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AZAD PARIVAAR™

CLARITY · DISCIPLINE · FINANCIAL FREEDOM

CODE OF CONDUCT

Effective Date: 21 MAY 2026

Last Updated: 21 MAY 2026

1. PREAMBLE

Prateek Singh, operating under the trade name AZAD PARIVAAR™ ("we," "us," "the Adviser"), is a SEBI Registered Investment Adviser. Pursuant to Regulation 15(9) of the SEBI (Investment Advisers) Regulations, 2013, we adopt and abide at all times by the Code of Conduct prescribed in the Third Schedule to those Regulations.

This page sets out each clause of the statutory Code together with how we operationalize it in practice.

2. THE CODE IN PRACTICE

(i) HONESTY AND FAIRNESS

We act honestly, fairly, and in the best interests of our clients and in the integrity of the market.

In practice: we receive no commission, referral fee, revenue share, or indirect benefit from any product manufacturer or third party. We do not solicit business through assured returns, performance guarantees, or superlatives.

(ii) DILIGENCE

We act with due skill, care, and diligence in the best interests of our clients, offering advice only after thorough analysis and consideration of available alternatives.

In practice: every advice instance is preceded by a documented suitability assessment and followed by a signed, dated rationale record per Reg 19(1)(f).

(iii) CAPABILITIES

We maintain appropriate resources and procedures for the efficient performance of our business.

In practice: current NISM certifications held and renewed before expiry; documented Standard Operating Procedures for risk profiling, suitability, advice rationale, record-keeping, grievance handling, and incident response; quarterly review of critical SaaS platforms for security and access controls.

(iv) INFORMATION ABOUT CLIENTS

We seek information about our clients' financial situation, investment experience, and objectives relevant to the services to be provided, and maintain confidentiality of that information.

In practice: data handling follows the Privacy Policy and the Digital Personal Data Protection Act, 2023. Client information is never shared with product manufacturers, distributors, or any party that may use it for sales or commercial purposes.

(v) INFORMATION TO CLIENTS

We make adequate disclosures of relevant material information in our dealings with clients.

In practice: registration status, regulatory disclosures, conflicts of interest, fee structure, and standard risk warnings are disclosed at engagement and refreshed periodically. The Letter of Engagement and the SEBI-prescribed Most Important Terms and Conditions (MITC) are executed before any fee is collected.

(vi) FAIR AND REASONABLE CHARGES

Fees are charged within the SEBI-specified ceiling and ensured to be fair and reasonable.

In practice: fees are documented in the Letter of Engagement before collection; cash fees are not accepted under any circumstance; invoices and receipts are issued for every payment.

(vii) CONFLICTS OF INTEREST

We avoid conflicts of interest as far as possible; where they cannot be avoided, we disclose them and ensure clients are fairly treated.

In practice: arms-length separation from any non-advisory activity (Reg 15(3)); recommendations restricted to direct (non-commission) plans wherever available; the 15-day own-account rule (Reg 15(7)) observed at all times; positions in any product that is the subject matter of advice disclosed to the client at or before the time of advice.

(viii) COMPLIANCE

We comply with all regulatory requirements applicable to the conduct of our business, in the interest of clients and market integrity.

In practice: Annual Compliance Audit by an independent external professional (Reg 19A); half-yearly Periodic Reports filed with BSE within prescribed timelines; BSE prior approval obtained for every advertisement requiring it under the Code of Advertisement.

(ix) RESPONSIBILITY OF SENIOR MANAGEMENT

This clause applies to Non-Individual Investment Advisers. We currently operate as an Individual IA; the clause will be operationalized upon transition.

3. ADDITIONAL COMMITMENTS

KYC AND CLIENT-LEVEL SEGREGATION

Client KYC follows SEBI-specified procedures per Reg 15(8). A separate register is maintained per client recording PAN, date of advice, nature of advice, securities or products covered, and fees received.

