Precision Research.
Disciplined Results.

1. Purpose
The purpose of the document is to provide essential information about the Research Services in a manner to assist and enable the prospective client/client in making an informed decision for engaging in Research services before onboarding.

2. History, Present Business, and Background
Sai Prasad Himmatrao Holkar is registered with SEBI as Research Analyst with registration no. INH000019901. The Research Analyst offers research and recommendation services. BSE Enlistment No. 6512.

3. Terms and Conditions of Research Services
The Research Services will be limited to providing independent research recommendations and shall not be involved in any advisory or portfolio allocation services. The Research Analyst never guarantees the returns on the recommendation provided. Investor shall take note that Investment/trading in stocks/Index or other securities is always subject to market risk. Past performance is never a guarantee of same future results. The Research Analyst shall not be responsible for any loss to the Investors.

4. Disciplinary History
There are no pending material litigations or legal proceedings against the Research Analyst. As on date, no penalties / directions have been issued by SEBI under the SEBI Act or Regulations made thereunder against the Research Analyst relating to Research Analyst services.

5. Details of Associates
No associates.

6. Disclosures with Respect to Research and Recommendations Services
• The Research Analyst or any of its officer/employee does not trade in securities which are subject matter of recommendation.
• There are no actual or potential conflicts of interest arising from any connection to or association with any issuer of products/securities.
• Research Analyst or its employee or its associates have not received any compensation from the company which is subject matter of recommendation.
• Research Analyst or its employee or its associates have not managed or co-managed the public offering of any company.
• Research Analyst or its employee or its associates have not received any compensation for investment banking or merchant banking or brokerage services from the subject company.
• Research Analyst or its employee or its associates have not received any compensation for products or services other than above from the subject company.
• Research Analyst or its employee or its associates have not received any compensation or other benefits from the Subject Company or 3rd party in connection with the research report/recommendation.
• The subject company was not a client of Research Analyst or its employee or its associates during twelve months preceding the date of recommendation services provided.
• Research Analysts or its employee 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.

Standard Warning
“Investment in securities market are subject to market risks. Read all the related documents carefully before investing.”

Disclaimer
“Registration granted by SEBI, and certification from NISM in no way guarantee performance of the Research Analyst or provide any assurance of returns to investors.”

A. Vision & Mission

Vision
Invest with knowledge & safety.

Mission
Every investor should be able to invest in suitable investment products based on their financial needs, effectively manage and monitor their investments to achieve financial goals, access relevant reports, and enjoy long-term financial well-being.

B. Business Activities of the Research Analyst
The Research Analyst undertakes the following activities:

• Publish research reports based on independent research activities.
• Provide independent and unbiased views on securities.
• Offer unbiased recommendations while disclosing any financial interest in recommended securities.
• Provide recommendations based on publicly available information and professional analysis.
• Conduct annual compliance audits as prescribed by SEBI.

C. Services Provided to Investors
The following services are provided without indicative timelines:

• Client onboarding and registration.
• Mandatory disclosures to clients.
• Distribution of research reports and recommendations without discrimination.
• Maintaining confidentiality of research reports until officially published or shared.

D. Grievance Redressal Mechanism
Investors should first approach the concerned Research Analyst for any complaint or grievance. Every effort shall be made to resolve the grievance within 30 days.

If the complaint is not resolved satisfactorily, investors may lodge a complaint through the SEBI SCORES Portal, which is SEBI's centralized web-based grievance redressal system. Investors can also track the status of their complaint through the portal.

For physical complaints, investors may write to:

Office of Investor Assistance and Education
Securities and Exchange Board of India (SEBI)
SEBI Bhavan, Plot No. C4-A, "G" Block,
Bandra-Kurla Complex, Bandra (East),
Mumbai – 400051.

E. Expectations from Investors

Do's

• Always deal with a SEBI Registered Research Analyst.
• Verify that the Research Analyst holds a valid SEBI Registration Certificate.
• Check the SEBI Registration Number before availing services.
• Refer to the official list of SEBI Registered Research Analysts available on the SEBI website.
• Read all disclosures in research reports before making investment decisions.
• Make all payments only through official banking channels and retain payment receipts.
• Review research recommendations carefully before investing or applying in public issues.
• Clarify all doubts with your Research Analyst before acting on recommendations.
• Inform SEBI if any Research Analyst offers assured or guaranteed returns.

