates under the brand name “The Trading Mitra™”. All communication, advice, and reporting bearing this brand are issued in compliance with SEBI guidelines.

• Termination Clause Disclosure

The Client or IA may terminate the advisory agreement with prior notice, as per the terms stated in the Agreement. All dues must be cleared before termination becomes effective.

• Third-Party Product Disclaimer (if software or tools used)

The IA may refer third-party tools for client awareness. However, such use does not constitute endorsement or assurance of performance or accuracy.

• Investor Charter Display

The Investor charter is published on the IA’s website/mobile app or send it to clients via email if no website exists.

• No Disciplinary history
• No penalties / directions have been issued by SEBI under the SEBI Act or Regulations made there under against the Investment Adviser relating to Investment Advisory services.
• There are no pending material litigations or legal proceedings, findings of inspections or investigations for which action has been taken or initiated by any regulatory authority against the Investment Adviser or its Directors, or employees.
• Affiliations with other intermediaries

Investment Advisor has no affiliation with any other SEBI registered intermediaries.

• Disclosure of all material facts by the IA

The Investment Adviser shall disclose all material facts, including but not limited to product features, performance track record, associated risks, disclaimers, and warnings relevant to the investment advice provided. The Client is advised to carefully review such disclosures before making any investment decision.

Such disclosures shall be made available to the Client through:

• The official website of the Investment Adviser ww.thetradingmitra.com,
• Publicly available regulatory sources such as www.sebi.gov.in, www.nseindia.com, and
• The official websites of respective issuers of the products/securities.

The Client is encouraged to verify and review the information from these sources prior to acting on any investment advice.

• Product Specific Disclosure/ Disclaimer/ Declaration 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 suitability and market analysis.
• Personal Trading by Investment Adviser (IA): As a SEBI-Registered Investment Adviser (RIA), we may engage in personal trading activities in securities that are also recommended to clients. However, such trades are executed based on our individual investment objectives, risk appetite, time horizon, target price, and stop-loss levels, which may differ significantly from those communicated to clients in their advisory plans.Our personal trades are not indicative of client-specific advice, and any deviation in execution is purely aligned with our proprietary goals. Clients are strictly advised to act solely based on the investment advice formally communicated by the RIA through appropriate channels or when target or stop-loss levels mentioned in the advice are triggered.While SEBI regulations permit the IA to trade in the same securities recommended to clients, the IA maintains a fiduciary responsibility to ensure client interests are not compromised. The client agrees and acknowledges that if they act on or mimic any trade executed by the IA without a corresponding formal recommendation, they do so entirely at their own risk and discretion. The client shall bear full responsibility and indemnify the RIA from any loss or consequence arising from such actions.
• Advisory in Derivatives Segment: 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 RIA.
• Execution Discipline and Risk Awareness: Clients acknowledge that all advice must be executed in the intended format, including quantity sizing and timing. Any deviation from this may result in outcomes not aligned with the original advice. We do not assume responsibility for any losses arising from incorrect or partial execution by the client.
• Market Risk Disclosure: Clients understand and accept that financial markets are inherently volatile, and the products advised carry high risk, especially in equities and derivatives. While we exercise professional judgment and due diligence in our recommendations, we do not guarantee profits or returns. Our role is advisory in nature, and we always aim to act in the best interest of the client. Advisory in derivative instruments involves high risk and is suitable only for clients with prior understanding and adequate risk capacity. Losses may exceed capital deployed in case of leveraged products.
• Product Suitability & Client Responsibility: The client confirms that they have understood the nature and features of the investment products/services offered by the SEBI-registered Investment Adviser (RIA), and such offerings are aligned with the client’s risk appetite and investment objectives. The client shall bear full responsibility for the selection and suitability of any product opted for, and agrees to indemnify the RIA against any claims, losses, or liabilities arising from the selection of an inappropriate product.
• Concentration Risk & Allocation Limits: The client acknowledges that, unless otherwise specified in the investment advice, no more than 5% of the total investable funds should be allocated to a single stock/security. Any allocation beyond this threshold shall be at the sole discretion and responsibility of the client. The client further agrees to indemnify the RIA from any financial or legal consequences arising due to such deviation, whether or not prior communication has been made.
• Deviation from Risk Profile: The client affirms that the investment advice provided is based on their duly assessed risk profile. However, if the client chooses to act contrary to the recommended products or deviates from the advised asset allocation based on personal preference or independent judgment, the client shall bear full responsibility and indemnify the RIA from any resulting risks, losses, or liabilities.
• Acknowledgement of Disclosures & Indemnity: By executing this agreement, the client acknowledges that they have thoroughly reviewed and understood all declarations, disclosures, disclaimers, and the terms and conditions of the advisory engagement. The client accepts full responsibility for their decision and agrees to indemnify the RIA for any claims or liabilities arising from matters covered under the agreement, declarations, or associated disclosures.
• All derivative instruments are advised only if they are traded on SEBI-recognized exchanges (e.g., NSE, BSE, MCX)