Investment Advisor Terms

Vision: Invest with knowledge and safety.

Mission: Every investor should be able to invest in the right investment products based on their needs, manage and monitor them to meet their goals, access reports, and enjoy financial wellness.

Onboarding of clients: sharing of agreement copy and completing KYC of clients.

Disclosure to clients:

• To provide full disclosure about its business, affiliations, and compensation in the agreement.
• To not access client accounts or holdings for offering advice, without consent.
• To disclose the risk profile to the client.
• To disclose any conflict of interest of the investment-advisory activities with any other activities of the investment adviser.
• To disclose the extent of use of artificial-intelligence tools in providing investment-advisory services.
• To provide investment advice to the client based on the client’s risk profiling and suitability.
• To treat all advisory clients with honesty and integrity.
• To make adequate disclosure of all material facts – such as risks, obligations, and costs – relating to the products or securities advised.
• To provide clear guidance and adequate caution notice when providing investment advice for dealing in complex and high-risk financial products or services.
• To ensure confidentiality of information shared by clients unless such information is required to be provided in furtherance of legal obligations or with the client’s specific consent.
• To disclose the timelines for the various services provided to clients and ensure adherence to those timelines.

Investors can lodge a complaint / grievance against the Investment Adviser in the following ways:

Mode of filing the complaint with the Investment Adviser:

In case of any grievance or complaint, an investor may approach the concerned Investment Adviser, who shall strive to redress the grievance immediately and in any case not later than 21 calendar days from the receipt of the grievance.

Grievance can be shared at hello@nyvo.in.

Other modes of filing the complaint on SCORES or with the Investment Adviser Administration and Supervisory Body (IAASB):

• SCORES 2.0 – a web-based centralised grievance redressal system of SEBI for facilitating effective grievance redressal in a time-bound manner – at scores.sebi.gov.in.
  • First review is done by the designated body (IAASB).
  • Second review is done by SEBI.
• By email to the designated email ID of IAASB.

If the investor is not satisfied with the resolution provided, the investor has the option to file the complaint or grievance on the Smart ODR platform for resolution through online conciliation or arbitration at smartodr.in.

For physical complaints, investors may write to:

Office of Investor Assistance and Education,
Securities and Exchange Board of India,
SEBI Bhavan, Plot No. C4-A, ‘G’ Block, Bandra-Kurla Complex, Bandra (E), Mumbai – 400 051

NYVO Technology Private Limited is a SEBI-registered Investment Adviser (SEBI IA No. INA000022172, valid 10 April 2026 – Perpetual) and BSE Membership No. 2469, with corporate office at Classic Converge, Building No.148, Ground floor, Sector 05, HSR Layout, Bengaluru, Karnataka 560034, India (“Company”, “NYVO Investment Advisor”, “NYVO Money”, “we”, “us”, “our”).

CIN of the Company: U62090KA2025PTC204991.

The Investment Advisory services are provided under the Investment Advisory Division of the Company.

The content and data available in the material prepared by the Company and on the Platform – including but not limited to index values, return numbers, illustrations, calculators, and rationales – are for information and illustration purposes only. Charts and performance numbers do not include the impact of transaction fees and other related costs. Past performance does not guarantee future returns, and performance of any portfolio is subject to market risk.

Information presented on the Platform shall not be considered as a solicitation for investment. Investors are responsible for their investment decisions and are responsible for validating all information used to make any decision. An investor should understand that an investment decision is based on personal investment needs and risk tolerance, and the Platform’s content is one of many things that may be considered while making an investment decision.

The Company has neither been suspended nor debarred from doing business by any Stock Exchange / SEBI / IRDAI / any other authorities; nor has its certificate of registration been cancelled by SEBI at any point in time.

The Company is not engaged in merchant banking, investment banking, or brokerage services.

Reports or research material prepared by the Company are not to be construed as an offer to buy / sell, or the solicitation of an offer to buy / sell, any security in any jurisdiction where such offer or solicitation would be illegal.

Reports or research material prepared by the Company do not constitute a personal recommendation and do not take into account the particular investment objectives, financial situations, risk profile, and needs of individual clients.

While the Company endeavours to update the information / material on various products and reports on a reasonable basis, regulatory, compliance, or other reasons may prevent it from doing so.

The Company and its associates, officers, directors, and employees, worldwide, may, from time to time, have long or short positions in, and buy or sell securities of, any company forming part of the products or reports prepared by the Company, or may have other potential / material conflicts of interest with respect to any company in such products or reports. Any such position of conflict of interest will be appropriately disclosed and dealt with in accordance with applicable law and the Conflict of Interest Policy of the Company.

The Company does not provide any promise or assurance of a favourable view for a particular industry, sector, or business group in any manner. Investors are requested to take into consideration all the risk factors, including their financial condition and suitability to risk-return profile, and to take professional advice before investing.

Analysts for various products or reports created by the Company certify that all of the information / material therein accurately reflects their personal views about the subject company / companies and their securities; and no part of their compensation was, is, or will be directly or indirectly related to specific recommendations or views in such products or reports. No part of this material may be duplicated in any form and / or redistributed without the prior written consent of the Company.

In compliance with Regulation 15(14) of the SEBI (Investment Advisers) Regulations, 2013 and the SEBI Guidelines for Investment Advisers (Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/003 dated 8 January 2025), NYVO Investment Advisor discloses the extent and manner of its use of Artificial Intelligence (AI) tools as follows:

• Current usage (operational only): NYVO Investment Adviser uses AI tools in day-to-day operations for efficiency – including, illustratively, internal research aggregation, document review, content production support, customer support automation, and back-office workflows.
• Future use: NYVO Investment Advisor may, in future, use AI for the enhancement of services (e.g., personalised insights, calculators, advisory drafting assistance). Any material change in the use of AI tools in advisory will be disclosed to clients in advance and reflected here, and the Investment Adviser remains solely responsible for the security, confidentiality, and integrity of client data; the use of any information or data to provide investment advice; the advice itself; and compliance with all relevant laws.

For products and services that are not regulated by SEBI, the Company shall make appropriate disclosure to the Client and obtain a declaration and undertaking from the Client that such products / services and the Company’s services in respect of such products / services do not come under the regulatory purview of SEBI, and that no recourse is available to the Client with SEBI for any grievances related to such products / services.

