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- - - 1i .

Cumulative Capital Private Limited


Date: February 28, 2024

To,
Securities Exchange Board of India
Market Intermediaries Regulations and Supervisio
n Department Division 5
SEBI Bhavan,
Plot No. C4-A, 'G' Block,
Bandra Kurla Complex, Bandra East,
Mumbai, Maharashtra-400051

Dear Sir,

We hereby undertake the following ;

1. We hereby declare and undertake that no enqu


iry/ adjudication/ prosecution or any other
action (suspension, debarment etc.)/ adverse comm
ents (warning/ caution) is/ was, at any
point of time, initiated/ pending against the
applicant company/ group entities/
associate(s) and/ or any of the Directors/ key
personnel / promoters of the applicant
company, from SEBl or any other regulatory body
, in India or abroad.
2. We hereby declare and undertake that
no compliant/ litigation including investor
grievances is pending again st the applicant comp
any and/ or any of the directors/ key
personnel of the applicant company as on date.

3. We hereby declare and undertake that no


person directly or indirectly connected with
the applicant (as associate, subsidiary, inter-con
nected or group company of the
applicant being a body corporate) has been refus
ed registration by· the SEBI under
SEBI Act, 1992 .

4. We hereby declare and undertake that no fees


are due from the appl icant/ associates to
SEBI.

5. We hereby declare and undertake that


the applicant company has adequate
infrastructure like office space, equipment, manp
ower and investor grievance redressal
system in place to effectively discharge its activity
as Merchant Bankers/ Bankers to an
Issue.

6. We hereby declare and undertake that the appli


cant company is not invo lved in any
activities other than that in the securities market.

7. We hereby declare and undertake that none


of the directors/ principal officer is/ are
involved in any litigation connected with the secu
rities market which has an adverse
bearing on the business of the company.
8. We hereby declare and undertake that no direc
tor(s) or principal officer(s) has at any
time been convicted for any offence involving mora
l turpitude or has been found guilty
of any economic offence.

(l) +919 8196 62 664


C-321, 3rd Floor, 215 Atrium Co Op Soc, Andh
CIN: U64910MH202 3PTC414974 eri Kurla
Road, Chakala MIDC, Andheri East Mum bai-
400 093
Cumulative Capital Private Limited

9. We hereby declare and undertake that none of the directors of the applicant company
is/ was, at any point of time, broker/ sub broker of any recognized stock exchange.

10. We hereby declare and undertake that the applicant company is not registered with RBI
in the capacity ofNBFC/ Primary Dealer/ Satellite Dealer.

11 . We hereby declare and undertake that there have been no instances of violation or non-
adherence to any securities market related regulations by the applicant or its
associate(s)/ group companies in India or abroad and any action has been taken by a
regulatory agency in this regard.

For and on behalfof For and on behalfof


Cumulative Capital Private Limited Cumulative Capital Private Limited

Swapnilsagar Vithalani Priyesh A. Karia


Director Director
DIN : 07315009 DIN :06846236

For and on behalf of


Cumulative Capital Private Limited

Bhavna Shah
Key Managerial Person

For and on behalf of


Cumulative Capital Private Limited

Bhavna Shah
Compliance Officer

CJ) +919819662 664 C-321, 3rd Floor, 215 Atrium Co Op Soc, Andheri Kurla
CIN: U64910MH2023PTC414974 Road, Chakala MIDC, Andherl E11st Mumbai - 400 093

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