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Risk Profile Questionnaire

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Declaration

I declare that the information provided in this questionnaire is true and accurate to the best of my knowledge. I undertake to inform the Investment Advisor in writing as soon as Possible of any changes to this information. I acknowledge that the Investment Advisor takes no responsibility or liability for any acts or omissions resulting from the provision of incomplete or inaccurate information.

Risk Classification Scores
Low Below 150
Medium 150 – 390
High Above – 390

SUITABILITY ASSESSMENT



Pursuant to SEBI guideline, (Investment Advisor) Regulations 2013 we have formed policies for risk profiling and suitability assessment as required under regulation 16 and 17 of the said act. Following which Investment adviser shall ensure that-

    (a) All investments on which investment advice is provided is appropriate to the risk profile of the client;
    (b) It has a documented process for selecting investments based on client’s investment objectives and financial situation;
    (c) It understands the nature and risks of products or assets selected for clients;
    (d) It has a reasonable basis for believing that a recommendation or transaction entered into:

      (i) meets the client’s investment objectives;
      (ii) is such that the client is able to bear any related investment risks consistent with its investment objectives and risk tolerance;
      (iii) is such that the client has the necessary experience and knowledge to understand the risks involved in the transaction.

Our risk profile comprehensive form comprises of such questions which helps client & us to determine the said objectives. This Investor Suitability assessment guides you in choosing services according to your investment objectives, risk tolerance, financial profile and investment experience. The information provided helps us to assess your needs in a defined manner. It is important to provide accurate and complete information to ensure that appropriate services are recommended according to investment needs and objectives.

To ensure that the advice given to you is suitable for you we shall ensure that all investments on which investment advice is provided is appropriate to your risk profile categorizing as low risk appetite, medium risk appetite and high risk appetite investor. A similar classification will be done for services after considering the risk and reward of the services offered and various SEBI guidelines in this regards. Client with Medium risk appetite is recommended to subscribe Medium risk services only and client with high risk appetite is recommended to subscribe either medium or high risk services. We do not offer low risk services.

Depending on the risk involved in stock market, financial profile and investment experience, clients can be classified into the following categories.


    1. Low risk investor- This type of investor take very low risk and mainly focus on capital protection, they are happy with low rewards.
    2. Medium risk investor - This type of investor is able to accept downfall in their investment occasionally and is willing to take medium risk associated with market. They focus on medium risk & reward.
    3. High risk investor - This type of investor is keen for opportunities to generate high returns and is able to accept substantial risk and even significant downfall in their investment values.

The maximum total score of the risk profile questionnaire is 750. Basis upon the scores we classify clients as –


Risk Assessment Score Risk Tolerance Investor Type Characteristics of Services
Less Than 150 Low Low Risk Investor We don't offer any services of equities & derivatives market to Low Risk appetite client
150 to 390 Medium Medium Risk Investor We don't offer any services of Derivatives & Commodity market to Medium Risk appetite client
Above 390 High High Risk Investor Offer services with High risk and return. Principal amount may be at 100% risk. Suitable only for experienced investor/trader or for investor/trader willing to take risk in market for high returns. Approximately 1-4 tips recommended per services and sometime requested to hold the position as per the services chosen.


As per the SEBI Guidelines, Investment Adviser shall ensure that-


    1. As per the risk profiling conducted, your total score is _______________ and your risk category is _______________________. Hence, Below is the investment advice services List based on your risk category, on next page you can select the services appropriate to your risk profile.
    2. After assessing your investment objectives and financial position through Risk Profiling filled by you through our website, it is notified to you through the e-mail on your registered e-mail id _____________________. Apart from this, you can also send us the risk profiling copy filled by you via e-mail.
    3. After the risk profiling only, the suitable products or services can be offered as per client risk category. Further, the risk associated with each service is defined under moderate risk and high risk.
    Please refer the table below with risk based classification of services.
    4. We believe that the recommendation provided:
      (i) Since your investment objective is __________________, this recommendation meets your expectations.
      (ii) Since, you have experience of ___________________ in the stock/derivative/currency market; it can be considered that you understand the risk associated with the market.
    5. We do not offer any complex financial product/services to any of our client. All the services offered are listed on our website along with their respective features hence you can always access the list of services we offer.