6.1 Insurance

6.2 Other non-SEBI products

For any other product / service falling outside SEBI’s purview that the Client may wish to avail through NYVO Investment Advisor or its group, the Client acknowledges:

• Such product / service is not regulated by SEBI;
• The Company’s services in respect of such product / service are not under SEBI’s purview;
• No recourse is available with SEBI in respect of grievances on such products / services;
• Any service the Company provides relating to such products / services is governed solely by the contractual terms agreed with the relevant regulated entity (e.g., bank, NBFC, AMC distributor, IRDAI corporate agent), and the Client agrees to abide by those terms.

The Client shall sign a separate undertaking to this effect at the time of onboarding (or, for existing Clients, at the time of availing the relevant non-SEBI product / service).

NYVO Investment Advisor is committed to ensuring that its Platform is accessible to persons with disabilities, in line with the Rights of Persons with Disabilities (RPwD) Act, 2016 and the SEBI Digital Accessibility framework (SEBI/HO/ITD-1/ITD_VIAP/P/CIR/2025/111 dated 31 July 2025 and follow-up circulars).

• Standards: the Platform endeavours to conform to WCAG 2.1 (AA), GIGW, and IS 17802.
• Accessibility Audit: NYVO Investment Advisor has completed its initial accessibility audit; a final post-remediation audit is scheduled by 31 July 2026, after which annual audits will be conducted by 30 April every financial year.
• Nodal Officer for Digital Accessibility: Kshitij Jain – kshitij@nyvo.in.
• Specialised grievance route: accessibility-related grievances may be raised at hello@nyvo.in with the subject line “Digital Accessibility – [issue]”. The Company will acknowledge within 2 working days and resolve within 21 calendar days.

The Company is committed to managing actual and potential conflicts of interest in line with SEBI Circular CIR/MIRSD/5/2013 dated 27 August 2013, Regulation 18 of the IA Regulations (disclosure of conflicts before and during advice), Regulation 22 (client-level segregation of advisory and distribution activities), and the SEBI Guidelines for Investment Advisers (CIR/2025/003 dated 8 January 2025).

8.1 What we do to identify and manage conflicts

• We act as a fiduciary; the client’s interest takes primacy over the Company’s interest in every advice, decision, and transaction.
• We maintain client-level segregation between investment-advisory activities and any distribution activities.
• We do not provide any distribution services to advisory clients or to their family members under our SEBI registration.
• Wherever direct (non-commission-based) plans / variants of products are available, we recommend such direct plans only.
• We promptly disclose to the Client any actual or potential conflict of interest that may affect the services being rendered.
• All directors, officers, employees, and persons associated with investment advice file an annual conflict-of-interest declaration capturing directorships, business interests, share ownership, beneficial trusts, and personal-account trading positions; mid-year material changes are declared within 7 working days.
• The Compliance Officer reviews each declared conflict, determines exposure, and takes appropriate action – including communicating with parties to the assignment to declare and resolve it.
• We maintain an annual certificate from a member of ICAI / ICSI / ICMAI confirming compliance with client-level segregation, obtained within six months from the end of each financial year as part of the annual compliance audit.

8.2 Position-related disclosures

• The Company has served as an officer, director, or employee of subject company(ies): No
• The Company or its associates have received compensation from subject company(ies) in the past 12 months: No
• The Company or its associates have managed or co-managed public offering of securities for subject company(ies) in the past 12 months: No
• The Company or its associates have received compensation for investment-banking, merchant-banking, or brokerage services from subject company(ies) in the past 12 months: No
• The Company or its associates have received compensation for products or services other than investment-banking, merchant-banking, or brokerage services from subject company(ies) in the past 12 months: No
• The Company or its associates have received any compensation or other benefits from subject company(ies) or third parties in connection with the products or reports created by the Company; and the Company’s associates may have a financial interest in the subject company(ies): No
• Subject companies may have been a client during the twelve months preceding the development and / or publication of products or reports created by the Company: No
• The Company has actual / beneficial ownership of 1% or more securities of subject company(ies) at the end of the month immediately preceding the date of sharing of products or reports: No

The full Conflict of Interest framework is operationalised through internal Code of Conduct, training, periodic review, and disciplinary action against non-compliance.

NYVO Technology Private Limited has no other Group Company, subsidiary, holding company, or affiliate as of the effective date of this disclosure. Any change to this position will be reflected here promptly.

The Securities and Exchange Board of India (SEBI), vide Circular CIR/MIRSD/5/2013, prescribed comprehensive guidelines for dealing with conflicts of interest among intermediaries, recognised stock exchanges, recognised clearing corporations, depositories and their associated persons. SEBI directed every such entity to adopt internal policies and procedures, with active senior management involvement, to identify and avoid or manage actual or potential conflicts of interest.

Modelled on Principle 8 of the IOSCO Objectives and Principles of Securities Regulations, the framework requires every entity to lay down an internal code of conduct, communicate it to all concerned persons, and periodically review its adequacy. The Company adopts this Policy in compliance with that framework.

The purpose of this Policy is to adopt and implement industry best practices, maintain an appropriate level of knowledge and competence, and abide by the SEBI Act and the regulations, circulars, and guidelines issued thereunder, so as to avoid or manage any conflict of interest that may arise during the conduct of the Company’s business.

The objectives of this Policy are:

• To promote high standards of integrity in the conduct of business.
• To ensure fairness in dealing with clients.
• To guide the identification, elimination, or management of conflict-of-interest situations.
• To provide a mechanism for periodic review and assessment of the policy on conflicts of interest.

The Policy aims to identify and prevent conflicts of interest from adversely affecting client interests, including conflicts arising between:

• The Company and a Client.
• A Relevant Person (employee, director, agent) and a Client.
• Any group entity of the Company and a Client.
• Two or more Clients of the Company.
• A service provider of the Company and a Client.

• Associated Person means a principal, employee, agent, or distributor of the Investment Adviser, or any other natural person engaged with the Investment Adviser.
• Customer / Client means any person or entity that signs an engagement mandate with the Investment Adviser to avail of any service offered by the Company.
• Employee means a person employed and on the payroll of the Investment Adviser.
• Intermediary means an entity registered under Sections 11 or 12 of the SEBI Act, 1992, including any person required to obtain membership or approval from a stock exchange or self-regulatory organisation.
• Securities means securities as defined in clause (h) of Section 2 of the Securities Contracts (Regulation) Act, 1956.

A conflict of interest exists where any party to a transaction may gain by taking actions that are detrimental to the other party. For a financial intermediary providing multiple services, a conflict can manifest as concealment of information or dissemination of misleading information.

