Manikanth Devarakonda

Disclaimer: Registration granted by SEBI, membership of a SEBI recognized supervisory body (if any), enlistment with RAASB/BSE and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

Standard Warning: Investments in the securities market are subject to market risks. Please read all related documents carefully before investing.

Our Registered Office address: Flat 203, 3rd floor, Deepika Residency Vijaypuri Colony, South Lalaguda, Tarnaka, Secunderabad, Hyderabad, Telangana, 500017

SEBI office address: SEBI Bhavan BKC, Plot No. C4-A, 'G' Block, Bandra-Kurla Complex, Bandra (East), Mumbai – 400051, Maharashtra

As per SEBI Circular SEBI/HO/IMD/IMD-II CIS/P/CIR/2023/30 dated April 6, 2023.

Manikanth Devarakonda is a SEBI-registered Research Analyst operating under the SEBI (Research Analysts) Regulations, 2014. Below are the key registration details:

Name of Research Analyst	Manikanth Devarakonda
Type of Registration	Individual
SEBI Registration Number	INH000015871
BSE Enlistment Number	6128
Registration Validity	Apr 16, 2024 – Perpetual
Registered Office Address	Flat 203, 3rd floor, Deepika Residency Vijaypuri Colony, South Lalaguda, Tarnaka, Secunderabad, Hyderabad, Telangana, 500017
Contact Number	+91 88002 64952
Email ID	manikanth.sebi@gmail.com

Herein, you can access the complete registration details of this Research Analyst and other necessary information associated with the license.

Annexure A — Investor Charter in Respect of Research Analysts

A. Vision and Mission Statements for Investors

Vision: Invest with knowledge & safety.

Mission: Every investor should be able to invest in right investment products based on their needs, manage and monitor them to meet their goals, access reports and enjoy financial wellness.

B. Details of Business Transacted by the Research Analyst

• To publish research reports based on the research activities of the RA.
• To provide an independent, unbiased view on securities.
• To offer unbiased recommendations, disclosing financial interests in recommended securities.
• To provide research recommendations based on analysis of publicly available information and known observations.
• To conduct an audit annually.
• To ensure all advertisements adhere to the Advertisement Code for Research Analysts.
• To maintain records of interactions with all clients, including prospective clients, where research-related conversations have taken place.

C. Details of Services Provided to Investors (No Indicative Timelines)

Onboarding of Clients

• Sharing of terms and conditions of research services.
• Completing KYC of fee-paying clients.

Disclosure to Clients

• Disclose material information for informed decisions, including business activity, disciplinary history, terms and conditions, associates, risks and conflicts of interest.
• Disclose the extent of use of Artificial Intelligence tools in providing research services.
• Disclose, while distributing third-party research reports, any material conflict of interest of such provider.
• Disclose any conflict of interest between research services and other activities.
• Distribute research reports and recommendations without discrimination.
• Maintain confidentiality of the research report until made available in the public domain.
• Respect data privacy rights of clients.
• Disclose service timelines and adhere to them.
• Provide clear guidance and caution when recommending complex, high-risk products.
• Treat all clients with honesty and integrity, and maintain confidentiality of client information.

D. Grievance Redressal Mechanism and How to Access It

Mode of filing a complaint with the Research Analyst: An investor may approach the concerned Research Analyst, who shall strive to redress the grievance immediately, but not later than 21 days of receipt.

Mode of filing on SCORES or with RAASB: SCORES 2.0 — a web-based centralized grievance redressal system of SEBI (scores.sebi.gov.in). Two-level review: first by RAASB, second by SEBI. Complaints may also be sent via the designated email ID of RAASB.

If unsatisfied with the resolution, investors may file a complaint on the SMARTODR platform for resolution via online conciliation or arbitration.

Physical complaints may be sent to: Office of Investor Assistance and Education, Securities and Exchange Board of India, SEBI Bhavan, Plot No. C4-A, 'G' Block, Bandra-Kurla Complex, Bandra (E), Mumbai – 400 051.

