Disclaimerread carefully.

1.About the Investment Adviser

ACUITY INSIGHTS PRIVATE LIMITED (hereinafter referred to as the "Investment Adviser" or "IA") is a registered SEBI Investment Adviser under the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013, having Registration No. INA000022358.

Below are the brief details:

2.History, Present Business and Background

The Investment Adviser is engaged in providing investment advice, including financial planning, to clients in the Indian Securities Market in its capacity as a SEBI-registered Investment Adviser under the IA Regulations. Its scope of services is restricted to rendering investment advice and does not extend to portfolio management, distribution, execution or any other ancillary services, except as otherwise permitted under the IA Regulations.

The Investment Adviser is a non-individual Investment Adviser. In accordance with Regulation 22 of the IA Regulations, the Investment Adviser maintains client-level segregation between investment advisory activities and distribution activities. The Investment Adviser shall not provide distribution services, directly or through its group, to any client to whom investment advice is provided, or to the family of such client; and shall not provide investment advice to any client who is receiving distribution services from the Investment Adviser or its group. As on the date of this document, the Investment Adviser does not carry on any distribution activity. The Investment Adviser has appointed a Principal Officer and a Compliance Officer, and maintains the eligibility, net-worth and infrastructure requirements applicable to a non-individual Investment Adviser under the IA Regulations.

3.Terms and Conditions of Investment Advisory Services

The advisory services of the Investment Adviser are limited to providing independent investment advice and do not extend to portfolio allocation, execution or distribution services. Where implementation services are provided incidental to advice, in accordance with Regulation 22A of the IA Regulations, such services shall be limited to direct schemes/products in the securities market, the client shall be under no obligation to avail of them, and no consideration, commission, referral fee or implementation fee, whether embedded, indirect or otherwise, shall be received by the Investment Adviser (directly or indirectly, at the Investment Adviser's group or family level) in this regard.

4.Disciplinary History

No penalties/directions have been issued by SEBI under the SEBI Act or the regulations made thereunder 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.

The Investment Adviser has never been suspended or barred from doing business by SEBI or any other authority, nor has SEBI ever cancelled the Investment Adviser's certificate of registration.

5.Details of its Associates

The details of associates, if any, shall be provided as and when required.

6.Disclosure with regard to Ownership and Material Conflicts of Interest

1. 6.1.
   The Investment Adviser shall act in a fiduciary capacity towards its clients and shall disclose all conflicts of interest as and when they arise, in accordance with Regulation 15(1) of the IA Regulations.
2. 6.2.
   The Investment Adviser, its associates or relatives do not have any financial interest in the securities/products which are the subject matter of advice, except as may be specifically disclosed to the client.
3. 6.3.
   The Investment Adviser, its associates or relatives do not have actual/beneficial ownership of one per cent or more of the securities which are the subject matter of advice, as on the date of such advice.
4. 6.4.
   The Investment Adviser shall maintain an arm's length relationship between its investment advisory activities and any other activity, and shall disclose to the client any conflict of interest arising between the two, in accordance with Regulation 15(3) and 15(5) of the IA Regulations.
5. 6.5.
   The Investment Adviser does not have any other known material conflict of interest at the time of providing investment advice.

7.Disclosure with regard to Fees and Compensation

1. 7.1.
   The Investment Adviser is entitled to charge fees for providing investment advice to a client in the manner specified by SEBI from time to time, in accordance with Regulation 15A of the IA Regulations.
2. 7.2.
   The Investment Adviser shall not receive any consideration, by way of remuneration, compensation or in any other form, from any person other than the client being advised, in respect of the underlying products or securities for which advice is provided, in accordance with Regulation 15(2) of the IA Regulations.
3. 7.3.
   The Investment Adviser and its associates have not received any compensation for investment banking, merchant banking, brokerage, distribution or execution services from any issuer of the products/securities on which advice is provided, in the past twelve months.

8.Disclosure with regard to Holding or Position

1. 8.1.
   The Investment Adviser shall disclose to the client its holding or position, if any, in the financial products or securities which are the subject matter of advice, in accordance with Regulation 18(4) of the IA Regulations.
2. 8.2.
   The Investment Adviser shall not enter into any transaction on its own account which is contrary to the advice given to a client, for a period of fifteen days from the date of such advice, except in the circumstances and manner permitted under Regulation 15(7) of the IA Regulations.
3. 8.3.
   The Investment Adviser shall not knowingly act on its own account to sell securities or investment products to, or purchase securities or investment products from, a client, in accordance with Regulation 15(10) of the IA Regulations.

9.General Obligations and Disclosures

1. 9.1.
   The Investment Adviser shall not divulge any confidential information about a client, which has come to its knowledge, without the client's prior permission, except where such disclosure is required under any law for the time being in force, in accordance with Regulation 15(6) of the IA Regulations.
2. 9.2.
   The Investment Adviser follows the Know Your Client (KYC) procedure as specified by SEBI from time to time, in accordance with Regulation 15(8) of the IA Regulations.
3. 9.3.
   The Investment Adviser shall abide by the Code of Conduct specified in the Third Schedule to the IA Regulations, in accordance with Regulation 15(9).
4. 9.4.
   The Investment Adviser shall ensure compliance with the certification and qualification requirements specified under Regulation 7 of the IA Regulations at all times, in accordance with Regulation 15(13).
5. 9.5.
   The Investment Adviser shall furnish to SEBI such information and reports as may be specified by SEBI from time to time, in accordance with Regulation 15(12) of the IA Regulations.
6. 9.6.
   The Investment Adviser has not served as an officer, director or employee of, and has not been engaged in any market-making activity for, the subject company of any advice rendered.

