Research Rationale | True Turtles

📢 Disclaimer & Disclosure in Research Report:

Issued By: TRUE TURTLES LLP

*SEBI Research Analyst Registration No.: INH000023621

🧾 General Terms & Conditions:

(a) The recommendations provided in this report are based on publicly available information we believe to be reliable and accurate at the time of publication.

(b) Unless otherwise stated, our recommendations are intended for a 12-month investment horizon.

(d) Security prices may fluctuate due to market volatility or company-specific events, and returns may vary dramatically over time.

(e) We reserve the right to revise or withdraw ratings due to reassessment of valuation, market events, or lack of clarity.

(f) Opinions expressed are subject to change without notice, and we are under no obligation to inform clients of such changes.

(g) Clients are advised to carefully assess market risks, including the possibility of partial or permanent capital loss.

(h) TRUE TURTLES LLP adheres strictly to SEBI (Research Analyst) Regulations, 2014, and does not offer investment advisory or PMS (Portfolio Management Services).

📜 Analyst Certification:

I, TRUE TURTLES LLP, as a SEBI-registered Research Analyst, certify that:

(a) The views expressed in this report represent the honest and independent opinions of the analyst(s) on the subject securities.

(b) This report has been prepared using data from publicly available sources deemed reliable.

🔍 Conflict of Interest & Ownership Disclosure:

Neither the firm, its analysts, nor their relatives or associates:

(a) May have a financial interest in the subject company at the time of publication.

(b) Own 1% or more of the subject company’s equity securities.

(d) Have received any compensation (direct or indirect) from the subject company in the past 12 months.

(e) Have provided any investment banking, merchant banking, or brokerage services to the subject company.

(f) Serve in any managerial, officer, or directorial capacity for the subject company.

(g) Are involved in market-making activities for the subject company.

(h) Have the subject company as a client in the last 12 months.

✅ Compensation & Conflicts of Interest:

(a) Have not received any compensation from the subject company during the past twelve months.

(b) Have not managed or co-managed any public offering of securities for the subject company in the past twelve months.

(c) Have not received any compensation for investment banking, merchant banking, or brokerage services from the subject company in the past twelve months.

(d) Have not received any compensation for products or services other than investment banking, merchant banking, or brokerage services from the subject company in the past twelve months.

(e) Have not received any other benefits or incentives from the subject company or any third party in connection with this research report.

✅ Employment & Operational Involvement:

(f) Have not served as an officer, director, or employee of the subject company at any point.

(g) Are not engaged in any market-making activity for the subject company.

✅ Client Relationship & Service Status:

(h) The subject company has not been a client of TRUE TURTLES LLP during the twelve months prior to the publication of this report, and no services have been rendered to the subject company during this period.

✅ Research Quality and Cross-Review:

(i)TRUE TURTLES LLP has a process in place to review third-party research reports, if used, to ensure that no untrue statements of material fact or misleading information are included.

🛑 Disciplinary History:

TRUE TURTLES LLP, its partners, employees, and associates have no prior disciplinary action, regulatory penalties, or adverse rulings from SEBI or any other authority.

📢 Terms and Conditions Regarding Research Reports and Recommendations

Issued By: TRUE TURTLES LLP

At TRUE TURTLES LLP, we prioritize delivering dependable and precise research reports and recommendations to our registered clients. Our analyses rely on authentic data from reliable sources, including publicly available information. All reports are carefully reviewed prior to dissemination to ensure accuracy and to avoid misleading statements.

⚠️ Key Disclosures and Risk Factors

(a) All research reports and recommendations are provided solely for informational purposes and should not be construed as an offer or solicitation to buy, sell, hold, or subscribe to any securities or financial instruments.

(b) TRUE TURTLES LLP, along with its partners, employees, officers, and affiliates, expressly disclaim any liability for loss or damages arising from unintentional errors or omissions in any information or recommendations contained in the research reports.

(c) Investment in capital markets is inherently subject to risks. Clients should assess their own risk tolerance carefully and consider consulting a qualified financial advisor prior to making investment decisions.

(d) The research products of TRUE TURTLES LLP are not tailored to individual investment objectives, financial situations, or specific needs.