In identifying conflicts of interest, the Company considers whether the Company, an employee, or any Relevant Person:

• Is likely to make a financial gain, or avoid a financial loss, at the expense of the Client.
• Has an interest in the outcome of a service or transaction that is distinct from the Client’s interest in that outcome.
• Has a financial or other incentive to favour the interest of one Client over another.
• Receives an inducement (in money, goods, or services) from a person other than the Client in relation to the service provided to the Client, beyond the standard fee.

The Company has identified the following as potential areas where a conflict of interest may arise:

• Directorships or other employment held outside the Company.
• Interests in business enterprises or professional practices.
• Share ownership.
• Beneficial interests in trusts.
• Personal account trading by employees.
• Professional associations or relationships with other organisations.
• Front running.
• Rebates, kickbacks, and commissions.
• Designing, marketing, or recommending a product or service without properly considering all of the Company’s other products and services and the interests of all clients.
• Receiving, or expecting to receive, an inducement from a person other than the Client in relation to a service provided to that Client.

Where a conflict of interest arises, it is managed promptly and fairly. The Company puts the following arrangements in place:

• No personal relationship will hamper the Company’s ability to carry out its duties to investors.
• Pre-existing relationships of interested parties with potential portfolio companies are taken into account when determining whether to pursue investments or take other actions.
• A clear distinction is maintained between the operations of different departments, with information barriers where required.
• No single person gathers conflicting information, so the risk of counterfeiting or hiding information from investors is minimised.
• Employees are prohibited from investing in any financial instrument for which they have access to non-public or confidential information. Transactions by the Company’s employees are neither performed nor executed by themselves.
• All employees sign a contract of employment containing confidentiality clauses. No associated person may disclose inside information except to other Company personnel or external parties with a valid business reason.
• Records of services and activities where a conflict of interest has been identified are maintained and stored securely.
• Where appropriate, disclosure is made to the Client in a clear, fair, and not-misleading manner so the Client can make an informed decision.
• The adequacy of the Company’s systems and controls is reviewed periodically.
• Employees are required to avoid conflicts with any activities they undertake outside the Company.
• The Company and its representatives accept no consideration in any form from interested parties or their affiliates that could influence any investment decision.
• Once a conflict is identified, the relevant employee refrains from taking any decision on the assignment until the conflict is resolved. Where necessary, the employee excuses themselves from the assignment entirely.

The Compliance Officer creates awareness of the Code of Conduct and the relevant legislation through training and educational material. The Compliance Officer assesses each declared conflict (whether actual or perceived), determines its value or exposure, and takes appropriate action – including communicating with other parties to the assignment – to declare and resolve it.

The Company shall either avoid any conflict of interest or, where conflicts arise, ensure fair treatment of all customers through disclosure, internal confidentiality rules, declining to act, or otherwise. Employees are expected to:

• At all times maintain high standards of integrity in conducting business activities.
• Ensure fair treatment of all customers and avoid any discrimination among them.
• Ensure that personal interests do not conflict with the duty owed to customers – the customer’s interest always takes primacy in advice, investment decisions, and transactions.
• Make appropriate disclosure of any actual or potential source of conflict that could impair the ability to provide fair, objective, and unbiased services.
• Use information barriers and other prescriptive measures to reduce opportunities for conflict.
• Place appropriate restrictions on personal transactions in securities while handling a customer mandate involving the same security.
• Not deal in customer securities while in possession of material unpublished or price-sensitive information.
• Not communicate price-sensitive information while dealing in customer securities.
• Not contribute, in any way, to the manipulation of the demand for or supply of securities, or to influencing prices.
• Not share information received from customers or pertaining to them, obtained as a result of their dealings, for personal interest.

As part of its fiduciary duty towards clients, the Company is committed to:

• Maintaining high standards of integrity, conducting business on an arm’s-length basis, ensuring equitable treatment of all clients, and preventing any form of discrimination.
• Upholding client interests at all times when rendering investment advice and undertaking transactions.
• Ensuring the personal interest of the Company does not, at any time, contradict or conflict with its duty to clients.
• Disclosing all matters and areas to investors where there may be a potential conflict of interest that could impair fair, objective, and unbiased services.
• Adhering to high-level principles on avoidance of conflicts of interest while dealing with affiliates and subsidiaries.
• Not contributing, in any way, to the manipulation of demand, supply, or prices of securities.

This Policy comes into effect from the date of approval by the Directors of the Company. It is reviewed periodically and updated in line with applicable rules and regulations.

Disciplinary action is taken against employees who fail to comply with this Policy.

The PMLA was brought into force on 1 July 2005. It applies to every banking company, financial institution, and intermediary registered with SEBI under Section 12 of the SEBI Act, 1992 – including investment advisers. Such intermediaries are required to follow client account-opening procedures and maintain records of transactions as prescribed by the PMLA and the rules notified under it.

Reportable transactions include:

• All cash transactions of a value greater than ₹10 lakh, or its equivalent in foreign currency.
• Series of cash transactions integrally connected to one another, individually below ₹10 lakh, where the monthly aggregate exceeds ₹10 lakh.
• All suspicious transactions, whether or not made in cash, including credits or debits to or from a non-monetary account such as a Demat or securities account maintained with a registered intermediary. For suspicious transaction reporting, both transactions integrally connected and transactions remotely connected or related are considered.

The objective of this AML Policy is to:

• Prevent the Company from being used, intentionally or unintentionally, by criminal elements for money-laundering activities.
• Better understand customers and their financial dealings, so that risk is managed prudently.
• Verify the identity, suitability, and risks involved in maintaining a business relationship with each client.
• Adopt and implement AML and Combating the Financing of Terrorism (CFT) standards in day-to-day operations.
• Carry out a proper Customer Due Diligence (CDD) process before registering clients.
• Monitor and report suspicious transactions.
• Maintain records of all transactions as required under applicable regulations and guidelines.

Global measures to combat drug trafficking, terrorism, and other organised serious crimes have emphasised the need for internal procedures that effectively prevent money laundering and terrorist financing. The senior management of the Company is fully committed to establishing appropriate policies and procedures, ensuring their effectiveness, and complying with all relevant legal and regulatory requirements.

The Principal Officer has the ultimate responsibility for the adoption and implementation of this Policy. The Company endeavours to ensure compliance with KYC and AML regulations by all its directors, employees, and agents through this Policy.