E. Rights of Investors

• Right to Privacy and Confidentiality
• Right to Transparent Practices
• Right to Fair and Equitable Treatment
• Right to Adequate Information
• Right to Initial and Continuing Disclosure
• Right to receive information about statutory and regulatory disclosures
• Right to Fair & True Advertisement
• Right to Awareness about Service Parameters and Turnaround Times
• Right to be informed of timelines for each service

By accessing and using this website or availing any of our services, you agree to be bound by the following terms and conditions. If you do not agree, you are advised not to use this website or subscribe to any services.

1. Use of Website and Services

The free trial services offered by Manikanth Devarakonda are intended solely for demonstration purposes. Any action taken based on such trial recommendations is at the sole discretion and risk of the user.

2. Research and Recommendations

All research-based recommendations are provided based on the subscription package chosen by the client, prepared through thorough technical and fundamental analysis. Clients are advised to exercise their own judgment; the firm bears no responsibility for gains or losses arising from acting on these recommendations.

3. Market Risk Disclaimer

Stock market investment and trading inherently involve risks. Manikanth Devarakonda shall not be held liable for losses arising due to market fluctuations, delays in receiving recommendations, technical or communication issues, or inaccuracies/omissions in shared information. Clients assume full responsibility for their trading activities.

4. Confidentiality and Data Sharing

All research reports, strategies, and communications are strictly confidential. Sharing or distributing this content is prohibited and may invite legal action.

5. Code of Conduct – Staff and Clients

No employee or associate is permitted to solicit or accept personal gifts, benefits, or payments from clients. All payments must be made only to the official bank account listed on this website. Personal transfers are not authorized.

6. Account Security

Manikanth Devarakonda does not operate or manage client Demat or trading accounts. Clients must never share login credentials, passwords, security questions, or OTPs with any representative. We disclaim liability for any loss resulting from such disclosure.

7. Policy Updates

We reserve the right to update these terms at any time without prior notice; continued use implies acceptance of updated terms.

8. Disclaimer

Content, research reports, and investment ideas shared on this website are for general informational purposes only and do not constitute financial advice or a solicitation to buy/sell securities.

9. Intellectual Property

All research material and content is for personal use only. Unauthorized reproduction, distribution, or commercial use is strictly prohibited.

10. Acceptance

By continuing to use this website, you confirm that you have read, understood, and agree to abide by these Terms & Conditions, including acknowledgment of trading and investment risks.

Data for the month ending: April 2026

1. Data for the Month Ending – April 2026

2. Trend of Monthly Disposal of Complaints

3. Trend of Annual Disposal of Complaints

All sales are final; we do not offer refunds for the paid period of services already availed. Complaints or dissatisfaction regarding service quality during the paid period do not entitle the client to any refund or compensation.

As per SEBI guidelines, if a client requests cancellation of subscription, a refund shall only be issued for the unused portion, calculated on a pro-rata basis, deducting charges for services already availed, including applicable taxes and administrative fees.

Refunds will not be provided for the period of services already availed, irrespective of client satisfaction with the recommendations or trade outcomes. Investment in securities markets is subject to market risks; profits and losses from using our recommendations are solely the client's responsibility.

By subscribing and making payment, the client acknowledges having read, understood, and agreed to this refund policy along with the disclaimer, disclosure, and other terms on this website.

For questions regarding refunds, contact: Phone: +91 88002 64952  |  Email: manikanth.sebi@gmail.com

Manikanth Devarakonda is committed to protecting the privacy of every individual who interacts with us. This Privacy Policy outlines how we collect, use, store, and safeguard personal information.

1. Information We Collect

We may collect personal information such as name, phone number, email address, and other contact details when you engage with our services, submit inquiries, fill out website forms, or communicate via email, WhatsApp, or social media.

2. Purpose of Collection and Usage

• To provide subscribed services
• To communicate updates, offers, or service-related information
• To send newsletters, surveys, and promotional content
• To improve services and understand client needs
• To comply with regulatory or legal requirements

3. Communication Consent

By submitting an inquiry or reaching out via any channel, you authorize us to contact you through calls, SMS, emails, and WhatsApp, even if registered under the National Do Not Disturb (DND) registry.

4. Data Security

We take appropriate technical and organizational measures to protect data from unauthorized access, misuse, or disclosure, though absolute security cannot be guaranteed.

5. Disclosure to Third Parties

We do not share personal information with third parties unless required by law or with explicit consent. Information is never sold or rented for marketing purposes.

