MAHIR INVESTMENT ADVISERS PRIVATE LIMITED

PART A: MANDATORY INVESTMENT ADVISER DISCLOSURE

As mandated by SEBI (IA) Regulations, 2013, SEBI Circular No. SEBI/HO/IMD/DF1/CIR/P/2020/182 dated September 23, 2020, and all subsequent amendments, the following details are mandatorily disclosed:

PART B: FEE DISCLOSURE (As per Regulation 22, SEBI IA Regulations)

B.1 Fee Structure and SEBI Limits

In accordance with Regulation 22 of SEBI (IA) Regulations, 2013 and SEBI Circular dated September 23, 2020, MIA's fee structure is disclosed as under:

• GST at applicable rate and other statutory taxes are payable by the client over and above the advisory fee.
• MIA does not accept trail fees, referral commissions, or any other payment from product manufacturers, fund houses, or third-party intermediaries.
• Fee receipts and GST invoices will be issued for all advisory fee payments within 7 working days.
• The fee mode applicable to each client is specified in their individual Client Agreement.
• Clients may switch between fee modes with mutual consent, subject to SEBI guidelines and execution of an amended Client Agreement.

PART C: CLIENT-LEVEL DISCLOSURES

The following disclosures are made to each client at onboarding and periodically thereafter, as mandated by SEBI:

• MIA does not hold a discretionary mandate over client portfolios. All investment decisions are made solely by the client on their own account.
• MIA is registered as an Investment Adviser with SEBI and is NOT registered as a Stock Broker, Portfolio Manager, Mutual Fund Distributor, Research Analyst, or any other intermediary unless separately disclosed in writing.
• MIA earns its revenue solely from advisory fees paid directly by clients. MIA does not receive referral fees, distribution commissions, trail commissions, or any other payment from product manufacturers.
• MIA maintains a written Board-approved Conflict of Interest Policy. All material conflicts of interest, if any, shall be disclosed to the client in writing before providing any advice.
• MIA maintains comprehensive client suitability records, risk profile assessments, and written investment rationale for all advice given, which are available for client inspection upon request.
• Clients have the right to receive: (a) a copy of the Client Agreement before commencement of services; (b) the Risk Profiling Report; (c) all investment advice in writing with stated rationale; and (d) a copy of these SEBI Disclosures.
• Investment advice is based entirely on information provided by the client. Clients are solely responsible for the accuracy and completeness of information furnished to MIA.
• MIA maintains records of all client interactions, written advice, investment rationale, and related communications for the minimum period prescribed by SEBI regulations.
• Clients have the right to approach SEBI SCORES (scores.gov.in) for unresolved grievances at any stage.

PART D: AML / KYC DECLARATION

Mahir Investment Advisers Private Limited hereby declares and confirms:

• MIA is fully committed to compliance with PMLA, 2002, the PMLA Rules, 2005, and SEBI AML/CFT guidelines applicable to Investment Advisers.
• MIA has implemented a comprehensive Board-approved AML/CFT Policy reviewed at least annually.
• MIA carries out Customer Due Diligence (CDD) for all clients and Enhanced Due Diligence (EDD) for high-risk clients including Politically Exposed Persons (PEPs), Non-Resident Indians, and clients from high-risk jurisdictions.
• MIA maintains a risk-based client classification system (Low / Medium / High risk) as per SEBI/PMLA guidelines, reviewed periodically.
• MIA has designated an AML Reporting Officer responsible for monitoring, detecting, and reporting suspicious transactions to FIU-IND.
• MIA conducts KYC verification through CKYCRR/KRAs and maintains all KYC records for a minimum period of 5 years post-relationship cessation, as required under PMLA.
• MIA conducts real-time sanctions screening against UN, OFAC, and Government of India sanctioned lists for all clients.
• MIA does not onboard shell companies, persons on sanctions lists, or clients from FATF high-risk jurisdictions without satisfying mandatory enhanced verification requirements.
• MIA reserves the right to decline or terminate client relationships at any time where KYC/AML requirements cannot be satisfied, or where MIA has reasonable grounds to suspect money laundering or terrorist financing.

PART E: CODE OF CONDUCT COMPLIANCE

MIA declares strict adherence to the Code of Conduct prescribed under the Third Schedule to SEBI (Investment Advisers) Regulations, 2013:

PART F: GRIEVANCE REDRESSAL MATRIX

PART G: ANNUAL COMPLIANCE DECLARATIONS

The following declarations are made on behalf of Mahir Investment Advisers Private Limited for the current compliance period:

• All personnel providing investment advice hold valid NISM-Series XA and XB certifications as mandated under SEBI IA Regulations.
• MIA shall file all periodic returns, compliance reports, and disclosures required by SEBI, including the Annual Compliance Report (ACR) within prescribed timelines.
• MIA has obtained / shall obtain Professional Indemnity (PI) Insurance as required under SEBI IA Regulations before commencing client advisory operations.
• MIA has implemented an Internal Audit mechanism for periodic review of regulatory compliance, to be conducted at least semi-annually.
• MIA's fee structure is in compliance with SEBI-prescribed limits and has been duly communicated to all clients in their Client Agreements.
• MIA does not engage in dual registration as Investment Adviser and Mutual Fund Distributor for the same client, in compliance with SEBI Circular dated September 23, 2020.
• MIA maintains a minimum net worth as prescribed under SEBI IA Regulations, evidenced by a certificate from a practising Chartered Accountant.
• All client agreements, risk profiles, and advisory records are maintained in accordance with Regulation 19 of SEBI IA Regulations.

PART H: CLIENT COMPLAINTS DATA DISCLOSURE

As mandated by SEBI, the following client complaints summary is published on the MIA Platform and updated on a monthly basis:

Data as of: June 01, 2026. Updated monthly by the 7th of the following month as per SEBI requirements.