The Company has designated the following officers under the PMLA and the rules notified thereunder:

The Principal Officer is responsible for:

• Compliance with the provisions of the PMLA and the AML Guidelines.
• Monitoring the implementation of the AML and CFT Policy.
• Reporting transactions and sharing information as required under the law.
• Submitting periodic reports to top management, including any suspicious transactions being looked into and any matter escalated to the authorities.

The Designated Director ensures compliance with the obligations under the PMLA and rules, oversees the AML compliance position, and performs the functions required under this Policy.

KYC is the process of identifying a client before signing them on as an investor. KYC norms require financial institutions and financial intermediaries to obtain and verify the personal and contact information of their clients in accordance with the laid- down standards. KYC is mandatory for all applications, regardless of the amount invested.

KYC registration is a one-time exercise across the securities market – once KYC is completed through any SEBI-registered intermediary (broker, depository participant, mutual fund, investment adviser, etc.), it does not need to be repeated when approaching another intermediary.

NYVO Technology Private Limited reserves the right to suspend or discontinue service if a client fails to provide KYC information – including PAN, Aadhaar, or passport – that is mandatory under SEBI regulations. The Company is not responsible for any discontinuance of service for clients who have not submitted the required KYC information.

The Company runs an ongoing employee training programme so staff are adequately trained in KYC procedures and understand the rationale behind them.

The CDD measures comprise:

• Obtaining sufficient information to identify persons who beneficially own or control the securities account. Where a securities account is beneficially owned by a party other than the client, that party is identified using the client identification and verification procedure. The beneficial owner is the natural person who ultimately owns, controls, or influences a client and/or the person on whose behalf a transaction is conducted.
• Verifying the client’s identity using reliable, independent source documents, data, or information.
• Identifying beneficial ownership and control – i.e. determining the individual(s) who ultimately own or control the client and/or the person on whose behalf a transaction is being conducted.
• Refusing clients whose identity matches that of any person known to have a criminal background.
• Understanding the ownership and control structure of the client.
• Conducting ongoing due diligence and scrutiny of transactions and accounts throughout the course of the business relationship.
• Periodically updating all documents, data, or information of clients and beneficial owners collected under the CDD process.

The Company may rely on a third party for the purpose of identifying and verifying a client and the beneficial owner, provided the third party is regulated, supervised, or monitored for, and has measures in place for compliance with, CDD and record-keeping requirements consistent with the PMLA.

NYVO Technology Private Limited has developed customer acceptance policies and procedures to identify the types of customers likely to pose a higher-than-average risk of money laundering or terrorist financing. The following safeguards are followed when accepting clients:

• No account is opened in a fictitious or anonymous (benami) name.
• Risk perception of each client is clearly defined, taking location, nature of business, transaction turnover, and payment manner into account. Clients are classified into low, medium, and high risk; clients of a special category may be classified higher and require enhanced due diligence.
• Documentation requirements are calibrated to the perceived risk and the requirements of the PMLA, RBI, and SEBI guidelines.
• Operational due diligence is revisited whenever there is any suspicion of money laundering or terrorist financing.

Each CDD measure is applied on a risk-sensitive basis. An enhanced CDD process is adopted for higher-risk clients; a simplified CDD process may be adopted for lower-risk clients.

Risk assessment is carried out to identify, assess, and mitigate money-laundering and terrorist-financing risk with respect to clients, countries or geographies, nature and volume of transactions, and payment methods. The assessment incorporates country-specific information circulated by the Government of India and SEBI, as well as the consolidated list of individuals and entities subject to UN Security Council sanctions, accessed at:

un.org/securitycouncil/content/un-sc-consolidated-list

The risk assessment is documented, updated regularly, and made available to competent authorities and self-regulating bodies as and when required.

Client identification is carried out at multiple stages – when the relationship is established, when transactions are carried out, and when the Company has doubts regarding the veracity or adequacy of previously obtained client identification data.

The Company complies with the following requirements:

• Risk-management systems are in place to determine whether the client, potential client, or beneficial owner is a Politically Exposed Person (PEP).
• Senior-management approval is obtained for establishing business relationships with PEPs, and for continuing relationships where a client subsequently becomes a PEP.
• Reasonable measures are taken to verify the sources of funds and the wealth of clients and beneficial owners identified as PEPs.
• Each client is identified using reliable sources, and adequate information is obtained to satisfactorily establish identity and the purpose of the intended relationship.
• Original documents are seen prior to acceptance of any copy.
• Failure by a prospective client to provide satisfactory evidence of identity is recorded and reported to higher authority within the Company.
• The Company maintains a comprehensive Customer Identification Procedure document – listing the documents accepted as identity and address proof for each customer category – updated with the approval of Compliance and Business heads, ratified by the Directors.
• The Company is able to satisfy the regulators that due diligence was observed based on the customer’s risk profile and the extant guidelines.

With reference to the provisions of the PMLA and its rules, NYVO Technology Private Limited maintains, preserves, and reports customer account information as follows:

• All necessary records of transactions between the Company and the customer are maintained for at least five years from the date of the transaction. Records permit reconstruction of each transaction, including: nature; amount and currency; date; and parties.
• Records relating to the identification of customers obtained at account opening and during the business relationship are preserved for at least five years after the relationship ends.
• Documents evidencing the identity of clients and beneficial owners – passports, identity cards, driving licences, account files, business correspondence – are preserved for five years after the relationship ends or the account is closed, whichever is later.
• Identification records and transaction data are made available to competent authorities upon request.
• Account information is preserved in a manner that allows it to be retrieved easily and quickly when required.
• Records relating to ongoing investigations or transactions that have been the subject of a suspicious transaction report are retained until the case is confirmed closed.
• Records of transactions reported to the Director, FIU-IND, under Rules 7 and 8 of the PML Rules are maintained for five years from the date of the transaction.

Regular monitoring of transactions is essential to effective AML procedures. The Company has specified an internal threshold of ₹25 lakh for each class of client account. Special attention is paid to all complex or unusually large transactions, and to transactions that exceed this internal threshold or appear to have no economic purpose. The background – including documents, office records, memorandums, and clarifications sought – is examined carefully and the findings recorded in writing. These findings, records, and related documents are made available to auditors and to SEBI / stock exchanges / FIU-IND / other relevant authorities during audit, inspection, or as required, and are preserved for five years from the transaction date.

