SEBI Disclosures

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)

In accordance with Regulation 22 of SEBI (IA) Regulations, 2013 and SEBI Circular dated September 23, 2020, Mahir Invest'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.
• Mahir Invest 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.

PART C: CLIENT-LEVEL DISCLOSURES

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

• Mahir Invest does not hold a discretionary mandate over client portfolios. All investment decisions are made solely by the client on their own account.
• Mahir Invest 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.
• Mahir Invest earns its revenue solely from advisory fees paid directly by clients. Mahir Invest does not receive referral fees, distribution commissions, trail commissions, or any other payment from product manufacturers.
• Mahir Invest 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.
• Mahir Invest 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 Mahir Invest.
• Mahir Invest 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:

• Mahir Invest is fully committed to compliance with PMLA, 2002, the PMLA Rules, 2005, and SEBI AML/CFT guidelines applicable to Investment Advisers.
• Mahir Invest has implemented a comprehensive Board-approved AML/CFT Policy reviewed at least annually.
• Mahir Invest 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.
• Mahir Invest maintains a risk-based client classification system (Low / Medium / High risk) as per SEBI/PMLA guidelines, reviewed periodically.
• Mahir Invest 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.
• Mahir Invest reserves the right to decline or terminate client relationships at any time where KYC/AML requirements cannot be satisfied.

PART E: GRIEVANCE REDRESSAL MATRIX