Risk based classification of the services:-

S. No. Service Name Risk classification
1 STOCK CASH Medium
2 CASH HNI High
3 CASH BTST High
4 STOCK FUTURE High
5 FUTURE HNI High
6 FUTURE BTST High
7 STOCK OPTION High
8 OPTION HNI High
9 OPTION BTST High
10 HIGHFLOWN OPTION High
11 TREASURE TROVE High
12 SAND TIMER High
13 EQUITY POSITIONAL High
14 INDEX OPTION High
15 MCX BULLION High
16 MCX ENERGY High


Service Selection Panel



SUITABILITY ASSESSMENT

THIS AGREEMENT IS MADE AND EXECUTED AT Indore (M.P.) on date ___________________.
Email id: ___________________, Contact no: ___________________, Pan No: ___________________,

Service name: ___________________, Fees: Rs. ___________________/-, Duration: ___________________.
Between: Ankush Sanodiya Proprietor of Delight Financial Services, A Registered Investment Adviser with SEBI bearing Registration No. INA000009278 and having its registered office at 201, 2nd Floor, Plot No. 356, 357, 358 Scheme No. 54 Vijay Nagar, Indore 452010 hereinafter called the Investment Adviser.;
AND
Client Name: Mr./Ms./Mrs. _____________________, having its residence at Address: _____________________, _____________________, _____________________, _____________________, herein after the client.That the expression of the term, Investment Adviser and Client shall mean and include their legal heirs, successors, assigns and representatives, etc.
WHEREAS Investment Adviser is been authorised by SEBI to provide investment advice in terms of SEBI (Investment Advisers) Regulations, 2013.

AND WHEREAS client wishes to invest in the securities market in accordance with the advice of the Investment Adviser.

NOW, THEREFORE, in consideration of the mutual covenants contained in this agreement, the parties hereby agree as follows:
    1. Appointment of the Investment Adviser: In accordance with the applicable laws,client hereby appoints, entirely at his / her / its risk, the Investment Adviser to provide the required services (advice relating to investing in, purchasing, selling or otherwise dealing in securities or investment products, and advice on investment portfolio containing securities or investment products, whether written, oral or through any other means of communication for the benefit of the client and shall include financial planning in accordance with the terms and conditions of the agreement as mandated under Regulation19(1)(d) of the Securities and Exchange Board of India(Investment Advisers) Regulations, 2013.
    2. Consent of the client:
      (a) I have read and understood the terms and conditions of Investment Advisory services provided by the Delight Financial Services along with the fee structure and mechanism for charging and payment of fee.

      (b) Based on my written request to the Delight Financial Services, an opportunity was provided by the Delight Financial Services to ask questions and interact with, person(s) associated with the investment advice.

      (c) I assure that I shall promptly update Delight Financial Services in case, my dependent family members‟ whose assets on which investment advice is sought/provided, originate from the income of the single entity i.e., earning individual.

      (d) I declare that I am authorized to make the above transaction and the subscription/investment amount invested by me in various services is through legitimate sources only and does not contravene any prevailing law.

      (e) I confirm and believe that this transaction is appropriate for me and suits my investment objective and risk-taking ability.

      (f) I agree that there is no guarantee of any return on investments made and the past performance does not indicate the future performance of any services.

    3. Declaration from Ankush Sanodiya Properitor of Delight Financial Services: The Investment Adviser hereby declares that it.
      (a) Shall neither render any investment advice nor charge any fee until the client has signed this agreement.

      (b) Shall not manage funds and securities on behalf of the client and that it shall only receive such sums of monies from the client as are necessary to discharge the client’s liability towards fees owed to Delight Financial Services.

      (c) Shall not in the course of providing its services to the client, hold out any investment advice implying any assured returns or minimum returns or target return or percentage accuracy or service provision till achievement of target returns or any other nomenclature that gives the impression to the client that the investment advice is risk-free and/or not susceptible to market risks and or that it can generate returns with any level of assurance.

