Regulatory Disclosures

Code of Conduct of Investment advisors

In accordance with the third schedule of IA regulations u/r 15(9) of the IA regulations which cover the CODE OF CONDUCT for Investment adviser:

1. Honesty and Fairness : I / We shall act honestly, fairly and in the best interest of my /our clients and in integrity of the market.

2. Diligence : I / We shall act with due skill, care and diligence in the best interests of my / our clients and shall ensure that my / our advice is offered after thorough analysis and taking into account available alternatives.

3. Capabilities: I / We shall have and employ effectively appropriate resources and procedures which re needed for the efficient performance of my / our business activities.

4. Information about clients: I / We shall seek from my / our clients, information about their financial situation, investment experience and investment objectives relevant to the services to be provided and maintain confidentiality of such information.

5. Information to its clients: I / We shall make adequate disclosures of relevant material information while dealing with my / our clients.

6. Fair and Reasonable charges: I / We advising my / our client may charge fees, subject to any ceiling as may be specified by the Board. I / We shall ensure that fees charged to my / our clients is fair and reasonable.

7. Conflicts of interest: I / We shall try to avoid conflicts of interest as far as possible and when cannot be avoided, I / We shall ensure that appropriate disclosures are made to my / our clients and that the clients are fairly treated.

8. Compliance: I / We, the investment adviser including its partners, principal officer and persons associated with investment advice, as the case may be, shall comply with all regulatory requirements applicable to the conduct of my / our business activities so as to promote the best interests of clients and the integrity of the market.

9. Responsibility of senior management: In case of we being the body corporate, which is registered as investment adviser, our senior management shall bear primary responsibility for ensuring the maintenance of appropriate standards conduct and adherence to proper procedures by us.

Investor Charter - SEBI Registered Investment adviser

A. Vision Statement : Invest with knowledge and safety

Mission Statement: 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 Investment Adviser with respect to the investors.

To enter into an agreement with the client providing all details including fee details, aspect of Conflict of interest disclosure and maintaining confidentiality of information.
To do a proper and unbiased risk – profiling and suitability assessment of the client.
To obtain registration with Know Your Client Registration Agency (KRA) and Central Know Your Customer Registry (CKYC).
To conduct audit annually.
To disclose the status of complaints in its website.
To disclose the name, proprietor name, type of registration, registration number, validity, complete address with telephone numbers and associated SEBI regional/local Office details in its website.
To employ only qualified and certified employees.
To deal with clients only from official number
To maintain records of interactions, with all clients including prospective clients (prior to onboarding), where any conversation related to advice has taken place.

C. Details of services provided to investors (No Indicative Timelines)

Onboarding of Clients

o Sharing of agreement copy

o Completing KYC of clients

Disclosure to Clients

o To provide full disclosure about its business, affiliations, compensation in the agreement.

o To not access client’s accounts or holdings for offering advice.

o To disclose the risk profile to the client.

To provide investment advice to the client based on the risk-profiling of the clients and suitability of the client.

D. Details of grievance redressal mechanism and how to access it.

In case of any grievance / complaint, an investor should approach the concerned Investment Adviser and shall ensure that the grievance is resolved within 30 days.

If the investor’s complaint is not redressed satisfactorily, one may lodge a complaint with SEBI on SEBI’s 'SCORES' portal which is a centralized web based complaints redressal system. SEBI takes up the complaints registered via SCORES with the concerned intermediary for timely redressal. SCORES facilitates tracking the status of the complaint.

With regard to physical complaints, investors may send their complaints 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. Expectations from Investors (Responsibilities of investors)

Do's:

Always deal with SEBI registered Investment Advisers.
Ensure that the Investment Adviser has a valid registraDon cerDficate.
Check for SEBI registraDon number. Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link: https://www.sebi.gov.in/sebiweb/other/OtherAction.do?doRecognisedFpi=yes&intmId=13
Pay only advisory fees to your Investment Adviser. Make payments of advisory fees through banking channels only and maintain duly signed receipts mentioning the details of your payments.
Always ask for your risk profiling before accepDng investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
Ask all relevant quesDons and clear your doubts with your Investment Adviser before acDng on advice.
Assess the risk–return profile of the investment as well as the liquidity and safety aspects before making investments.
Insist on gegng the terms and condiDons in wriDng duly signed and stamped. Read these terms and conditions carefully particularly regarding advisory fees, advisory plans, category of recommendations etc. before dealing with any Investment Adviser.
Be vigilant in your transacDons.
Approach the appropriate authoriDes for redressal of your doubts / grievances.
Inform SEBI about Investment Advisers oﬀering assured or guaranteed returns.

Don'ts:

Don’t fall for stock tips oﬀered under the pretext of investment advice.
Do not provide funds for investment to the Investment Adviser.
Don’t fall for the promise of indicative or exorbitant or assured returns by the Investment Advisers.
Don’t let greed overcome rational investment decisions.
Don’t fall prey to luring advertisements or market rumors.
Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or
its representatives.
Don’t take decisions just because of repeated messages and calls by Investment Advisers.
Do not fall prey to limited period discount or other incenDve, gihs, etc. oﬀered by Investment advisers.
Don’t rush into making investments that do not match your risk taking appeDte and investment goals.
Do not share login credenDal and password of your trading and demat accounts with the Investment Adviser.