6. Opt-Out Option

To stop receiving promotional communication, email manikanth.sebi@gmail.com. Preferences will be updated within a reasonable timeframe.

7. Policy Modifications

This policy may be updated to reflect changes in business practices or legal obligations; changes will be posted with an updated effective date.

8. Contact Information

Manikanth Devarakonda
Registered Office: Flat 203, 3rd floor, Deepika Residency Vijaypuri Colony, South Lalaguda, Tarnaka, Secunderabad, Hyderabad, Telangana, 500017
Phone: +91 88002 64952  |  Email: manikanth.sebi@gmail.com

This document provides essential information about Research Services to assist the prospective client/client in making an informed decision before onboarding.

History, Present Business and Background

Manikanth Devarakonda is registered with SEBI as a Research Analyst (Registration No. INH000015871), engaged in offering research and recommendation services.

Terms and Conditions of Research Services

Research Services are limited to providing independent research recommendations and do not involve advisory or portfolio allocation services. The Research Analyst never guarantees returns on recommendations; investment/trading in stocks, index, or other securities is always subject to market risk, and past performance is never a guarantee of future results. The Research Analyst is not responsible for any loss to investors.

Disciplinary History

There are no pending material litigations or legal proceedings against the Research Analyst. As on date, no penalties or directions have been issued by SEBI against the Research Analyst relating to Research Analyst services.

Details of Associates

No associates.

Disclosures with Respect to Research and Recommendation Services

• The Research Analyst or any officer/employee does not trade in securities that are the 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 that might compromise objectivity or independence; any such conflict shall be disclosed to the client as and when it arises.
• The Research Analyst, employees, or associates have not received compensation from the company that is the subject matter of recommendation.
• The Research Analyst, employees, or associates have not managed or co-managed any public offering.
• No compensation has been received for investment banking, merchant banking, or brokerage services from the subject company.
• No compensation has been received for products or services other than the above from the subject company.
• No compensation or other benefits have been received from the subject company or a third party in connection with the research report/recommendation.
• The subject company was not a client of the Research Analyst, employees, or associates during the twelve months preceding the date of recommendation.
• The Research Analyst, employees, or associates have not served as an officer, director, or employee of the subject company.
• The Research Analyst 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, enlistment as RA with Exchange and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors."

We value your trust and are committed to addressing any concerns or complaints promptly and transparently. Clients may reach out through:

• Email: manikanth.sebi@gmail.com for any queries or grievances
• Phone: +91 88002 64952 during working hours
• Post: Flat 203, 3rd floor, Deepika Residency Vijaypuri Colony, South Lalaguda, Tarnaka, Secunderabad, Hyderabad, Telangana, 500017

We aim to provide resolution within 21 working days from the date of receiving your complaint.

Escalation Matrix & Contact Information

Designations	Customer Care, Head of Customer Care, Compliance Officer, CEO, and Principal Officer
Contact Person	Manikanth Devarakonda
Office Address	Flat 203, 3rd floor, Deepika Residency, Vijaypuri Colony, South Lalaguda, Tarnaka, Secunderabad, Hyderabad, Telangana, 500017
Contact No.	+91 88002 64952
Email ID	manikanth.sebi@gmail.com
Working Hours	Monday to Friday, 10:00 AM – 6:00 PM

Still Not Satisfied?

1. Raise your concern through SEBI's SCORES Portal: scores.sebi.gov.in
2. Still dissatisfied? Proceed to Online Dispute Resolution (ODR): smartodr.in

Internal Policy & Control Procedures to effectively address conflict of interest in line with Chapter III of SEBI (Research Analysts) Regulations, 2014, and disclosure requirements.

1. Preamble

Per Regulation 15, Chapter III of SEBI (Research Analysts) Regulations, 2014, the Research Analyst shall have written internal policies and control procedures governing dealing and trading. Manikanth Devarakonda ("Research Analyst") is a SEBI Registered Research Analyst Entity and has prepared this policy accordingly.

2. Objective

• Establish proper internal control and procedures governing dealing and trading by any research analyst.
• Address actual or potential conflicts of interest arising from dealing or trading of securities of the subject company, promoting objective and reliable research.
• Prevent the use of research reports or analysis to manipulate the securities market.
• Implement mechanisms ensuring independence of research activities from other business activities.
• Ensure compliance with SEBI rules and regulations.

