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The purpose of this document is to provide essential information about the Research Services in a manner to assist and enable the prospective client in making an informed decision for engaging in Research services before onboarding.

History, present business and background

Prime Investment Consultants is registered with SEBI as a Research Analyst with registration no. INH000016603. The Research Analyst received its registration on 28 June 2024 and is engaged in offering research and recommendation services.

Terms and conditions of Research Services

• The Research Services are limited to providing independent research recommendations, and do not involve any advisory or portfolio allocation services.
• The Research Analyst never guarantees returns on any recommendation provided. Investors should note that investment/trading in stocks, indices, or other securities is always subject to market risk. Past performance is never a guarantee of future results.
• The Research Analyst shall not be responsible for any loss to investors.

Disciplinary history

There are no pending material litigations or legal proceedings against the Research Analyst. As on date, no penalties or directions have been issued by SEBI under the SEBI Act or Regulations against the Research Analyst relating to Research Analyst services.

Details of associates

No associates.

Disclosures with respect to Research and Recommendations Services

• The Research Analyst or any of its officer/employee does not trade in securities which are the subject matter of recommendation.
• There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products or securities. Any such conflict of interest, if it arises, shall be disclosed to the client.
• The Research Analyst, its employees, or its associates have not received any compensation from the company which is the subject matter of recommendation.
• The Research Analyst, its employees, or its associates have not managed or co-managed the public offering of any company.
• The Research Analyst, its employees, or its associates have not received any compensation for investment banking, merchant banking, or brokerage services from the subject company.
• The Research Analyst, its employees, or its associates have not received any compensation for products or services other than the above from the subject company.
• The Research Analyst, its employees, or its associates have not received any compensation or other benefits from the subject company or any third party in connection with the research report or recommendation.
• The subject company was not a client of the Research Analyst or its employees or associates during the twelve months preceding the date of recommendation services provided.
• The Research Analyst, its employees, or its associates has not served as an officer, director, or employee of the subject company.
• The Research Analyst has not been engaged in market-making activity of the subject company.

Standard warning

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

Disclaimer

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

All sales are final. Prime Investment Consultants does not offer refunds for the paid period of services already availed by the client. Complaints or dissatisfaction regarding the quality of services during the paid period shall not entitle the client to any refund or compensation.

As per SEBI guidelines, if a client requests to cancel the subscription, a refund shall only be issued for the unused portion of the subscription period. The refund will be calculated on a pro-rata basis, deducting the charges for the services already availed, including applicable taxes and administrative fees.

Refunds will not be provided for the period of services already availed, irrespective of the client's satisfaction with the recommendations or the outcome of trades. Investment in securities markets are subject to market risks. Profits and losses incurred due to the use of our recommendations are solely the responsibility of the client.

By subscribing to our services and making payment, the client acknowledges that they have read, understood, and agreed to this refund policy, as well as the disclaimer, disclosure, and other terms mentioned on this website.

For questions regarding this refund policy, contact us at finprime.investments@gmail.com or +91 9999396356.

Identification of conflicts of interest

I, Amardeep Batra, proprietor of Prime Investment Consultants, shall take adequate steps to identify conflicts of interest. In identifying conflicts of interest, I will take into account situations where I, an employee, or a 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 provided to the client or of a transaction carried out on behalf of the client, which 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;
• Carries out the same business as the client;
• Receives from a person other than a client an inducement in relation to a service provided to a client, in the form of monies, goods, or services, other than the standard commission or fee for that service.

Measures to avoid or manage conflicts of interest

Should a conflict of interest arise, it needs to be managed promptly and fairly. Prime Investment Consultants has put in place the following arrangements:

• No single person shall gather conflicting information, minimising the risk of hiding information from investors.
• We shall not invest in a financial instrument for which we have access to non-public or confidential information.
• Transactions by the proprietor or employees are neither performed nor executed by themselves in a way that creates a conflict.
• Where appropriate, disclosure shall be made to the client in a clear, fair and non-misleading manner to enable the client to make an informed decision.
• Every staff member must have a copy of this Policy on management of conflicts of interest.
• If a potential conflict of interest arises, the transaction shall first be discussed with management before proceeding.
• All new employees, if any, shall be required to declare their outside interests when joining.

Consequences of non-compliance

Non-compliance with this policy and the procedures described here may be considered misconduct and may be subject to disciplinary action.

Standards of appropriate conduct

• Place the client's interests first. Act honestly and do not place personal gain or advantage before the client's interests.
• Provide business services with integrity. Integrity requires honesty and sincerity in all business matters.
• Provide business services objectively. Objectivity requires intellectual honesty and impartiality, regardless of the services delivered.
• Be fair and reasonable, and disclose conflicts. Fairness includes honesty and disclosure of material conflicts of interest, and managing one's own biases to achieve a proper balance of interests.
• Protect the confidentiality of client information. Client information shall be protected and maintained so that only authorised persons can access it.
• Provide business services diligently. Fulfil business commitments in a timely and thorough manner, and take due care in planning, supervising, and delivering services.

The Prevention of Money Laundering Act, 2002 (PMLA) forms the core of the legal framework put in place by India to combat money laundering and related crimes. PMLA and the rules notified thereunder came into force from 1 July 2005. Under PMLA, all entities registered with SEBI are required to furnish information of all suspicious transactions, whether or not made in cash, to FIU-IND. Under Section 3 of PMLA, projecting the proceeds of crime as untainted property is an offence punishable under Section 4.