USE OF ARTIFICIAL INTELLIGENCE

AI tools are used only as productivity and research aids, never as substitutes for the judgment of the Adviser, who remains personally accountable for every recommendation per Reg 15(14). Full details: see the AI Use Disclosure.

INVESTOR CHARTER

We comply with the Investor Charter for Investment Advisers prescribed by SEBI per Reg 15(15). The Charter is published on the SEBI Disclosures page.

4. HOW WE MONITOR ADHERENCE

- Continuous internal compliance review

- Quarterly checkpoints on record integrity, advice rationale, suitability files, and conflicts disclosures

- Annual Compliance Audit by an independent external professional

- Half-yearly Periodic Reports to BSE

- Monthly Investor Complaints register update on the website, regardless of complaint volume

- Independent inspections by SEBI or BSE as initiated

Adherence evidence is preserved per the record-retention requirements of Reg 19(2).

5. GRIEVANCE

Any concern regarding adherence to this Code may be raised through the channels on our Grievance page. Grievances are acknowledged within one working day and resolved within twenty-one calendar days. Unresolved matters escalate to SEBI through SCORES and Smart ODR.

6. REVIEW

This Code of Conduct is reviewed at least annually, and sooner upon any material amendment to the IA Regulations, the Third Schedule, or any relevant SEBI or BSE circular. The latest version is always available on this page.

 

ACCESSIBILITY STATEMENT

AZAD PARIVAAR™ (trade name of Prateek Singh, SEBI Registered Investment Adviser, Reg. No. INA000020077, BSE Enlistment No. 2254) is committed to making this website and its digital content accessible to all users, including persons with disabilities.

Effective Date: 21 MAY 2026

Last Updated: 21 MAY 2026

1. PREAMBLE

Prateek Singh, operating under the trade name AZAD PARIVAAR™ ("we," "us," "the Adviser"), is a SEBI Registered Investment Adviser. Pursuant to Regulation 15(9) of the SEBI (Investment Advisers) Regulations, 2013, we adopt and abide at all times by the Code of Conduct prescribed in the Third Schedule to those Regulations.

This page sets out each clause of the statutory Code together with how we operationalize it in practice.

2. THE CODE IN PRACTICE

(i) HONESTY AND FAIRNESS

We act honestly, fairly, and in the best interests of our clients and in the integrity of the market.

In practice: we receive no commission, referral fee, revenue share, or indirect benefit from any product manufacturer or third party. We do not solicit business through assured returns, performance guarantees, or superlatives.

(ii) DILIGENCE

We act with due skill, care, and diligence in the best interests of our clients, offering advice only after thorough analysis and consideration of available alternatives.

In practice: every advice instance is preceded by a documented suitability assessment and followed by a signed, dated rationale record per Reg 19(1)(f).

(iii) CAPABILITIES

We maintain appropriate resources and procedures for the efficient performance of our business.

In practice: current NISM certifications held and renewed before expiry; documented Standard Operating Procedures for risk profiling, suitability, advice rationale, record-keeping, grievance handling, and incident response; quarterly review of critical SaaS platforms for security and access controls.

(iv) INFORMATION ABOUT CLIENTS

We seek information about our clients' financial situation, investment experience, and objectives relevant to the services to be provided, and maintain confidentiality of that information.

In practice: data handling follows the Privacy Policy and the Digital Personal Data Protection Act, 2023. Client information is never shared with product manufacturers, distributors, or any party that may use it for sales or commercial purposes.

(v) INFORMATION TO CLIENTS

We make adequate disclosures of relevant material information in our dealings with clients.

In practice: registration status, regulatory disclosures, conflicts of interest, fee structure, and standard risk warnings are disclosed at engagement and refreshed periodically. The Letter of Engagement and the SEBI-prescribed Most Important Terms and Conditions (MITC) are executed before any fee is collected.

(vi) FAIR AND REASONABLE CHARGES

Fees are charged within the SEBI-specified ceiling and ensured to be fair and reasonable.

