The particulars given in this Disclosure Document have been prepared in accordance with SEBI (Investment Advisers) Regulations, 2013

The purpose of the Document is to provide essential information about the Investment Advisory Services in a manner to assist and enable the perspective client/client in making an informed decision for engaging Investment Advisor before investing.

For the purpose of this Disclosure Document, Investment Adviser is Bestway Smart Financial Private Limited) (“Investment Advisor”)

A. Descriptions about “Investment Advisor”

• • History, Present business and Background
  Investment Advisor is registered with SEBI as Investment Advisor with Registration No. INA000017392. The firm got its registration on Nov 25, 2022 and is engaged in advisory services.
• • Terms and conditions of Advisory Services
  Terms and conditions of advisory services are detailed in the client agreement. Please refer to the same for details.
• • Disciplinary history
  i. No penalties / directions have been issued by SEBI under the SEBI Act or Regulations made there under against the Investment Adviser relating to Investment Advisory services.
  ii. There are no pending material litigations or legal proceedings, findings of inspections or investigations for which action has been taken or initiated by any regulatory authority against the Investment Adviser or its Directors, or employees.
• • Affiliations with other intermediaries
  Investment Advisor has no affiliation with any other SEBI registered intermediaries.

B. Disclosures with respect to Investment Advisor’s own holding position in financial products / securities:

• Investment Advisor may hold position in the financial products/ securities advised in its personal portfolio. Details of the same may be referred through the disclosures made at the time of advice.

C. Disclosures with respect to 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.

• There are no 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. Such conflict of interest shall be disclosed to the client as and when they arise.

D. Disclosure of all material facts relating to the key features of the products or securities, particularly, performance track record, warnings, disclaimers etc.

• Clients are requested to go through the detailed key features, performance track record of the product, or security including warnings, disclaimers etc before investing as and when provided by the Investment Advisor. Such product materials may also be available to www.sebi.gov.in or www.nseindia.com or respective issuers website.

E. Drawing client’s attention to warnings, disclaimers in documents, advertising materials relating to investment products.

• Investment Advisor draws the client’s attention to the warnings, disclaimers in documents, advertising materials relating to an investment product/s which are being recommended to the client/s. A brief regarding the risk associated with the investment products are available in client agreement, same may be referred before investing in advised product or securities.