The compliance department randomly examines a selection of client transactions and notes whether any are suspicious in nature. Any suspicious transaction is immediately notified to the Principal Officer in the form of a detailed report referencing the client, the transaction, and the nature and reason for suspicion. Continuity in dealing with the client is maintained until told otherwise; the client is not informed of the report. In exceptional circumstances, transactions may be suspended or other action taken.

Indicators of potentially suspicious transactions include – without limitation:

• Clients whose identity verification seems difficult, or who appear uncooperative.
• Asset-management services for clients where the source of funds is unclear or inconsistent with the client’s standing or business.
• Clients based in high-risk jurisdictions.
• Substantial increases in business without an apparent cause.
• Transfers of large sums of money to or from overseas locations with instructions for cash payment.
• Attempted transfer of investment proceeds to apparently unrelated third parties.
• Unusual transactions involving offshore banks or financial services, or businesses reported to be in the export-import of small items.

This list is illustrative – whether a particular transaction is suspicious depends on its background and full facts and circumstances.

The Company accesses the updated list of individuals and entities subject to UN Security Council sanction measures (asset freezes, denial of financial services, etc.) at:

un.org/securitycouncil/content/un-sc-consolidated-list

No account is opened where the name appears on this list. Existing accounts are reviewed periodically. Any resemblance is reported to SEBI and FIU-IND.

As required under the PMLA and rules, the Company reports the following to the Director, FIU-IND:

• All cash transactions of value greater than ₹10 lakh, or its equivalent in foreign currency.
• Series of cash transactions integrally connected, individually below ₹10 lakh, where the monthly aggregate exceeds ₹10 lakh.
• All transactions involving receipts by non-profit organisations of value greater than ₹10 lakh.
• All cash transactions where forged or counterfeit currency notes have been used as genuine, or where any forgery of a valuable security or document facilitates the transaction.
• All suspicious transactions, whether or not made in cash, including attempted transactions.
• All cross-border wire transfers of value greater than ₹5 lakh where either the origin or destination of funds is in India.
• All purchases or sales of immovable property valued at ₹50 lakh or more registered by the reporting entity.

The Company adheres to the following submission schedule:

• Cash Transaction Report (CTR): submitted to FIU-IND by the 15th of the succeeding month.
• Suspicious Transaction Report (STR): submitted within 7 days of arriving at a conclusion that any transaction or series of transactions is of a suspicious nature. The Principal Officer records reasons for treating any transaction as suspicious. Conclusion is reached without undue delay.
• Non-Profit Organisation Transaction Report (NTR): submitted to FIU-IND by the 15th of the succeeding month.

The Principal Officer is responsible for timely submission of CTR, STR, and NTR. No nil reporting is required if there are no qualifying transactions to report. Utmost confidentiality is maintained when filing these reports – there is no tipping off to the customer at any time. As per CFT norms, details of any individual or entity matching the UN sanctions list are immediately reported to FIU-IND and RBI.

FIU-IND website: fiuindia.gov.in

NYVO Technology Private Limited has adequate screening procedures to ensure high standards when hiring employees. Key positions are identified having regard to the risk of money laundering and terrorist financing, and the Company ensures that the persons taking up such roles are suitable and competent to perform their duties. AML and CFT measures are prescribed to ensure that criminals are not allowed to misuse the Company’s infrastructure.

HR verifies the identity, cross-checks references, and reviews family background to establish authenticity and genuineness before recruiting. The following are obtained:

• Photographs.
• Proof of address.
• Identity proof.
• Proof of educational qualification.
• Proof of bank account details.

The Company runs an ongoing employee training programme so that staff are adequately trained in KYC and AML procedures. Training requirements are calibrated for front-line, back-office, compliance, risk-management, and new-client-handling staff. All staff understand the rationale behind the directives, implement them consistently, and remain sensitive to the risk of misuse.

Implementing AML/CFT measures requires the Company to demand and collect certain information from investors that may be personal in nature or has not been requested historically – including documents evidencing source of funds, income tax returns, and bank records. To sensitise clients to the rationale behind these requirements, the Company circulates PMLA circulars and other educational material. The same is emphasised in the investor- awareness programmes the Company conducts at frequent intervals.

The Client hereby consents to the following understanding:

• I / We have read and understood the terms and conditions of the Investment Advisory Services provided by the Investment Adviser, along with the fee structure and mechanism for charging and payment of fees.
• Based on our written request to the Investment Adviser, an opportunity was provided by the Investment Adviser to ask questions and interact with ‘person(s) associated with the investment advice’.
• I / We hereby consent to receive and access all information about products and services, including but not limited to the risk-return profile of products / solutions offered under Investment Advisory services, to help me make informed investment decisions.
• In addition to the terms and conditions stated herein, I confirm that I have read and understood the Company’s other Terms and Conditions and other relevant policies applicable to the investment advisory business for availing of Investment Advisory Services and agree to abide by them.

The Investment Adviser hereby declares that:

(i) It shall neither render any investment advice nor charge any fee until the Client has signed this Agreement.

(ii) It shall not manage funds or securities on behalf of the Client and shall only receive such sums of monies from the Client as are necessary to discharge the Client’s liability towards fees owed to the Investment Adviser.

(iii) It shall not, in the course of performing its services to the Client, hold out any investment advice implying any assured returns, minimum returns, target returns, percentage accuracy, or service provision till achievement of target returns, or any other nomenclature that gives the impression that the investment advice is risk-free and / or not susceptible to market risks and / or that it can generate returns with any level of assurance.

THIS INVESTMENT ADVISORY AGREEMENT (“Agreement”) is entered into

BY AND BETWEEN

NYVO Technology Private Limited, CIN: U62090KA2025PTC204991, a company incorporated under the Companies Act, 2013 and having its corporate office at Classic Converge, Building No.148, Ground floor, Sector 05, HSR Layout, Bengaluru, Karnataka 560034, India (acting through its Investment Advisory Division, operating under the brand name “NYVO Investment Advisor”), hereinafter referred to as the “Investment Adviser” or “NYVO Money” or “NYVO Investment Advisor”, which expression unless excluded by or repugnant to the context shall be deemed to include its successors and permitted assigns;

AND

The Person(s) named in Schedule I, hereinafter referred to as the “Client” or “you”, which expression unless repugnant to the context or meaning thereof shall be deemed to include –

1. (if the Client is an individual) his / her heirs, executors, administrators, legal representatives, and permitted assigns;
2. (if the Client is a partnership firm) the partners for the time being of the said firm, the survivor(s) of them, and their respective heirs, executors, administrators, legal representatives, successors, and permitted assigns;
3. (if the Client is a company or a body corporate) its successors and permitted assigns;
4. (if the Client is the Karta of a Hindu Undivided Family) the members for the time being of the said HUF and their respective heirs, executors, administrators, and assigns;
5. (if the Client is a Trust) the principal trustee or the board of trustees or the trustees or the person(s) authorised by the board of trustees and their respective successors;
6. (if the Client is the governing body of a society) the respective members and their successors.