In practice: fees are documented in the Letter of Engagement before collection; cash fees are not accepted under any circumstance; invoices and receipts are issued for every payment.

(vii) CONFLICTS OF INTEREST

We avoid conflicts of interest as far as possible; where they cannot be avoided, we disclose them and ensure clients are fairly treated.

In practice: arms-length separation from any non-advisory activity (Reg 15(3)); recommendations restricted to direct (non-commission) plans wherever available; the 15-day own-account rule (Reg 15(7)) observed at all times; positions in any product that is the subject matter of advice disclosed to the client at or before the time of advice.

(viii) COMPLIANCE

We comply with all regulatory requirements applicable to the conduct of our business, in the interest of clients and market integrity.

In practice: Annual Compliance Audit by an independent external professional (Reg 19A); half-yearly Periodic Reports filed with BSE within prescribed timelines; BSE prior approval obtained for every advertisement requiring it under the Code of Advertisement.

(ix) RESPONSIBILITY OF SENIOR MANAGEMENT

This clause applies to Non-Individual Investment Advisers. We currently operate as an Individual IA; the clause will be operationalized upon transition.

3. ADDITIONAL COMMITMENTS

KYC AND CLIENT-LEVEL SEGREGATION

Client KYC follows SEBI-specified procedures per Reg 15(8). A separate register is maintained per client recording PAN, date of advice, nature of advice, securities or products covered, and fees received.

USE OF ARTIFICIAL INTELLIGENCE

AI tools are used only as productivity and research aids, never as substitutes for the judgment of the Adviser, who remains personally accountable for every recommendation per Reg 15(14). Full details: see the AI Use Disclosure.

INVESTOR CHARTER

We comply with the Investor Charter for Investment Advisers prescribed by SEBI per Reg 15(15). The Charter is published on the SEBI Disclosures page.

4. HOW WE MONITOR ADHERENCE

- Continuous internal compliance review

- Quarterly checkpoints on record integrity, advice rationale, suitability files, and conflicts disclosures

- Annual Compliance Audit by an independent external professional

- Half-yearly Periodic Reports to BSE

- Monthly Investor Complaints register update on the website, regardless of complaint volume

- Independent inspections by SEBI or BSE as initiated

Adherence evidence is preserved per the record-retention requirements of Reg 19(2).

5. GRIEVANCE

Any concern regarding adherence to this Code may be raised through the channels on our Grievance page. Grievances are acknowledged within one working day and resolved within twenty-one calendar days. Unresolved matters escalate to SEBI through SCORES and Smart ODR.

6. REVIEW

This Code of Conduct is reviewed at least annually, and sooner upon any material amendment to the IA Regulations, the Third Schedule, or any relevant SEBI or BSE circular. The latest version is always available on this page.

CODE OF CONDUCT

Effective Date: 21 MAY 2026

Last Updated: 21 MAY 2026

1. PREAMBLE

Prateek Singh, operating under the trade name AZAD PARIVAAR™ ("we," "us," "the Adviser"), is a SEBI Registered Investment Adviser. Pursuant to Regulation 15(9) of the SEBI (Investment Advisers) Regulations, 2013, we adopt and abide at all times by the Code of Conduct prescribed in the Third Schedule to those Regulations.

This page sets out each clause of the statutory Code together with how we operationalize it in practice.

2. THE CODE IN PRACTICE

(i) HONESTY AND FAIRNESS

We act honestly, fairly, and in the best interests of our clients and in the integrity of the market.

In practice: we receive no commission, referral fee, revenue share, or indirect benefit from any product manufacturer or third party. We do not solicit business through assured returns, performance guarantees, or superlatives.

(ii) DILIGENCE

We act with due skill, care, and diligence in the best interests of our clients, offering advice only after thorough analysis and consideration of available alternatives.

In practice: every advice instance is preceded by a documented suitability assessment and followed by a signed, dated rationale record per Reg 19(1)(f).