Don'ts

• Do not provide investment funds directly to the Research Analyst.
• Do not rely on misleading advertisements or market rumours.
• Do not get influenced by limited-period discounts, gifts, or promotional incentives.
• Never share your Trading Account or Demat Account login credentials, passwords, PINs, or OTPs with anyone.

1. Acceptance of Terms
By accessing and using this website, you acknowledge that you have read, understood, and agreed to be bound by these Terms & Conditions and all applicable policies published on this website.

2. Free Trial Recommendations
Free trial recommendations provided by Sai Prasad Himmatrao Holkar are intended solely for demonstration and evaluation purposes. The decision to act upon or disregard these recommendations rests entirely with the client.

3. Research Recommendations
Research recommendations are provided according to the subscription package selected by the client and are based on comprehensive market analysis. The final decision to execute or avoid any trade remains solely with the client. Sai Prasad Himmatrao Holkar shall not be liable for any profits or losses arising from investment decisions based on these recommendations.

4. Market Risk & Limitation of Liability
Sai Prasad Himmatrao Holkar shall not be responsible for any losses arising due to market fluctuations, delays in receiving recommendations, technical failures, communication issues, or inaccuracies in information. Investments and trading in the securities market are subject to market risks, and clients are solely responsible for their investment decisions.

5. Confidentiality & Intellectual Property
All employees, associates, and clients of Sai Prasad Himmatrao Holkar are strictly prohibited from sharing, reproducing, distributing, forwarding, or publishing any research reports, trading calls, or confidential information without prior written consent. Appropriate legal action may be initiated against any person found violating this policy.

6. Payment Policy
No employee or associate of Sai Prasad Himmatrao Holkar is authorized to accept gifts, commissions, or personal benefits from clients. All payments must be made only to the official bank account or payment methods published on the official website. Payments made to any personal account shall be solely at the client's own risk.

7. Trading Account Security
Sai Prasad Himmatrao Holkar does not operate, manage, or access clients' Demat or Trading Accounts. Clients must never share their User ID, Password, Security Questions, PIN, OTP, or any login credentials with any employee or representative. The firm shall not be responsible for any losses arising from sharing such confidential information.

8. Modification of Terms
Sai Prasad Himmatrao Holkar reserves the right to modify, update, or revise these Terms & Conditions at any time without prior notice. Updated terms shall become effective immediately upon publication on the website.

9. Investment Disclaimer
Trading and investing in the securities market involve substantial risk, including the possible loss of capital. All research reports, recommendations, opinions, and market views provided through this website are intended solely for informational and educational purposes and should not be construed as guaranteed returns or assured profits. Clients accept full responsibility for all investment decisions and their outcomes.

10. Copyright & Usage
All content, research reports, trading recommendations, graphics, documents, and materials available on this website are the intellectual property of Sai Prasad Himmatrao Holkar and are intended solely for the personal use of subscribed clients. Reproduction, redistribution, resale, copying, or commercial use without prior written permission is strictly prohibited.

11. Confirmation
By continuing to access or use this website and its services, you confirm your acceptance of these Terms & Conditions and agree to comply with all applicable laws, regulations, and policies governing the services offered by Sai Prasad Himmatrao Holkar.

1. No Refund for Availed Services
All payments made towards our research services are final and non-refundable for the period of services already availed by the client. Any dissatisfaction, complaint, or concern regarding the quality of services during the active subscription period shall not entitle the client to any refund or compensation.

2. Refund for Unused Subscription Period
In accordance with applicable SEBI guidelines, if a client chooses to discontinue the subscription before the expiry of the subscription period, a refund shall be processed only for the unused portion of the subscription on a pro-rata basis.

The refund amount shall be calculated after deducting:

• Charges for services already availed.
• Applicable taxes.
• Administrative or processing charges, if applicable.

3. No Refund for Market Outcomes
Refunds shall not be granted based on trading losses, investment performance, market fluctuations, or dissatisfaction with research recommendations. Investments in securities markets are subject to market risks, and all investment decisions remain the sole responsibility of the client.

4. Acknowledgement of Terms
By subscribing to our research services and making payment, the client confirms that they have read, understood, and accepted this Refund Policy along with all applicable Terms & Conditions, Risk Disclosures, and other regulatory disclosures published on our website.