The Investment Adviser and the Client are individually referred to as a “Party” and collectively as the “Parties”.

WHEREAS:

A. The Investment Adviser is duly registered with the Securities and Exchange Board of India (“SEBI”) as a Non-Individual Investment Adviser, vide registration number INA000022172, valid from 10 April 2026 – Perpetual; and is enlisted with the Investment Adviser Administration and Supervisory Body (“IAASB”) through BSE Limited under BSE Membership No. 2469.

B. The Client is desirous of seeking investment advice in relation to investments in securities under the regulatory purview of SEBI and other related advisory services as offered by the Investment Adviser.

C. The Parties hereto are entering into this Agreement to set out the terms and conditions on which the Investment Adviser shall provide investment-advisory services to the Client.

NOW THEREFORE, in consideration of the mutual covenants set out herein, the Parties agree as follows:

(a) Words importing the singular shall include the plural and vice versa.

(b) Words importing a gender shall include any gender.

(c) Headings are for reference only and shall not affect interpretation.

(d) References to clauses, schedules, and recitals are to clauses, schedules, and recitals of this Agreement unless otherwise specified.

(e) References to a statute or regulation shall include all amendments, modifications, and re-enactments.

3.1 The Client appoints the Investment Adviser to provide Advisory Services in respect of investments in securities under the purview of SEBI, on the terms set out in this Agreement.

3.2 Service Start Date. The Advisory Services shall commence on the Service Start Date specified in Schedule I, being the date of completion of subscription payment by the Client and onboarding by the Investment Adviser, whichever is later.

3.3 The Investment Adviser shall not render any investment advice nor charge any fee until the Client has signed this Agreement and the KYC and risk-profiling processes are complete.

4.1 The Client agrees and acknowledges that several Services available on the NYVO Investment Advisor platform are governed by Supplemental Terms and / or a separate agreement that the Client may be required to accept directly with the relevant Affiliate.

4.2 In the event of any inconsistency between this Agreement and the Supplemental Terms applicable to a specific Service, the Supplemental Terms shall prevail to the extent of such inconsistency for that Service.

5.1 The Investment Adviser shall provide the following Advisory Services to the Client:

• Goal-based financial planning, asset allocation, and personalised investment advice;
• Recommendations in respect of securities (mutual funds, equities, bonds, ETFs, government schemes, etc.) under the purview of SEBI;
• Periodic portfolio review, rebalancing recommendations, and ongoing suitability assessment;
• Educational content, research, calculators, and digital tools accessible via the NYVO Investment Advisor platform.

5.2 Risk Assessment. The Investment Adviser shall, before providing any investment advice, conduct a risk profile of the Client through a structured questionnaire. The Risk Profile shall be communicated to the Client in writing and the Client’s acknowledgement shall be obtained. The Risk Profile shall be reviewed at least annually, or earlier on any material change in the Client’s circumstances.

5.3 The Services shall be provided by the Investment Adviser through the NYVO Investment Advisor platform, including its website (https://www.nyvo.money) and the NYVO Investment Advisor mobile application.

5.4 The Client has the sole discretion to decide whether or not to act on the Investment Advice. The Investment Adviser shall not execute any trade on behalf of the Client without the Client’s specific and positive consent on every trade.

5.5 The Investment Adviser shall, while making the Investment Advice or recommendation, take into account the Client’s Risk Profile and suitability.

5.6 The Investment Adviser shall disclose to the Client any actual or potential conflict of interest that may affect the services being rendered to the Client.

5.7 The Advisory Services shall also be subject to the Most Important Terms and Conditions (“MITC”), as standardised by the Industry Standards Forum and specified by SEBI from time to time, set out in Schedule II of this Agreement. The Client confirms by signing this Agreement that he / she / it has read, understood, and accepted the MITC. The MITC shall prevail over any inconsistent provision of this Agreement to the extent of such inconsistency.

5.8 Any changes, revisions, or amendment to the Services, fees, or supplemental terms will be detailed by the Investment Adviser in writing and communicated to the Client in advance.

6.1 Fee Modes. The Client may be charged Fees under one of the following modes (subject to applicable SEBI ceilings):

(a) Fixed Fee mode: maximum ₹ 1,51,000 per annum per family of Client.

(b) Assets under Advice (AUA) mode: maximum 2.5% of AUA per annum per family of Client.

The applicable Fee Mode and amount are set out in Schedule I.

6.2 Fee Mode Change. The Investment Adviser may change the fee mode at any time with the Client’s consent. The maximum fee in such cases shall not exceed the higher of the fixed-fee limit or 2.5% of AUA per annum per family of Client.

6.3 Mode of Payment. Fees shall be paid through cheque, online bank transfer, UPI, or any other banking channel, including the Centralised Fee Collection Mechanism (CeFCoM) where opted. Cash payments are not permitted.

6.4 Advance Fees. The Investment Adviser may charge fees in advance for a period not exceeding 1 (one) year.

6.5 Refunds on Pre-mature Termination. In case of pre-mature termination, the Client shall be entitled to a refund of proportionate fees for the unexpired period, less a maximum breakage fee of one-quarter of the annual fee.

6.6 Statutory Charges. All applicable statutory charges (GST, etc.) shall be borne by the Client over and above the Fees.

6.7 Execution Service Charges. Where the Client opts for execution support through a Group Company or third-party Affiliate, separate execution service charges, as applicable and communicated in writing, shall apply and shall be governed by the relevant Supplemental Terms.

7.1 The NYVO Investment Advisor platform may integrate with third-party service providers, including KYC Registration Agencies (KRAs), Account Aggregators, payment processors, and execution partners.

7.2 The Investment Adviser is not responsible or liable for any loss incurred by the Client as a result of the Client’s interaction with a third-party product or service.

7.3 The Client’s relationship with such third parties shall be governed by their own terms and regulator-mandated disclosures.

8.1 The Investment Adviser shall act as a fiduciary to the Client and shall always act in the best interest of the Client.