(iii) CAPABILITIES

We maintain appropriate resources and procedures for the efficient performance of our business.

In practice: current NISM certifications held and renewed before expiry; documented Standard Operating Procedures for risk profiling, suitability, advice rationale, record-keeping, grievance handling, and incident response; quarterly review of critical SaaS platforms for security and access controls.

(iv) INFORMATION ABOUT CLIENTS

We seek information about our clients' financial situation, investment experience, and objectives relevant to the services to be provided, and maintain confidentiality of that information.

In practice: data handling follows the Privacy Policy and the Digital Personal Data Protection Act, 2023. Client information is never shared with product manufacturers, distributors, or any party that may use it for sales or commercial purposes.

(v) INFORMATION TO CLIENTS

We make adequate disclosures of relevant material information in our dealings with clients.

In practice: registration status, regulatory disclosures, conflicts of interest, fee structure, and standard risk warnings are disclosed at engagement and refreshed periodically. The Letter of Engagement and the SEBI-prescribed Most Important Terms and Conditions (MITC) are executed before any fee is collected.

(vi) FAIR AND REASONABLE CHARGES

Fees are charged within the SEBI-specified ceiling and ensured to be fair and reasonable.

In practice: fees are documented in the Letter of Engagement before collection; cash fees are not accepted under any circumstance; invoices and receipts are issued for every payment.

(vii) CONFLICTS OF INTEREST

We avoid conflicts of interest as far as possible; where they cannot be avoided, we disclose them and ensure clients are fairly treated.

In practice: arms-length separation from any non-advisory activity (Reg 15(3)); recommendations restricted to direct (non-commission) plans wherever available; the 15-day own-account rule (Reg 15(7)) observed at all times; positions in any product that is the subject matter of advice disclosed to the client at or before the time of advice.

(viii) COMPLIANCE

We comply with all regulatory requirements applicable to the conduct of our business, in the interest of clients and market integrity.

In practice: Annual Compliance Audit by an independent external professional (Reg 19A); half-yearly Periodic Reports filed with BSE within prescribed timelines; BSE prior approval obtained for every advertisement requiring it under the Code of Advertisement.

(ix) RESPONSIBILITY OF SENIOR MANAGEMENT

This clause applies to Non-Individual Investment Advisers. We currently operate as an Individual IA; the clause will be operationalized upon transition.

3. ADDITIONAL COMMITMENTS

KYC AND CLIENT-LEVEL SEGREGATION

Client KYC follows SEBI-specified procedures per Reg 15(8). A separate register is maintained per client recording PAN, date of advice, nature of advice, securities or products covered, and fees received.

USE OF ARTIFICIAL INTELLIGENCE

AI tools are used only as productivity and research aids, never as substitutes for the judgment of the Adviser, who remains personally accountable for every recommendation per Reg 15(14). Full details: see the AI Use Disclosure.

INVESTOR CHARTER

We comply with the Investor Charter for Investment Advisers prescribed by SEBI per Reg 15(15). The Charter is published on the SEBI Disclosures page.

4. HOW WE MONITOR ADHERENCE

- Continuous internal compliance review

- Quarterly checkpoints on record integrity, advice rationale, suitability files, and conflicts disclosures

- Annual Compliance Audit by an independent external professional

- Half-yearly Periodic Reports to BSE

- Monthly Investor Complaints register update on the website, regardless of complaint volume

- Independent inspections by SEBI or BSE as initiated

Adherence evidence is preserved per the record-retention requirements of Reg 19(2).

5. GRIEVANCE

Any concern regarding adherence to this Code may be raised through the channels on our Grievance page. Grievances are acknowledged within one working day and resolved within twenty-one calendar days. Unresolved matters escalate to SEBI through SCORES and Smart ODR.

6. REVIEW

This Code of Conduct is reviewed at least annually, and sooner upon any material amendment to the IA Regulations, the Third Schedule, or any relevant SEBI or BSE circular. The latest version is always available on this page.

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