5. Contact for Assistance
For any queries regarding this Refund Policy or refund eligibility, clients may contact us using the details below:

Phone: +91 8308900769
Email: ra.saiprasadholkar@gmail.com

Firm Details
Sai Prasad Himmatrao Holkar
SEBI Registration Number: INH000019901
BSE Enlistment: 6512
Address: Shrikrushna Nagar, Nandurkhi Road, Shirdi, Maharashtra - 423107 (India)
Email: ra.saiprasadholkar@gmail.com
Support: +91 8308900769
Instagram: @urssaii
WhatsApp: +91 8308900769

1. Introduction
This Anti-Money Laundering (AML) Policy outlines the framework adopted by Sai Prasad Himmatrao Holkar, a SEBI Registered Research Analyst (Registration No. INH000019901, BSE Enlistment: 6512), to comply with the Prevention of Money Laundering Act, 2002 (PMLA), applicable rules, and SEBI guidelines including the SEBI Circular dated February 17, 2025. The policy ensures that all research and advisory services, including Intraday Trading, Swing Trading, Research Reports, and IPO Analysis, are protected against misuse for money laundering or terrorist financing activities.

2. Objective
The objective of this policy is to establish a comprehensive framework for detecting, preventing, monitoring, and reporting suspicious activities while ensuring compliance with applicable laws and regulations.

• Policy for acceptance of clients.
• Procedure for identifying clients.
• Transaction monitoring and Suspicious Transaction Reporting (STR).

3. Client Due Diligence (CDD) Process

Policy for Acceptance of Clients

• No accounts will be opened in fictitious or anonymous names.
• Accounts will not be opened where adequate KYC procedures, including PAN verification, cannot be completed.
• All clients must be KYC compliant and provide documents as prescribed by SEBI.
• Client identities will be verified against SEBI's list of banned persons/entities and stock exchange records.
• Risk assessments will include screening against sanctions lists maintained under United Nations Security Council Resolutions.

Procedure for Identifying Clients

• Client identity will be verified using reliable KYC documents including PAN and address proof.
• Any discrepancy in documentation will be escalated to the Compliance Officer.
• Client records will be updated periodically in accordance with SEBI KYC requirements.

4. Maintenance of Records
All KYC records, client documents, transaction details, and communication records shall be maintained securely for a minimum period of 10 years or until completion of any regulatory proceedings, in accordance with PMLA and SEBI regulations.

Records shall be securely maintained at:
Shrikrushna Nagar, Nandurkhi Road, Shirdi, Maharashtra - 423107 (India)

5. Monitoring & Reporting of Transactions

Monitoring Transactions

• Fees for research services shall be accepted only through authorized banking channels such as UPI and Bank Transfer.
• No cash transactions shall be accepted.
• Transactions shall be continuously monitored for unusual or suspicious activities.
• Relevant transaction records shall be maintained for regulatory and audit purposes.

Reporting Suspicious Transactions

• Suspicious activities shall be documented with supporting details.
• The Compliance Officer shall report suspicious transactions to the Financial Intelligence Unit – India (FIU-IND).
• Confidentiality shall be maintained while filing Cash Transaction Reports (CTR) and Suspicious Transaction Reports (STR).

6. Roles & Responsibilities

Principal Officer
Name: Sai Prasad Himmatrao Holkar
Phone: +91 8308900769
Email: ra.saiprasadholkar@gmail.com

• Communicate AML policy to all employees.
• Conduct regular AML awareness and compliance training.
• Ensure compliance with SEBI and PMLA regulations.
• Report suspicious transactions to FIU-IND.
• Resolve AML-related employee queries.

7. Onboarding Staff

• Follow KYC and Client Due Diligence procedures during onboarding.
• Verify PAN card and address proof.
• Report suspicious client activities to the Compliance Officer.
• Comply with AML laws and internal compliance procedures.

8. Communication of Policy

• A copy of this policy will be shared with relevant staff.
• Annual AML awareness training shall be conducted.
• The policy shall remain available on the official website under the Compliance & Disclosures section.

9. Compliance & Cooperation

• Comply with SEBI regulations, PMLA, and other statutory requirements.
• Submit regulatory reports to BASL whenever required.
• Cooperate with law enforcement authorities as permitted under applicable law.
• Maintain an investor grievance redressal mechanism through email and phone support.
• Respond to grievances within SEBI prescribed timelines.
• Report any fraudulent or unauthorized use of the SEBI Registration Number to SEBI.