8.2 The Investment Adviser and its employees / family members shall not provide any distribution services to the Client or the Client’s family under the SEBI IA registration.

8.3 The Investment Adviser shall, wherever available, advise direct plans (non-commission-based) of products only.

8.4 The Investment Adviser shall comply with the IA Regulations, the SEBI Master Circular for Investment Advisers, and all applicable circulars, notifications, and guidelines.

8.5 The Investment Adviser shall maintain adequate records of advice rendered, the rationale, time-stamp, channel, and Client acknowledgement, for the periods prescribed under applicable law (minimum five years).

8.6 The Investment Adviser shall maintain confidentiality of the Client’s information except where disclosure is required under law or with the Client’s specific consent.

9.1 The Client has provided all true, correct, and complete information as required for the purposes of KYC, risk profiling, and suitability assessment.

9.2 The Client acknowledges and has understood the risks associated with investments in securities and confirms that no guaranteed returns have been promised.

9.3 The Client agrees to follow all procedures as required by the Investment Adviser, including providing financial information (income, investments, liabilities, etc.) on an ongoing basis.

9.4 The Client agrees to furnish investment details along with relevant documents from time to time as required by the Investment Adviser.

9.5 The Client agrees to execute such consents, declarations, undertakings, and other documents as may be required for the provision of the Services.

9.6 The Client shall keep the Investment Adviser duly informed of any change in the constitution, contact details, KYC information, or financial circumstances.

9.7 The Client agrees to make payment of the Fees as due to the Investment Adviser on the dates and in the manner set out in Schedule I.

9.8 The Client acknowledges that the tax-related implications of any investment decision are the Client’s responsibility, and the Client may seek independent tax / legal advice.

9.9 The Client acknowledges that where the Client is more than one individual / entity, all such persons shall be jointly and severally liable under this Agreement.

Each Party represents and warrants to the other that:

10.1 It has full power, capacity, and authority to execute, deliver, and perform this Agreement.

10.2 This Agreement has been duly executed and delivered by the Parties and constitutes a legal, valid, and binding obligation, enforceable in accordance with its terms.

10.3 There are no legal, quasi-legal, administrative, arbitration, mediation, or conciliation proceedings pending or threatened that would adversely affect the Party’s ability to perform under this Agreement.

10.4 The execution, delivery, and performance by the Parties of this Agreement does not violate any applicable law, regulation, or contract.

11.1 The Client’s investment objectives, time horizon, and risk appetite are captured in the Risk Profile and Schedule I.

11.2 The Investment Adviser shall provide Advisory Services aligned to the assessed Risk Profile and stated investment objectives.

12.1 Investments in securities are subject to market risks. Past performance does not guarantee future results.

12.2 The Investment Adviser does not guarantee returns, accuracy, or risk-free investments. SEBI registration, IAASB enlistment, and NISM certification do not guarantee performance or assure returns.

12.3 The Investment Adviser is neither responsible nor liable for any losses resulting from the Investment Advice provided, save and except in cases of wilful default and / or fraud by the Investment Adviser.

13.1 The Investment Adviser shall maintain accurate records of advice rendered, communications, and the Client’s documents.

13.2 The Investment Adviser shall maintain confidentiality of all Client information, except where disclosure is required under law or with the Client’s specific consent.

13.3 The Client agrees that interactions with the Investment Adviser via call, chat, or app may be recorded for compliance, training, and audit purposes.

14.1 Term. This Agreement is effective from the Service Start Date and shall continue until terminated as per Clause 14.2.

14.2 Termination. Either Party may terminate this Agreement by providing 30 days’ written notice. The Investment Adviser may terminate immediately on:

(a) Material breach of this Agreement by the Client;

(b) Failure to provide complete / accurate KYC or risk-profile information;

(c) Adverse findings under PMLA / FATF screening;

(d) Non-payment of Fees beyond the agreed window.

14.3 Effects of Termination. On termination – (a) the Investment Adviser shall stop rendering advice; (b) the Client shall be entitled to a refund of proportionate Fees for the unexpired period, less a maximum breakage of one-quarter of the annual Fee; (c) the Client’s account shall be deactivated within a reasonable time; (d) Records shall continue to be maintained per Clause 13.

15.1 Personal data is processed in accordance with the NYVO Investment Advisor Privacy Policy and the Digital Personal Data Protection Act, 2023.

15.2 The Client consents to the Investment Adviser sharing limited information with regulators, KRAs, FIU-IND, KYC partners, payment processors, and audit / compliance professionals, strictly to the extent required to deliver Services and meet legal obligations.

16.1 The Investment Adviser shall not seek a power of attorney from the Client to operate the Client’s bank, demat, or trading account, or to execute any trade on the Client’s behalf.

16.2 The Client is advised never to grant a power of attorney for execution of trades to the Investment Adviser.

17.1 All Intellectual Property Rights in the NYVO Investment Advisor platform, content, designs, trademarks, logos, and software are the property of NYVO Technology Private Limited or its licensors.

17.2 No right or licence is granted to the Client other than the limited right to use the platform to avail the Services.

18.1 The Client agrees to indemnify and hold harmless the Investment Adviser, its directors, officers, employees, and Affiliates from any claims, liabilities, damages, losses, or expenses arising from the Client’s breach of this Agreement, misrepresentation, or unlawful act.

18.2 To the fullest extent permitted by law, the Investment Adviser’s total aggregate liability under this Agreement shall not exceed the Fees paid by the Client in the immediately preceding twelve-month period.

19.1 The Parties shall first attempt to resolve disputes amicably within 30 days of written notice.

19.2 Failing amicable resolution, disputes shall be resolved through the Smart ODR mechanism (smartodr.in) for online conciliation / arbitration, in accordance with SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/131.

19.3 If Smart ODR is unavailable, disputes shall be referred to arbitration under the Arbitration and Conciliation Act, 1996, before a sole arbitrator. Seat: Bengaluru, Karnataka. Language: English.

All notices under this Agreement shall be in writing and shall be sent to:

• Investment Adviser: hello@nyvo.in / Compliance Officer, NYVO Investment Advisor, Classic Converge, Building No.148, Ground floor, Sector 05, HSR Layout, Bengaluru, Karnataka 560034, India / +91 80888 30781.
• Client: the email address and phone number specified in Schedule I.

