Research Disclosures

1. Research Analyst Identity

Research published on TruePrice (trueprice.pro) is prepared and owned by Devesh Varshney, who is registered as a Research Analyst with the Securities and Exchange Board of India (“SEBI”) under the SEBI (Research Analysts) Regulations, 2014. SEBI Registration Number: Pending issuance. Place of business: Bengaluru, Karnataka, India.

These Disclosures are published in compliance with Regulation 19 read with Schedule III of the SEBI (Research Analysts) Regulations, 2014, and with subsequent SEBI master circulars and guidelines applicable to Research Analysts (including the Advertisement Code dated 5 April 2023 and the circulars on association of regulated entities with unregulated persons dated 25 October 2024 and 29 January 2025).

Standard regulatory disclaimer: Registration granted by SEBI, membership of any administrative body of the Research Analyst Administration and Supervisory Body (RAASB), and certification from the National Institute of Securities Markets (NISM) in no way guarantee performance of the Research Analyst or provide any assurance of returns to investors.

2. Nature Of Services

TruePrice provides equity-valuation research for securities listed on the National Stock Exchange of India (NSE) and BSE Limited. Research outputs include intrinsic-value estimates, peer-comparison analyses, Sum-of-the-Parts breakdowns, reverse-engineered implied-growth models, and portfolio fair-value summaries.

Research outputs represent the independent professional opinion of the Research Analyst as of the date of publication, based solely on information that is publicly available. Research is prepared for informational and educational purposes only. Nothing on the Platform should be construed as personalised investment advice or as a recommendation tailored to the financial circumstances of any individual User.

3. Methodology

Valuation reports are prepared using one or more of the following rule-based, deterministic methodologies:

• Discounted Cash Flow (DCF): projects future free cash flows over an explicit forecast horizon and a terminal-value tail, discounted to present value using a risk-adjusted Weighted Average Cost of Capital (WACC).
• Reverse DCF: solves for the implied growth or return-on-capital that the current market price embeds, given an assumed cost of capital.
• Relative Valuation: benchmarks a company against a curated set of quality-adjusted peers using sector-appropriate earnings, cash-flow, or book-value multiples.
• Sum-of-the-Parts (SOTP): values distinct business segments independently and aggregates them into a consolidated enterprise value.
• Excess-Returns / Residual-Income models for banking and insurance issuers where DCF is not appropriate.

All material assumptions — revenue growth rates, operating margins, capital intensity, terminal growth, equity risk premium, beta, and discount rate — are disclosed within each Research Report. The Research Analyst retains sole discretion over the selection of methodology and the determination of underlying assumptions.

4. Sources Of Information

Research is prepared solely on the basis of information that is publicly available as of the date of preparation. Primary sources include:

• Audited annual reports filed with the Ministry of Corporate Affairs;
• Quarterly financial results and disclosures filed with NSE and BSE;
• XBRL-tagged financial data published via the MCA portal;
• Earnings call transcripts and investor-day presentations published by the issuer;
• Exchange filings including shareholding-pattern disclosures and corporate-action notices;
• Credit-rating reports and sectoral research published by SEBI-registered credit-rating agencies;
• Public market data from third-party sources including Yahoo Finance, the Federal Reserve Economic Data (FRED) service for the India 10-year sovereign yield, and publicly published Damodaran data sets for equity risk premium and sector beta benchmarks.

We do not engage in any communication with company management, brokers, or insiders for the purpose of obtaining material non-public information. Any information that may constitute Unpublished Price-Sensitive Information (UPSI) under the SEBI (Prohibition of Insider Trading) Regulations, 2015 is expressly excluded from research preparation.

5. AI-Assisted Data Extraction

We use commercial large-language-model APIs (Anthropic Claude and OpenAI) strictly as tooling to extract and structure data from the publicly available documents listed in Section 4 — for example, parsing financial statements out of annual reports, extracting guidance and segment commentary from earnings transcripts, and (in Portfolio Sync) reading holdings tables from user-uploaded screenshots.

• The valuation engines themselves are rule-based and deterministic. They are not generative; they produce a numeric output from defined inputs and assumptions.
• We use AI providers under commercial / enterprise terms which contractually prohibit them from using our inputs or outputs to train their models.
• AI-extracted figures are validated against deterministic rules and cross-references (filing-level totals, prior-period continuity, accounting identities) before being used in valuation models.
• Where the Platform displays content that is substantially generated using AI tooling, we identify it as such, in line with the IT (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules, 2026.

6. Independence & Conflicts Of Interest

Devesh Varshney certifies that, as of the date of each Research Report published on TruePrice:

• He does not hold any financial interest, directly or indirectly, in the securities of any company covered in the report at the time of publication, except where such interest is separately and explicitly disclosed within the report itself;
• He has not received and is not in receipt of any compensation, gift, or benefit from the company covered or from any person with a financial interest in the research outcome;
• No part of his compensation is or was linked to the specific recommendations or views expressed in any Research Report;
• TruePrice does not engage in investment banking, corporate advisory, distribution, broking, market-making, portfolio management, or stock-broking services for covered companies;
• The research is prepared free from the influence or direction of any third party, broker, issuer, or platform partner.

In the event a conflict of interest arises, it will be promptly disclosed within the relevant Research Report. The Research Analyst and his immediate relatives may from time to time hold positions in covered securities for personal investment, in compliance with the SEBI Code of Conduct for Research Analysts (Schedule III of the RA Regulations, 2014).

7. Risk Factors & Limitations

Equity valuation is inherently uncertain and involves significant assumptions about future events that may not materialise. Key risks include but are not limited to:

• Market risk: stock prices are subject to market fluctuations, macroeconomic conditions, and geopolitical events that no model can fully anticipate.
• Model risk: valuation models are simplifications of reality and small changes to assumptions can produce materially different outputs.
• Data risk: errors, restatements, or delays in the underlying public filings flow through into valuations.
• Liquidity risk: some securities may be difficult to buy or sell at, near, or close to fair value.
• Regulatory risk: changes in government policy, tax law, or regulation may impact the issuer or the security.
• Forward-looking statements: valuation outputs rely on projected revenue, margins, and cash flows. Actual results may differ materially from projected figures.

8. No Assured Returns

A stock trading below its calculated intrinsic value does not guarantee future price appreciation. A stock trading above its calculated intrinsic value does not guarantee future price decline. Valuation is one of many factors that influence investment outcomes. TruePrice does not promise, imply, or guarantee any specific return, including any minimum return, target return, or percentage accuracy.

9. Past Performance & Update Policy

Past performance of any security, sector, or valuation methodology is not a guarantee or indicator of future results. Research is a point-in-time opinion based on information available at the date of publication and may not reflect subsequent developments. We do not undertake to update Research Reports after publication except at our sole discretion.

10. Portfolio Sync Disclosure

The Portfolio Sync feature works exclusively from screenshots that you choose to upload. We do not connect to any broker, depository, or banking system. We do not request, receive, or store broker login credentials, demat account numbers, bank account numbers, or PAN. We cannot place orders, modify positions, or execute trades on your behalf.

11. Reporting Errors

If you identify a data inaccuracy or factual error in any Research Report, please write to support@trueprice.pro. We investigate every report and correct confirmed errors promptly, with a publicly visible correction notice on materially revised Research Reports.

12. Grievances

For complaints or grievances, please refer to our Grievance Redressal Policy and our Regulatory page. You may escalate unresolved grievances to SEBI via the SCORES portal at scores.sebi.gov.in and the SEBI Online Dispute Resolution platform at smartodr.in.