10. Review of Policy
This AML Policy shall be reviewed annually or whenever required to ensure continued compliance with updated SEBI regulations, PMLA provisions, and other applicable legal requirements.

Business Hours
Monday – Friday: 9:00 AM – 6:00 PM
Saturday: 10:00 AM – 2:00 PM
Sunday: Closed

Last Updated: 13 July 2026

1. Introduction
This Privacy Policy explains how Sai Prasad Himmatrao Holkar, trading as ShareBiz Research ("ShareBiz Research", "we", "us", "our"), a SEBI Registered Research Analyst (Registration No. INH000019901, BSE Enlistment No. 6512), collects, uses, stores, discloses and protects personal information obtained through this website, free trial forms, WhatsApp, phone, email and other channels used to provide research and advisory services. By accessing this website or availing our services, you agree to the collection and use of information in accordance with this Policy. This Policy should be read together with our Terms & Conditions, AML Policy, Investor Charter and Refund Policy, all published on this website.

2. Information We Collect
• Full name, mobile number, email address, and the service(s) you are interested in.
• KYC documents where required for client onboarding (PAN card, address proof, and other documents prescribed by SEBI).
• Communications sent via WhatsApp, email, phone, or contact forms.
• Payment-related details such as transaction reference or UPI/bank transfer confirmation — we do not collect or store your card, net-banking, or UPI login credentials.
• Technical data such as IP address, browser type, device information, and pages visited, collected through cookies when you browse this website.

3. How We Use Your Information
We use your information to provide research recommendations and advisory services you have subscribed to, process free trial requests, onboard clients including KYC verification as mandated under SEBI (Research Analysts) Regulations, 2014 and the PMLA, respond to queries and grievances, comply with SEBI/BSE/PMLA/FIU-IND regulatory obligations, send service-related communications, and prevent fraud or misuse of our SEBI registration. We do not use your information to guarantee or assure any investment returns.

4. Sharing and Disclosure of Information
We do not sell, rent, or trade your personal information. We may share information only with regulators and authorities (SEBI, BSE, SEBI SCORES, ODR Portal, FIU-IND) where required by law; with service providers who assist in operating this website strictly for that purpose; where required to comply with a legal obligation; or in connection with a business restructuring, subject to confidentiality obligations equivalent to this Policy.

5. Data Retention
Client KYC records, transaction details, and related communication records are retained for a minimum of 10 years, or until completion of any regulatory proceeding, in accordance with PMLA and SEBI requirements, and are securely maintained at our registered address: Shrikrushna Nagar, Nandurkhi Road, Shirdi, Maharashtra – 423107, India. Other personal information is retained only as long as necessary to fulfil the purpose for which it was collected, unless a longer period is required by law.

6. Data Security
We implement reasonable technical and organizational security practices to protect your personal information, in line with the IT Act, 2000 and applicable rules. No method of transmission over the internet is 100% secure, and we cannot guarantee absolute security. We will never ask for your Trading Account or Demat Account login ID, password, PIN, or OTP.

7. Cookies
Our website may use cookies and similar technologies to improve functionality and understand usage. You can control or disable cookies through your browser settings.

8. Your Rights
Subject to applicable law, you may request access to or correction of the personal information we hold about you, withdraw consent for non-regulatory communications at any time, and lodge a grievance regarding handling of your personal information. We may be unable to delete certain information we are legally required to retain under SEBI/PMLA regulations.

9. Children's Privacy
Our services are intended only for individuals competent to contract under the Indian Contract Act, 1872, and are not directed at children under 18 years of age.

10. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised "Last Updated" date.

11. Grievance Officer / Contact Us
Sai Prasad Himmatrao Holkar
SEBI Registered Research Analyst (INH000019901), BSE Enlistment 6512, Compliance Officer & Grievance Officer.
Address: Shrikrushna Nagar, Nandurkhi Road, Shirdi, Maharashtra – 423107, India
Email: ra.saiprasadholkar@gmail.com    Phone: +91 88287 36710 / +91 83089 00769
If you are not satisfied with our response, you may escalate through the SEBI SCORES Portal and thereafter the ODR Portal, as applicable.