3. Scope / Applicability

Applies to the Research Analyst, Manikanth Devarakonda, and all employees engaged in the Research Department as a research analyst — i.e., any person primarily responsible for preparing or publishing research report content, providing a research report, making buy/sell/hold recommendations, giving price targets, or offering opinions on public offers, whether or not the person holds the job title of "Research Analyst."

4. Key Definitions

Research Analyst means a person primarily responsible for preparation/publication of research report content, providing research reports, making buy/sell/hold recommendations, giving price targets, or offering opinions concerning public offers of listed or to-be-listed securities.

Research Report means any written or electronic communication including research analysis, research recommendation, or an opinion concerning securities or public offers that provides a basis for an investment decision — excluding general market commentary, broad-based index discussions, economic/political commentary, periodic fund/AIF/PMS/IA reports, internal communications not shared with clients, offer documents/prospectuses, statistical summaries, and sector-level technical demand-supply analysis.

Significant News or Event means news expected to materially impact the subject company's earnings, operations, or financial condition, other than unpublished price sensitive information.

Subject Company means the company whose securities are the subject of a research report or public appearance.

Third Party Research Report means a research report produced by a person or entity other than the Research Analyst.

5. Management of Conflict of Interest and Disclosure Requirements

5.1 Internal Policies: The Research Analyst maintains an arms-length relationship between research activity and other activities via a "Chinese Wall" policy separating research from other business activities.

5.2 Limitations on Trading: Personal trading by the research analyst is monitored and subject to formal approval where necessary. The Research Analyst shall not deal or trade in securities recommended or followed within 30 days before and 5 days after publication of a research report on the subject company, nor trade contrary to an outstanding recommendation, nor purchase securities of an issuer before its IPO if in the same line of business as companies followed. Exceptions require prior written approval from the Compliance Officer for significant news/events or unanticipated personal financial circumstances.

5.3 Compensation: Research analyst compensation is not tied to specific brokerage transactions and is reviewed and approved annually.

5.4 Limitations on Publication / Public Appearance: The Research Analyst shall not publish research or make public appearances regarding a subject company during prescribed cooling-off periods related to IPO/FPO underwriting or management roles, absent prior written Compliance Officer approval. All research reports must be based on adequate documentary evidence, and no promise of favourable review may be made in exchange for business or compensation.

5.5 Disclosures in Research Report: Reports must disclose business activity, disciplinary history, terms and conditions of research services, details of associates, and ownership/material conflict of interest details, including financial interest, 1%+ beneficial ownership, any compensation received from the subject company in the past 12 months, and any prior investment banking/brokerage relationship with the subject company.

5.6 Contents of Research Report: Facts must be based on reliable information with consistently defined terms; rating systems must clearly define ratings, time horizons and benchmarks; reports with a rating/price target for at least one year must include a graph of daily closing price for the assigned period or three years, whichever is shorter.

5.7 Recommendations in Public Media: Any public appearance or recommendation via public media requires disclosure of registration status and financial interest in the subject company at the time of the recommendation.

5.8 Distribution of Research Reports: Reports shall not be made selectively available to internal trading personnel or particular clients in advance of others entitled to receive them. Third-party research reports distributed must be reviewed for false/misleading information and any material conflict of interest of the third-party provider disclosed.

5.9 Maintenance of Records & Audit: Research reports, recommendations, rationale, and records of public appearances are maintained for a minimum of 5 years. An annual audit is conducted by a member of ICAI or ICSI.

5.10 Compliance Officer: Responsible for monitoring compliance with the Act, regulations, and SEBI circulars.

5.11 General Responsibility: The Research Analyst maintains NISM certification as specified by SEBI and abides by the Code of Conduct — honesty and good faith, diligence, conflict of interest management, no insider trading or front-running, confidentiality until public disclosure, professional standards, and regulatory compliance.

Place: Hyderabad

Manikanth Devarakonda — Anti-Money Laundering Policy

Overview

The Prevention of Money Laundering Act, 2002 ("PMLA") came into force on July 1, 2005. This KYC/AML Policy has been prepared in accordance with the PMLA. Every intermediary registered under Section 12 of the SEBI Act shall adhere to client account opening procedures and maintain transaction records as prescribed by the PMLA, covering cash transactions above ₹10 lakh, connected transaction series exceeding ₹10 lakh monthly in aggregate, and all suspicious transactions regardless of value.