    4. Fees specified under Investment Adviser Regulations and relevant circulars issued thereunder applicability latest by 1st April 2021: As per the Regulation 15A of the SEBI Investment Adviser Regulations and Circular SEBI/HO/IMD/DF1/CIR/P/2020/182 on Guidelines for Investment Advisers dated September 23, 2020, an Investment Adviser can charge fees from the clients in either of the two modes:
      (a) Assets Under Advice (AUA) mode or Fixed Fee Mode.

      (b) The maximum fee that Investment Adviser can charge is 2.5% of AUA or Rs.1,25,000 per annum per client across all services offered by Delight Financial Services.

    5. Fees: Fees charged to the client. Kindly refer to the Annexure – A.
    6. Terms and Mode of fees applicability latest by 1st April 2021:
      (a) Delight Financial Services fee structure is based on Fixed Fee Model, wherein the total fee charged shall not exceed INR 125000 (Rupees One Lakh Twenty-Five Thousand Only) per annum per client across all services offered. The mode of fee shall remain fixed till 12 months of on-boarding. For fee and its calculation thereof, please refer to the Annexure – A.

      (b) The fee will be charged on the fixed fee basis once, which will be taken as advance for the complete tenure of service. Illustration - The client shall receive payment receipt through email. Periodicity of billing - one-time payment.

      (c) Delight Financial Services accepts payment only through cheque/ Demand Drafts or by way of direct credit to the bank accounts through NEFT/ RTGS/ IMPS/ UPI. However, the fees shall not be accepted in CASH.

      (e) Delight Financial Services shall receive all considerations by way of subscription fee from the client only and not from any person other than the client being advised, in respect of the underlying securities or investment products for which the advice is or to be provided. Please note that the price paid by you may be different (discounted) than that of the list price of a service. Such price paid by you shall not be more that the list price mentioned herewith.

    7. Refund & Cancellation Policy:
      (a) Delight Financial Services does not have a refund policy towards the fee of 1 quarter and may refund the remaining fee in case the service subscribed is of tenure more than 1 quarter in terms of clause 9 refund. Provided, the Client applies for the same in terms of the following conditions:

      (b) The Client is required to apply for refund of any service after subscription thereof via written request at: info@delightfinancial.com from client’s email id registered with Delight Financial Services within first 30 days from the date of commencement of services. Any request send on subsequent dates would not be entertained.

    8. Scope of Services: For Features of the service subscribed, service term, minimum investment etc., please refer to details in service verification emails- Annexure A. For trading principles, please refer to https://delightfinancial.com/index?page=trading-principles
    9. Functions of the Delight Financial Services: Functions, obligations, duties and responsibilities of the Investment Adviser (including principal officer and all persons associated with the investment advice), with specific provisions covering, inter alia
      (a) The Principal Officers and representatives of Delight Financial Services who are rendering investment advice on behalf of Delight Financial Services fulfil minimum qualification and certification requirements as specified under Regulation 7(1) and regulation 7(2) of IA Regulations at all times.

      (b) Delight Financial Services complies with the KYC requirements specified by SEBI from time to time and relies upon on the KYC of the client, as per the terms specified in SEBI {KYC (Know Your Client) Registration Agency} Regulations, 2011 and circulars issued thereunder.

      (c) The nature of service that is provided by Delight Financial Services is directly related to the financial situation of its clients. The relationship between Delight Financial Services and client is that of trust, and Delight Financial Services while performing its role, acts in good faith in the best interests of the client.

      (d) Delight Financial Services discloses all conflicts of interest to the client if at all they arise.

      (e) Delight Financial Services does not receive any consideration or remuneration or payment in any other form from anyone except for the subscription towards the services subscribed i.e., investment advice.

      (f) Delight Financial Services does not provide any other activity such as execution services except for investment advisor services.

      (g) Delight Financial Services maintains strict confidentiality with respect to the information received from the client. Moreover, it does not carry out transaction contrary to its advice to clients on his own account unless 15 days have passed from the date of providing the service.

      (h) Delight Financial Services abides by the Code of Conduct as specified in Third Schedule of the Investment Adviser Regulations.