21.1 In case of any grievance or complaint, the Client may approach the Investment Adviser, who shall strive to redress the grievance immediately and in any case not later than 21 calendar days from the receipt of the grievance. The complaint can be shared at hello@nyvo.in or +91 80888 30781.

21.2 Unresolved grievances may be lodged through SEBI’s SCORES platform (scores.sebi.gov.in).

21.3 Thereafter, unresolved grievances may be escalated through the Smart ODR portal (smartodr.in).

21.4 Complete grievance and escalation matrix is available at /grievance-redressal-policy.

22.1 Governing Law and Jurisdiction. This Agreement is governed by the laws of India. Subject to Clause 19, Courts in Bengaluru, Karnataka shall have exclusive jurisdiction.

22.2 Amendments. The Investment Adviser may amend this Agreement consistent with regulatory changes. Material amendments shall be notified to the Client; continued availing of Services after notification will be deemed acceptance.

22.3 Severability. If any provision is held invalid, the remaining provisions continue in full force.

22.4 Waiver. The Investment Adviser’s failure to enforce any right does not constitute a waiver.

22.5 Entire Agreement. This Agreement, together with its Schedules, the MITC, the Risk Factors, the Privacy Policy, and other policies referenced herein, constitute the entire understanding between the Parties.

The Most Important Terms and Conditions (“MITC”), as standardised by the Industry Standards Forum (ISF) and specified by SEBI from time to time (BSE Notice 20250225-50 dated 25 February 2025), shall apply to every Investment Advisory engagement between the Investment Adviser and the Client and form an integral part of this Agreement.

1. Fee acceptance only – no funds or securities. The IA shall only accept payments towards its fees for advisory services and is not permitted to accept funds or securities in its account on the Client’s behalf.

2. No guaranteed returns. The IA does not guarantee returns, accuracy, or risk-free investments. All advice is subject to market risks, and there is no assurance of any returns or profits.

3. Prohibition on assured-return schemes. Any assured / guaranteed / fixed-return 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 IA.

4. Scope of SEBI’s regulatory purview. Investment advice related only to securities falls under the purview of SEBI. In case of any services offered by the IA related to products or services not under the purview of SEBI, the IA shall make a disclosure to the Client and obtain a declaration and undertaking from the Client that such products / services and the services of the IA in respect of such products / services do not come under the regulatory purview of SEBI, and that no recourse is available to the Client with SEBI for grievances related to such products / services.

5. No execution without explicit consent. This Agreement is for the investment advisory services provided by the IA. The IA cannot execute or carry out any trade (purchase / sell transaction) on behalf of the Client without his / her / its specific and positive consent on every trade.

6. Fee limits as prescribed by SEBI / IAASB. The fee charged by the IA to the Client will be subject to the maximum amount prescribed by SEBI / IAASB from time to time (applicable only for Individual and HUF Clients).

• Fixed Fee mode: the current fee limit is ₹ 1,51,000 per annum per family of Client.
• Assets under Advice (AUA) mode: the maximum fee limit is 2.5% of AUA per annum per family of Client.
• The IA may change the fee mode at any time with the Client’s consent; however, the maximum fee limit in such cases shall be the higher of the fee limit under the fixed-fee mode or 2.5% of AUA per annum per family of Client.
• Fee limits do not include statutory charges.
• Fee limits apply only for investment advice related to securities under the purview of SEBI.
• Fee limits do not apply to a non-individual Client / accredited investor.

7. Advance fees and refunds. The IA may charge fees in advance if agreed by the Client. Such advance shall not exceed the period stipulated by SEBI; presently it is a maximum of one year. In case of pre-mature termination of the IA services, the Client shall be entitled to seek refund of proportionate fees only for the unexpired period. The IA is entitled to retain a maximum breakage fee of not greater than one-quarter of the fee.

8. Permitted modes of fee payment. Fees to the IA may be paid by the Client through any of the specified modes – cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally, the Client may make payments through the Centralised Fee Collection Mechanism (CeFCoM), managed by BSE Limited.

9. Sharing of financial information. The IA is expected to know the Client’s financial details for providing services. Hence, the Client is required to share financial information (e.g. income, existing investments, liabilities, etc.) with the IA.

10. Risk profiling and suitability. The IA is required to carry out the Client’s risk profiling and suitability analysis before providing services and thereafter on an ongoing basis.

11. Conflict-of-interest management. As part of conflict-of-interest management, the Client or the Client’s family members will not be provided any distribution services by the IA or any of its group entities / family members. The IA shall, wherever available, advise direct plans (non-commission-based) of products only.

12. Grievance redressal. For any grievances:

• Step 1 – Contact the IA directly: Compliance Officer, hello@nyvo.in, +91 80888 30781; Principal Officer Kshitij Jain, kshitij@nyvo.in.
• Step 2 – Lodge through SEBI’s SCORES platform at scores.sebi.gov.in if the resolution provided by the IA is unsatisfactory.
• Step 3 – Smart ODR. If the Client remains dissatisfied with the outcome of the SCORES complaint, the Client may consider Online Dispute Resolution (ODR) through smartodr.in.

13. Registration / certification do not guarantee performance. The SEBI registration, enlistment with IAASB, and NISM certification do not guarantee the performance of the IA or assure returns to the Client.

14. Keep contact details updated. Clients are required to keep their contact details, including email ID and mobile number(s), updated with the IA at all times.

15. Login credentials and OTPs. The IA shall never ask for the Client’s login credentials and OTPs for the Client’s Trading Account, Demat Account, or Bank Account. Never share such information with anyone – including the IA.

(i) Securities investments are subject to market risk; there is no assurance or guarantee that the Client’s objectives will be achieved.

(ii) Past performance does not indicate future performance.

(iii) The net asset value of the Client’s portfolio may go up or down depending on factors and forces affecting the capital markets.

(iv) Investment decisions made by the Client based on the Investment Adviser’s advice may not always be profitable; actual market movements may diverge from anticipated trends.

(v) The Investment Adviser is neither responsible nor liable for any losses resulting from the investment advice provided, save and except in cases of wilful default and / or fraud.

(vi) Names of securities or services do not in any manner indicate their prospects or returns.

(vii) Investments are subject to a wide range of risks – economic slowdown, volatility and illiquidity, poor corporate performance, changes in policies, natural disasters, civil disturbance, sovereign action, technology obsolescence, legislative changes, etc. – beyond the Investment Adviser’s control.

(viii) The Client is not being offered any guaranteed or assured returns of principal or appreciation.