Objective

• Prevent misuse of the organisation for money laundering activities.
• Understand customers and their financial dealings to manage risk prudently.
• Verify identity, suitability, and risks of maintaining a business relationship with clients.
• Adopt AML and Combating of Financing of Terrorism (CFT) standards.
• Conduct proper Customer Due Diligence (CDD) before registering clients.
• Monitor and report suspicious transactions and maintain required records.

Principal Officer

Name: Mr. Manikanth Devarakonda  |  Designation: Research Analyst  |  Contact: +91 88002 64952  |  Email: manikanth.sebi@gmail.com. The Principal Officer is responsible for compliance with PMLA and AML Guidelines, monitoring implementation of AML/CFT policy, reporting transactions, and periodic reporting to top management.

Know Your Customer (KYC) Policy

KYC is mandatory for all clients regardless of the amount invested. KYC registration is a one-time exercise; once completed through any SEBI-registered intermediary, it need not be repeated. Manikanth Devarakonda reserves the right to suspend or discontinue services where a client fails to provide mandatory KYC information (PAN, Aadhaar, Passport, etc.).

Client Due Diligence (CDD)

CDD measures include obtaining sufficient beneficial ownership information, verifying client identity via reliable independent sources, understanding ownership/control structures, declining clients with known criminal backgrounds, conducting ongoing due diligence and scrutiny of transactions, and periodically updating client and beneficial owner information. Reliance on a regulated third party for identity verification is permitted where that party maintains equivalent CDD and record-keeping standards under PMLA.

Client's Acceptance Policy

No account shall be opened in a fictitious or anonymous name. Risk perception factors (location, business activity, turnover, payment manner) classify clients into low, medium, or high risk, with clients of special category requiring enhanced due diligence and regular KYC updates.

Risk-Based Approach & Risk Assessment

An enhanced due diligence process applies to higher-risk clients and a simplified process to lower-risk clients. Risk assessment considers client background, geography, transaction nature/volume, payment methods, and applicable UN Security Council sanctions lists (un.org/securitycouncil), and is documented and updated regularly.

Client Identification Procedure

Risk management systems determine whether a client or beneficial owner is a Politically Exposed Person (PEP); senior management approval is required to establish or continue relationships with PEPs. Reasonable measures verify sources of funds and wealth. Clients are identified using reliable documents; original documents are seen prior to accepting copies; failure to provide satisfactory identity evidence is reported to higher authority.

Record Keeping and Retention of Records

All transaction records are maintained for a minimum of five years from the date of transaction, and client identification records for five years after the business relationship ends or the account is closed, whichever is later. Records are made available to competent authorities upon request and maintained in hard or soft format for easy retrieval.

Monitoring of Transactions

An internal threshold limit of ₹25 lakh per client account class is specified for special attention to unusual or complex transactions without apparent economic purpose. Suspicious transaction indicators include difficulty verifying client identity, unclear source of funds, clients based in high-risk jurisdictions, sudden unexplained increases in business activity, and unusual overseas fund transfers. Any suspicious transaction is notified to the Principal Officer, with continuity of normal client dealing maintained without alerting the client to any suspicion or report ("no tipping off").

Reporting to Financial Intelligence Unit-India (FIU-IND)

Cash Transaction Reports (CTR) and Non-Profit Organisation Transaction Reports (NTR) are submitted monthly by the 15th of the succeeding month; Suspicious Transaction Reports (STR) are submitted within 7 days of concluding a transaction is suspicious, with no undue delay and utmost confidentiality maintained throughout. Reporting is made to FIU-IND (fiuindia.gov.in).

Employee Hiring & Training

Screening procedures verify identity, references, and background before hiring for key positions. An ongoing KYC/AML training programme ensures staff at all levels remain sensitive to the risk of system misuse.

Investor Education

Given the sensitivity of collecting personal financial information for AML/CFT purposes, clients are educated on the objectives of the AML/CFT programme through circulars, literature, and periodic Investor Awareness Programs.