      (i) Provision regarding Audit as per the Securities and Exchange Board of India (Investment Advisers) Regulations, 2013.

      (j) The investment advice and asset allocation for an investor will be customized to the ability and willingness of the investor to assume risk. This is determined by a risk profiling exercise, which seeks to assess the attitude towards risk and possible loss and the willingness to pursue an investment plan, after understanding the underlying risks. In this regard, Delight Financial Services obtains from the client, such information as is necessary for the purpose of giving investment advice. This information includes age, investment objective, investment horizon, income details, existing assets and liabilities and risk appetite and liability/borrowing details.

      (k) Information provided by clients and their risk assessment gets updated periodically.

      (l) Delight Financial Services communicates the risk profile of the client to such client after risk assessment.

      (m) Delight Financial Services makes disclosures and disclaimers to client in terms of Regulation 18 of the IA Regulations, 2013, to enable the client to take an informed decision. Delight Financial Services endeavours to draw the client’s attention to the warnings, disclaimers in documents, advertising materials relating to an investment product which it is recommending to the client.

      (n) Delight Financial Services maintains client records in terms of Regulation 19 of the IA Regulations, 2013 for a period of five years.

    10. Risk Factors: Based on risk involved in Stock Market, financial profile and investment experience, clients can be categorized into following categories:
      (a) Aggressive Investors (High Risk) - As an aggressive investor you are ready to take higher risk expecting greater returns. This is a result of your urge to get more income and capital growth. You are well place to recover from unforeseen market downturns either because you have time on your side or access to capital returns.

      (b) Moderate Investors (Medium Risk) – As a moderate investor your portfolio should have a bias towards capital growth and a little need of income. You are prepared to accept higher degree of volatility and risk. Your primary concern is to accumulate assets over the medium to long term.

      (c) Conservative Investor (Low Risk) - As a conservative investor your investment portfolio is directly focused on capital growth as well as protecting the wealth already accumulated by you. Your portfolio should be yielding capital for maintaining assets. Calculated risk is accepted to yield better returns.

    11. Validity of Advisory Services: This Advisory Services shall remain in force as long as mutually agreed to by Client and by the Investment Adviser. Further, if the client wishes to renew his/her existing services, then he/she may intimate Investment Adviser in writing and shall pay the renewal fees before the expiry of the current service duration. For further information, please refer to Annexure – A.
    12. Amendments: This agreement may be amended by mutual written consent of the parties and shall have same impact as of this Agreement.
    13. Termination: This Agreement may be terminated under the following circumstances, namely:
      (a) Voluntary / mandatory termination by Delight Financial Services.

      (b) Voluntary / mandatory termination by the client.

      (c) Suspension/Cancellation of registration of Delight Financial Services by SEBI.

      (d) Any other action taken by other regulatory body/ Government authority.

      (e) In case of a voluntary termination of the agreement, the client as well as the Delight Financial Services would be required to give a 30 days prior written notice.

      (f) In case of suspension of the certificate of registration of the Delight Financial Services, the client may be provided with the option to terminate the agreement.

      (g) Such termination shall not, however, affect liabilities or obligations incurred or arising from transactions initiated under this agreement prior to such termination, including the provisions regarding arbitration, which shall survive any expiration or termination of this agreement.

    14. Delight Financial Services engaged in other activities:
      (a) Delight Financial Services maintains an arms-length relationship between its activities as an investment adviser and other activities and to covenant that this arm’s length relationship shall be maintained throughout the tenure of advisory service.

      (b) Delight Financial Services shall not provide any distribution services, for securities and investment products, either directly or through their group to an advisory client.

      (c) Delight Financial Services shall not provide investment advisory services, for securities and investment products, either directly or through their group to the distribution client.

    15. Representation to the Client: Delight Financial Services shall take all consents and permissions from the client prior to undertaking any actions in relation to the securities or investment products advised.
    16. Power of Attorney: Delight Financial Services shall not seek any power of attorney or authorizations from its clients for implementation of investment advice.
    17. Conflict of Interest: Delight Financial Services shall also disclose to the client any 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 investment advisory services.
    18. Maintenance of accounts and Confidentiality:
      (a) Delight Financial Services shall be responsible for maintenance of client accounts and data as mandated under the SEBI (Investment Advisers) Regulations, 2013.