10.Disclosure with regard to Use of Artificial Intelligence Tools

1. 10.1.
   The Investment Adviser is not using any Artificial Intelligence (AI) tool for servicing its clients or for arriving at investment advice, as on the date of this disclaimer.
2. 10.2.
   In the event the Investment Adviser uses any Artificial Intelligence tool, irrespective of the scale or scenario of its adoption, for servicing clients, the Investment Adviser shall be solely responsible for the security, confidentiality and integrity of client data, the use of any information or data to arrive at investment advice, the investment advice based on the output of such tools, and compliance with applicable law, in accordance with Regulation 15(14) of the IA Regulations. The extent of use of such Artificial Intelligence tools, if any, shall be disclosed to the client, in accordance with Regulation 18(9) of the IA Regulations.

11.Risk Profiling and Suitability

1. 11.1.
   The Investment Adviser obtains from the client such information as is necessary for rendering investment advice, including age, investment objectives, income details, existing investments/assets, risk appetite/tolerance and liability/borrowing details, and has a documented process for risk profiling and assessing the suitability of advice, in accordance with Regulations 16 and 17 of the IA Regulations.
2. 11.2.
   All investment advice rendered to a client is based on an assessment of the client's risk profile, financial situation and investment objectives. The client's risk profile is communicated to the client after such risk assessment is undertaken, and the information provided by the client and the risk assessment are updated periodically.

12.Grievance Redressal Mechanism

In accordance with Regulation 21 of the IA Regulations, the Investment Adviser shall redress investor grievances promptly and, in any event, not later than twenty-one calendar days from the date of receipt of the grievance.

1. a.
   Clients may first approach the Investment Adviser directly at the contact details mentioned in Section 1 above for redressal of any grievance.
2. b.
   If not satisfied with the response, clients may lodge a complaint with SEBI through the SEBI Complaints Redress System (SCORES) at https://scores.gov.in or through the SCORES mobile application. SEBI's toll-free helpline numbers are 1800 22 7575 / 1800 266 7575.
3. c.
   Clients may also initiate dispute resolution through the SEBI Online Dispute Resolution Portal ("SMART ODR Portal") at https://smartodr.in, which provides for mediation, conciliation and/or arbitration, in accordance with the procedure specified by SEBI.

13.Investor Charter

The Investment Adviser shall ensure compliance with the Investor Charter specified by SEBI for Investment Advisers from time to time, in accordance with Regulation 15(15) of the IA Regulations.

14.Additional Disclosures

1. 14.1.
   Trading/investing in the stock market involves considerable risk. Investment in equity shares, futures, options and commodities has its own risks. You may lose part or all of your initial investment because stock market investments are subject to market risk. Investing in the stock market may not be suitable for all types of investors.
2. 14.2.
   Registration granted by SEBI, enlistment with BSE and certification from NISM in no way guarantee the performance of the Investment Adviser or provide any assurance of returns to investors.
3. 14.3.
   The investment advice provided is based on information and analysis believed to be accurate. This information is provided to enable clients to make their own informed investment decisions and should not be construed as a guarantee or assurance of returns.
4. 14.4.
   The Investment Adviser does not offer any product/service with assured/guaranteed returns. Any anticipatory views mentioned are subject to technical/fundamental studies and do not account for sudden currency/market volatility or unforeseen data events. The Investment Adviser cannot be held responsible for the accuracy of the investment advice provided.
5. 14.5.
   The Investment Adviser does not make any profit commitments. Investment in stock or commodity markets is subject to market risk; though best efforts are made in arriving at investment advice, no surety of return or accuracy of any kind is guaranteed. Clients are advised to exercise their own judgment before acting on any advice.
6. 14.6.
   Where a client seeks advice on a specific position already taken by the client, the Investment Adviser will suggest the best possible course of action based on its view on the security or product concerned. Save as provided under applicable law, the Investment Adviser shall not be liable for any losses the client may incur in acting upon such suggestion, and the client is advised to make the final investment decision at their own discretion.
7. 14.7.
   Clients are advised to act on investment advice only if it suits their current risk appetite and risk-bearing capacity. All investment advice shall be considered in that light, and the client shall, at their discretion, decide on the actual investment to be made.
8. 14.8.
   The Investment Adviser does not provide merchant banking, investment banking, research analyst, or brokerage services.
9. 14.9.
   The Investment Adviser has never been in partnership with any third-party intermediary for execution or distribution services and, save as permitted under Regulation 22A of the IA Regulations, receives no compensation for execution or distribution services.

15.Interpretation

Unless the context otherwise requires, words importing the singular shall include the plural and vice versa; words importing the masculine gender shall include the feminine and vice versa; and words importing natural persons shall include bodies corporate, partnerships, and other legal entities, and vice versa.