The Financial Intelligence Unit-India (FIU-IND) is the central national agency responsible for receiving, processing, analysing, and disseminating information of suspicious financial transactions, and for coordinating national and international efforts to combat money laundering.

Definition of a suspicious transaction

Under Section 2(1)(g) of the PMLA Rules, a suspicious transaction — whether or not made in cash — is one which, to a person acting in good faith:

• Gives rise to a reasonable ground of suspicion that it may involve proceeds of crime;
• Appears to be made in circumstances of unusual or unjustified complexity;
• Appears to have no economic rationale or bona-fide purpose; or
• Gives rise to a reasonable ground of suspicion that it may involve the financing of activities relating to terrorism.

Transactions to be recorded under PMLA

• All cash transactions of value more than ten lakh rupees or its equivalent in foreign currency.
• All series of cash transactions integrally connected which individually are below ten lakh rupees but whose monthly aggregate exceeds ten lakh rupees.
• All cash transactions where forged or counterfeit currency notes have been used, or where any forgery of a valuable security has taken place.
• All suspicious transactions whether or not made in cash, including credits or debits into or from any non-monetary account such as a demat or security account.

Client Due Diligence (CDD) Process

The CDD measures adopted by the Research Analyst comprise:

• Verifying the client's identity. Since Research Analyst regulations do not envisage full KYC of clients, basic KYC details — i.e. PAN card number — are collected to establish identity. The KYC status of clients is verified from the Central KYC Registry (CKYC).
• Beneficial ownership. Transaction data is not handled by the Research Analyst; execution is at the discretion of the client. Identifying the beneficial owner of the securities account is the responsibility of the broker handling the trading and securities accounts.

Policy for acceptance of clients

• No account is opened in a fictitious or benami name or on an anonymous basis.
• No account is opened where basic client due diligence — i.e. collecting PAN — cannot be applied.
• The client must be KYC-registered.
• The client shall not be permitted to act on behalf of another person or entity.
• The client's identity is checked against the SEBI/Stock Exchange debarred lists before onboarding. If a match is found, the account is not opened. Lists may be verified at:
  • BSE debarred list
  • NSE / SEBI debarred list
• A risk assessment is conducted using country-specific information and the updated UN Security Council sanctions lists. Clients present on any of the following lists are not on-boarded:
  • UN 1267 sanctions list
  • UN Security Council consolidated list
  • Interpol UN notices — individuals

Procedure for identifying clients

Client identification is carried out at the time of onboarding. Basic KYC details — PAN card number — are collected to establish identity. Failure by a prospective client to provide satisfactory evidence of identity is noted and reported, and services are not started.

Maintenance of records

All client records are maintained for a minimum period of 5 years, or as directed by SEBI and other regulatory authorities from time to time. Where records relate to ongoing investigations or transactions that have been the subject of suspicious transaction reporting, they are retained until the case is confirmed closed.

Audit

An audit of Research Analyst activities is carried out by an independent professional, as allowed by the regulation. Observations of audit are taken on priority basis and corrective actions are initiated.

Transaction monitoring and Suspicious Transaction Reports (STR)

The only transaction encountered while delivering the service is the collection of fees; the Research Analyst does not have access to execution data of clients. Fee collection is therefore accepted through banking channels only, and no cash transactions are allowed for fee payment.

Any suspicious transaction is immediately notified to the Principal Officer, with a detailed report referencing the client, the transaction, and the reason for suspicion.

Reporting of suspicious transactions and accounts

• Information relating to cash and suspicious transactions is reported to The Director, Financial Intelligence Unit-India (FIU-IND), 6th Floor, Tower-2, Jeevan Bharati Building, Connaught Place, New Delhi-110001, or through the applicable online module (FINnet/FINGate), per regulatory requirements.
• Full details of accounts resembling any individual/entity on the regulated or sanctioned lists shall be intimated to the Central Nodal Officer for the UAPA (Fax 011-23092551, Tel 011-23092548, email jsctcr-mha@gov.in).
• A copy of the communication shall also be sent to the UAPA Nodal Officer of the State/UT where the account is held, and to SEBI and FIU-IND without delay. SEBI is reached via post and email (sebi_uapa@sebi.gov.in).

Role of staff

Principal Officer is responsible for communicating this policy to staff, receiving reports of suspicious dealings, clarifying staff queries, ensuring staff dealing with clients follow the guidelines, reporting suspicious transactions to authorities, and maintaining compliance controls.

On-boarding staff, where applicable, carry primary responsibility for AML compliance since they deal directly with customers. They perform KYC / client due diligence at onboarding and renewal, and escalate any suspicious activity to management.

Communication of policy

A copy of this policy is provided to all management and relevant staff who handle account information, securities transactions, money, or client records. An internal session on awareness of this policy is conducted in the first week of April each year.

Compliance and cooperation with law enforcement

Activities are conducted in compliance with all relevant statutory and regulatory requirements. Appropriate information about clients is shared with law enforcement authorities in a timely manner when sought.

Review of policy

This AML policy is reviewed by the Research Analyst to ensure effectiveness whenever there is a change in regulatory guidelines on the prevention of money laundering or terrorist financing.

For: Prime Investment Consultants · Analyst: Amardeep Batra · SEBI Reg INH000016603 · Email finprime.investments@gmail.com · Mobile +91 9999396356