      (b) Delight Financial Services shall not divulge any confidential information about its client, which has come to its knowledge, without taking prior permission of its client, except where such disclosures are required to be made in compliance with any law for the time being in force.

      (c) Delight Financial Services shall not enter into transactions on its own account which are contrary to its advice given to clients for a period of fifteen days from the day of such advice. If, during the period of such fifteen days, the investment adviser is of the opinion that the situation has changed, then it may enter into such a transaction after giving such revised assessment to the client at least 24 hours in advance of entering into such transaction.

    19. Liability of Investment Adviser:
      (a) Delight Financial Services shall not be liable of any loss, which a client may suffer by reason of any depletion in the value of the assets under advice, which may result by reason of fluctuation in asset value, or by reason of non-performance or under-performance of any of its services or any other market conditions.

      (b) The Client acknowledges that Delight Financial Services (or its directors, officers, employees, agents, group entities) shall not be responsible or liable for any loss, claim or direct, indirect, incidental, consequential, special, exemplary, punitive or any other damages (including loss of profits, depreciation in the value of Securities and/ or any financial products, loss of goodwill etc.) for any error of judgment, mistake or for any loss suffered by the Client in connection with the Services relates unless such damage or loss is finally determined by a court of competent jurisdiction to have solely resulted from mala fide, fraud or gross negligence of Delight Financial Services.

    20. Death or Disability of client: In event of client's death/disability, services shall be terminated or provided to his/her succession, nomination, representation etc.
    21. Death or Disability of Investment Adviser: In the event of Investment Adviser’s death / disability, its legal heirs, executor, trustee, administrator of estate of the deceased (the “Obligor”) shall be the person-in-charge. Please refer to Annexure- B for further details.
    22. Settlement of disputes and provision for Arbitration: All such disputes, differences and questions of any nature which at any time arise between the parties to this agreement out of the construction of or concerning anything contained in or arising out of this agreement or as to the rights, duties or liabilities under it or the parties to it shall be referred to the sole Arbitrator under the Arbitration and Conciliation Act, 1996. The sole Arbitrator shall be appointed by the Proprietor of Delight Financial Services. The Arbitration Proceedings shall be held at Indore (Madhya Pradesh) India. However, if disputes do not get resolved through Arbitration, such disputes shall be subject to the exclusive jurisdiction of courts of Indore (Madhya Pradesh) only.
    23. Adherence to grievance redressal timelines: Delight Financial Services shall be responsible to resolve the grievances within the timelines specified under the SEBI circulars.
    24. Severability: If any provision of this Agreement shall be held or made invalid by a court decision, statute, rule or otherwise, the remainder of this Agreement shall not be affected thereby.
    25. Force Majeure: Delight Financial Services shall not be liable for delays or errors occurring by reason of circumstances beyond its control, including but not limited to acts of civil or military authority, national emergencies, work stoppages, fire, flood, catastrophe, acts of God, insurrection, war, riot, or failure of communication or power supply. In the event of equipment breakdowns beyond its control, Delight Financial Services shall take reasonable steps to minimize service interruptions but shall have no liability with respect thereto.
    26. Miscellaneous: Each party agrees to perform such further actions and execute such further agreements as are necessary to effectuate the purposes hereof.
    Annexure-A
    Parameters Description
    Client Name _____________________
    Contact Number _____________________
    Email Id _____________________
    Service Name _____________________
    Service Term _____________________
    Service Price _____________________
    Time Horizon _____________________
    Risk Type _____________________
    Open Position _____________________
    Expected Reward And Risk Per Call _____________________
    Capital Requirement _____________________
I, _____________________ give consent to subscribe _____________________ as per Annexure-A description.
IN WITNESS WHEREOF, the parties hereto have executed the Agreement on the date(s) set forth below, and the Agreement is effective from the date of its execution.
Mr.__________________________________
Mr. Ankush Sanodiya

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