(e) Clients obtaining research recommendations should exercise independent judgment and act in accordance with their financial capacity and risk appetite, fully appreciating the risks involved in securities markets.

⚠️ Risk Warnings:

(a) Investment in securities markets is subject to market risks. Read all related documents carefully before investing.

(b) Market conditions may cause partial or permanent loss of capital or portfolio value.

(c) The Securities Quoted Are for Illustration Only and Are Not Recommended.

(d) Past performance is not indicative of future results.

(e) “Registration granted by SEBI, membership of a SEBI recognized supervisory body (if any), and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.”.

❗ Open Position Risk:

Our research recommendations may remain open-ended, and in certain cases, no stop-loss or target levels may be defined. In such scenarios, your portfolio could be at risk of heavy losses caused by rapid market movements or unforeseen company-specific events.

🧾 No Loss or Refund Guarantee:

(a) There is absolutely no scope for refunding losses incurred from acting on any research report or commentary.

(b) While pro-rata refunds may be considered for subscriptions due to dissatisfaction, these are not tied to investment outcomes.

💻 Social Media Disclaimer:

Any content shared via our social media handles is strictly for educational purposes and should not be interpreted as financial recommendations.

📌 Always consult a SEBI-registered investment adviser before making any financial decisions.

🤖 Use of AI and Algorithm tools in Research:

Our research process includes technical and fundamental analysis, occasionally supported by AI and algorithm-based tools.

While AI and algorithms enhance analytical capabilities:

(a) It may introduce data biases, system vulnerabilities, or errors in interpretation, which lead to losses.

(b) AI and algorithm-generated insights carry a risk of misleading recommendations due to inaccurate or poor-quality input data.

(c) Client data privacy and security remain a top priority and are handled in accordance with applicable laws and regulations.

(d) There is no guarantee of success or return when acting on AI-generated recommendations.

(e) You bear the full risk of any investment decisions made based on such advice.

(f) The provider is not liable for any losses or damages you may incur as a result of your actions taken as per AI recommendations.

📈 Model Portfolio Disclaimer:

TRUE TURTLES LLP may issue model portfolios for educational purposes, in full compliance with SEBI regulations. These are not tailored to individual financial goals, and clients must independently assess risk-reward based on their profile.

✅ Business Activity and Disclosures:

Entity Name: TRUE TURTLES LLP (Research Analyst)

Principal Officer of TRUE TURTLES LLP

TRUE TURTLES LLP primarily focuses on Research Analyst activities, offering clients defined ratings for Buy, Sell, Hold, and other options.

Any additional activities do not pose a conflict of interest with the responsibilities of a Research Analyst.

✅ Compliance and Transparency:

This disclosure is made to ensure transparency regarding potential outside business interests and affiliations of the Principal Officer. There is no conflict of interest between research activities and other activities.

💳 Fee Payment & Investor Protection:

(a) All service fees must be paid only via our official website: www.trueturtles.in or verified bank/payment gateway channels/@valid UPI.

(b) Centralized Fee Collection Mechanism (CeFCoM), if applicable

(c) Payments made to any personal accounts or unauthorized third parties will not be acknowledged, and no liability will arise therefrom.

(d) No third party or employee is authorized to offer return guarantees. Report any such activity to our Compliance Officer and SEBI immediately.

(e) If you engage with such unauthorized persons, including our employees or associates, or accept return guarantees without officially informing the company, the company will not be liable for any resulting losses or liabilities.

(f) Reporting such incidents both internally (Compliance Officer) and to the regulatory authority (SEBI) is a critical step to help stop potentially illegal investment schemes.

📬 Contact Details:

Research Analyst Entity: TRUE TURTLES LLP

SEBI RA Reg. No.: INH000023621

Trade Name/Website: www.trueturtles.in

Registered Office:

Tower E Flat No. 404, Emerald Estate, Sector 65, Badshahpur, GURUGRAM, HARYANA, 122101

Compliance Officer: TRUE TURTLES LLP

📧 Email: support@trueturtles.in

📞 Phone: +91 80530 80430

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