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Disclosure

Confluence Research

SEBI Registered Research Analyst Registration No. INH000014207

The particulars given in this Disclosure Document have been prepared in accordance with SEBI (Research Analyst) Regulations, 2014.

The purpose of the Document is to provide essential information about the Research and recommendation Services in a manner to assist and enable the perspective client/client in making an informed decision for engaging in Research and recommendation services before investing.

For the purpose of this Disclosure Document, Research Analyst is Confluence Research (hereinafter referred as “Research Entity”)

A. Descriptions about “Research Entity”
  • History, Present business and Background
  • Research Entity is registered with SEBI as Research Analyst with Registration No. INH000014207. The firm got its registration on December 26, 2023 and is engaged in research and recommendation Services.
  • The focus of Research entity is to provide research and recommendations services to the clients. Analyst aligns its interests with those of the client and seeks to provide the best suited services.
  • Terms and conditions of Research and Recommendation Services
  • Terms and conditions of Research and Recommendation Services are detailed in the terms and condition document. Please refer to the same for details.
  • Disciplinary history
  • 1. Terms and conditions of Research and Recommendation Services are detailed in the terms and condition document. Please refer to the same for details.
  • 2.ii. 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 Research entity, Research Analyst or its associates or relatives.
  • Details of its associates
  • No Associates

B. Disclosures with respect to Research and Recommendations Services
  • Research entity or Research Analyst or his associate or his relative may have financial interest or actual / beneficial ownership of one per cent or more in the securities recommended in its personal portfolio at the end of the month immediately preceding the date of publication of the research report or date of the public appearance. Details of the same may be referred through the disclosures made at the time of recommendation.
  • There are no actual or potential conflicts of interest arising from any connection of Research entity or Research Analyst or his associate or his relative to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of Research Analyst services. Such conflict of interest shall be disclosed to the client as and when they arise.
  • Research analyst or research entity or its associates or relatives, may have actual/beneficial ownership of one per cent or more securities of the subject company, at the end of the month immediately preceding the date of publication of the research report or date of the public appearance or research recommendation. Details of the same may be referred through the disclosures made at the time of recommendation.
  • Research entity or Research analyst or its associate or relatives has no connection or association of any sort with any issuer of products/ securities recommended herein.
  • Research analyst or his associate or his relative has no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/ securities, including any material information or facts that might compromise its objectivity or independence in the carrying on of research and recommendations services.
  • Research entity or Research analyst or its associates has not received any kind of remuneration or consideration form the products/ securities recommended herein.
  • Research entity or Research analyst or its associates have not received any compensation from the subject company in past 12 months.
  • Research entity or Research analyst or its associates have not managed or co-managed the public offering of Subject Company in past 12 months.
  • Research entity or Research analyst or its associates have not received any compensation for investment banking or merchant banking of brokerage services from the subject company in past 12 months.
  • Research entity or Research analyst or its associates have received any compensation for products or services other than investment banking or merchant banking or brokerage services from the subject company in the past twelve months.
  • Research entity or Research analyst or its associates have not received any compensation or other benefits from the subject company or third party in connection with the research report or research recommendations.
  • Research entity or Research analyst or its associates have not received any compensation for products or services from the subject company in past 12 months.
  • The subject company is or was not a client of Research entity or Research analyst or its associates during twelve months preceding the date of distribution of the research report and recommendation services provided.
  • Research Analysts or its associates has not served as an officer, director or employee of the subject company.
  • Research Analysts has not been engaged in market making activity of the subject company.
  • Research analyst is also working on to development of AI and Algorithmic trading for the extent use of Artificial tools in providing research services.
  • B. Research Analyst is charging maximum Rs 1,51,000 per client per annum per family as per regulations.
  • The pre-paid subscription shall be collected through any of the mode i.e. Account Payee Crossed Cheque/ Demand Drafts I Credit Card or by way of direct credit to the bank accounts through NEFT/ RTGS/ IMPS/ UPI or any other mode specified by SEBI from time to time. All payments made by means of cheques are subject to realization. Client can also make the payment for research services through ‘centralised fee collection mechanism for RA’ (CeFCom).
  • Investors and traders understand the risk involved in the market while trading and investment. Investors and traders agrees that they have read all the disclaimers, disclosures, terms and conditions mentioned in the agreement and on website https://confluenceresearch.in/ before signing the agreement and providing your acknowledgment.
  • Availing the research services: By accepting delivery of the research service, the client confirms that he/she has elected to subscribe the research service of the RA at his/her sole discretion. RA confirms that research services shall be rendered in accordance with the applicable provisions of the RA Regulations.
  • Obligations on RA: RA and client shall be bound by SEBI Act and all the applicable rules and regulations of SEBI, including the RA Regulations and relevant notifications of Government, as may be in force, from time to time.
  • Client Information and KYC: The client shall furnish all such details in full as may be required by the RA in its standard form with supporting details, if required, as may be made mandatory by RAASB/SEBI from time to time. RA shall collect, store, upload and check KYC records of the clients with KYC Registration Agency (KRA) as specified by SEBI from time to time.
  • Standard Terms of Service: For Client consent “I / We have read and understood the terms and conditions applicable to a research analyst as defined under regulation 2(1)(u) of the SEBI (Research Analyst) Regulations, 2014, including the fee structure. I/We are subscribing to the research services for our own benefits and consumption, and any reliance placed on the research report provided by research analyst shall be as per our own judgment and assessment of the conclusions contained in the research report. I/We understand that – i. Any investment made based on the recommendations in the research report are subject to market risk. ii. Recommendations in the research report do not provide any assurance of returns. iii. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report.” Declaration of the RA that: i. It is duly registered with SEBI as an RA pursuant to the SEBI (Research Analysts) Regulations, 2014 and its registration details are: (registration number - INH000014207, registration date Nov 23, 2022); ii. It has registration and qualifications required to render the services contemplated under the RA Regulations, and the same are valid and subsisting; iii. Research analyst services provided by it do not conflict with or violate any provision of law, rule or regulation, contract, or other instrument to which it is a party or to which any of its property is or may be subject; iv. The maximum fee that may be charged by RA is ₹1.51 lakhs per annum per family of client. v. The recommendations provided by RA do not provide any assurance of returns.
  • Risk Factors: Standard warning: “Investment in securities market are subject to market risks. Read all the related documents carefully before investing."
Termination of service and refund of fees:

In case of suspension of certificate of registration of the RA for more than 60 (sixty) days or cancellation of the RA registration, RA shall refund the fees, on a pro rata basis for the period from the effective date of cancellation/ suspension to end of the subscription period.

Mandatory notice:

Clients shall be requested to go through Do’s and Don’ts while dealing with RA as specified in SEBI master circular no. SEBI/HO/MIRSD-POD-1/P/CIR/2024/49 dated May 21, 2024 or as may be specified by SEBI from time to time.

As per SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2025/004 dated January 08, 2024:

The following guidelines apply to fees charged by Research Analysts (RA):

  • Annual Fee Cap:A Research Analyst is permitted to charge a maximum of ₹1,51,000 in total from a client and their family within a 12-month period.
  • Renewal Restrictions:If a client has already paid the maximum permissible fee of ₹1,51,000 before the completion of the 12-month service period (Ex -3,6,9 Months etc), the client shall not be allowed to renew their subscription or Terms and conditions agreement with the Research Analyst until the conclusion of the 12-month period.
  • Compliance Obligation:Clients are advised to note this limitation and plan their subscriptions accordingly, in compliance with SEBI regulations.
Consideration and mode of payment:

The client shall duly pay to RA, the agreed fees for the services that RA renders to the client and statutory charges, as applicable. Such fees and statutory charges shall be payable through the specified manner and mode(s)/ mechanism(s)

Conflict of interest:

The RA shall adhere to the applicable regulations/ circulars/ directions specified by SEBI from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. (A statement covering the mandatory disclosures to be added under this clause by the RA.)

Grievance redressal and dispute resolution:

Any grievance related to (i) non-receipt of research report or (ii) missing pages or inability to download the entire report, or (iii) any other deficiency in the research services provided by RA, shall be escalated promptly by the client to the person/employee designated by RA, in this behalf (RA to provide name and e-mail ID of the designated person/employee).

The RA shall be responsible to resolve grievances within 7 (seven) business working days or such timelines as may be specified by SEBI under the RA Regulations. RA shall redress grievances of the client in a timely and transparent manner. Any dispute between the RA and his client may be resolved through arbitration or through any other modes or mechanism as specified by SEBI from time to time.

Additional Clause:

All additional voluntary clauses added by the RA should not be in contravention with rules/ regulations/ circulars of SEBI. Any changes in such voluntary clauses/document(s) shall be preceded by a notice of 15 days.

Optional Centralised Fee Collection Mechanism:

RA Shall provide the guidance to their clients on an optional ‘Centralised Fee Collection Mechanism for IA and RA’ (CeFCoM) available to them for payment of fees to RA.

Most Important Terms and Conditions (MITC):

The terms and conditions and the consent thereon are for the research services provided by the RA and RA cannot execute/ carry out any trade (purchase/ sell transaction) on behalf of the client. Thus, you are advised not to permit RA to execute any trade on your behalf.

AI and Algorithmic Trading Disclosure:

As per SEBI regulations, we are committed to ensuring transparency in our research and trading services. Our offerings may include the use of Artificial Intelligence (AI) and Algorithmic Trading tools to provide research insights and facilitate trading decisions. However, it is important for investors to understand the following points:

  • No Assurance or Guaranteed Returns: Algorithmic trading tools, Algorithmic strategies and AI-based systems are designed to assist in data-driven decision-making but do not guarantee profits or assured returns. The performance of these tools depends on market conditions, which are inherently unpredictable.
  • Limitations of Algorithmic Trading: Despite the advanced capabilities of these tools, they come with certain limitations.
    • a) Technical Errors – Software or API providers may encounter technical glitches that can lead to incorrect or unintended order execution.
    • b) Broker-Related Issues – Errors originating from the broker's platform or infrastructure may affect the execution of orders.
    • c) Market Conditions – Extreme market volatility may impact the effectiveness of algorithms.
  • No Liability for External Errors: While we take all reasonable steps to ensure the robustness of our systems, we cannot be held responsible for errors or malfunctions arising from:
    • Third-party software or API providers.
    • Broker-related disruptions.
    • Any external factors beyond our control.
  • Risk Acknowledgment: Investors are advised to understand and accept the risks associated with algorithmic trading before using our services. We strongly recommend conducting thorough due diligence and consulting with a financial advisor to align these services with individual investment goals and risk tolerance.
  • Consent: By using our AI and Algorithmic Trading services, you acknowledge and accept the above limitations and disclaimers. This disclosure is in compliance with SEBI regulations to promote transparency and protect investor interests.

Note: Please ensure to review all terms and conditions carefully before proceeding with any investment or trading activity.

Most Important Terms and Conditions (‘MITC’) as per SEBI Circular SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/20 Dated February 17, 2025:
  1. These terms and conditions, and consent thereon are for the research services provided by the Research Analyst (RA) and RA cannot execute/carry out any trade (purchase/sell transaction) on behalf of the client. Thus, the clients are advised not to permit RA to execute any trade on their behalf.
  2. The fee charged by RA to the client will be subject to the maximum of amount prescribed by SEBI/ Research Analyst Administration and Supervisory Body (RAASB) from time to time (applicable only for Individual and HUF Clients).
    • 2.1. The current fee limit is Rs 1,51,000/- per annum per family of client for all research services of the RA.
    • 2.2. The fee limit does not include statutory charges.
    • 2.3. The fee limits do not apply to a non-individual client / accredited investor.
  3. RA may charge fees in advance if agreed by the client. Such advance shall not exceed the period stipulated by SEBI; presently it is one quarter. In case of pre-mature termination of the RA services by either the client or the RA, the client shall be entitled to seek refund of proportionate fees only for unexpired period.
  4. Fees to RA may be paid by the client through any of the specified modes like cheque, online bank transfer, UPI, etc. Cash payment is not allowed. Optionally the client can make payments through Centralized Fee Collection Mechanism (CeFCoM) managed by BSE Limited (i.e. currently recognized RAASB).
  5. The RA is required to abide by the applicable regulations/ circulars/ directions specified by SEBI and RAASB from time to time in relation to disclosure and mitigation of any actual or potential conflict of interest. The RA will endeavor to promptly inform the client of any conflict of interest that may affect the services being rendered to the client.
  6. Any assured/guaranteed/fixed returns 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 RA.
  7. The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA’s research services. All opinions, projections, estimates of the RA are based on the analysis of available data under certain assumptions as of the date of preparation/publication of research report.
  8. Any investment made based on recommendations in research reports are subject to market risks, and recommendations do not provide any assurance of returns. There is no recourse to claim any losses incurred on the investments made based on the recommendations in the research report. Any reliance placed on the research report provided by the RA shall be as per the client’s own judgement and assessment of the conclusions contained in the research report.
  9. The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client.
  10. For any grievances:
    1. Step 1: the client should first contact the RA using the details on its website or following contact details: (RA to provide details as per ‘Grievance Redressal / Escalation Matrix’)
    2. Step 2: If the resolution is unsatisfactory, the client can also lodge grievances through SEBI’s SCORES platform at www.scores.sebi.gov.in
    3. Step 3: The client may also consider the Online Dispute Resolution (ODR) through the Smart ODR portal at https://smartodr.in
  11. Clients are required to keep contact details, including email id and mobile number/s updated with the RA at all times.
  12. The RA shall never ask for the client’s login credentials and OTPs for the client’s Trading Account Demat Account and Bank Account. Never share such information with anyone including RA.