Compliance

Investor Charter for Alternative Investment Funds

A. Vision and Mission Statement

Vision

To develop the Alternative Investment Fund (“AIF”) industry on professional and ethical lines and maintain high standards of governance and transparency.

Mission

  • Maintain high professional and ethical standards within the AIF industry.
  • Comply with all applicable regulations and co-operate with the regulators in all aspects of the AIF activity.
  • Act in a fiduciary capacity towards the investors.

B. Details of business transacted by the organization with respect to the investors:

  • To raise capital from domestic and global investors.
  • To invest in portfolio companies in accordance with investment strategy stated in Fund documents, with an objective to generate positive returns for the stakeholders including investors.
  • To distribute returns to the investors as per the fund documents.

C. Details of services provided to investors:

  1. On-boarding of investors.
    1.1. Sharing of Private Placement Memorandum (PPM).
    1.2. Account opening with the AIF:
    • Completing KYC of investors and registration of KYC with KRAs.
    • Sharing of copies of fund documents with investors.
    • Entering into contribution agreement with investor.
  2. Obtaining investor consent for material changes to fund structure
    2.1. Change in the sponsor or the manager of the AIF.
    2.2. Change in control of the sponsor or the manager of the AIF.
    2.3. Material changes to terms of PPM
    • Term of Fund.
    • Investment Strategy.
    • Increase in fees and charges.
    • 2.4. Winding up of Fund/ Scheme prior to expiry of tenure.
  3. Dissemination of financial information of Fund.
    3.1. Net Asset Value of Fund/ Scheme.
    3.2. Financial information of investee companies.
    3.3. Information on performance of scheme/fund.
  4. Disclosures with respect to material risks associated with the fund and its portfolio investments.
    4.1. Any inquiries/ legal actions by legal or regulatory bodies in any jurisdiction.
    4.2. Any material liability arising during the tenure of the fund.
    4.3. Any breach of a provision of the PPM or any other agreement made with the investor or any other fund documents.
    4.4. Intimation regarding any conflict of interest.
    4.5. Risks associated with the portfolio, such as concentration risk, foreign exchange risk, leverage risk, realization risk, strategy risk, reputation risk, extra-financial risks such as social and corporate governance risks etc. at fund and investee company level.
  5. Intimation of any non-material changes in the operations of the fund.
    5.1. Non-material changes such as
    • Bank account details
    • Address of AIF or its Manager or Sponsor
    • Contact details such as email-id, contact number, etc. of AIF or its Manager or Sponsor
  6. Grievance redressal
    6.1. Redressal of investor complaints received directly from investors and/ or from SEBI / SCORES.

D. Timelines of the activity/services provided to investors:

Sr No.Description of activity/services provided by Alternative Investment Funds (AIFs) to its investorsTimeline for completion of activity
1.Valuation related disclosures:
a.Valuation of investment by Category I and II Alternative Investment Fund At least once every six months. Can be extended to once a year with approval of 75% of its investors by value of investment.
b.Disclosure of NAV of scheme(s) of the Category III Alternative Investment FundClose ended fund – quarterly basis Open ended fund – monthly basis
2.Transparency related disclosures:
a. Disclosure of financial information of investee companies • Category I and II – within 180 days from the year end or earlier as per the fund documents.
• Category III – within 60 days from the end of the quarter end or earlier as per the fund documents.
b.Disclosure of Material risks:
concentration risk, foreign exchange risk at fund level and leverage risk, realization risk, strategy risk, reputation risk at investee company level, extra- financial risks such as social and corporate governance risks etc. at fund and investee company
level
c.Financial, risk management, operational, portfolio, and transactional information regarding fund investments To be disclosed periodically to the investors
d.Any fees ascribed to the Manager or Sponsor; and any fees charged to the Alternative Investment Fund or any investee company
e.Any inquiries/ legal actions by legal or regulatory bodies in any jurisdiction As and when occurred
f.Any material liability arising during the Alternative Investment Fund’s tenure
g.Any breach of a provision of the placement memorandum or agreement made with the investor or any other fund documents
h.Intimation regarding conflict of interest in any transaction As and when they arise or seem likely to arise
i.Any change in terms of Private Placement Memorandum /fund documentsOn consolidated basis within one month of end of each financial year
3.Complaint handling related services:
a.Response to complaint received from investors Within 30 days from the date of receipt of complaint
b.Redressal of investor complaint received from SEBI/ SCORES Within 30 days from the date of receipt of complaint

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

  1. Alternative Investment Funds are required to redress all investor complaints in timely manner.
  2. An Alternative Investment Fund, by itself or through the Manager or Sponsor, are required to lay down procedure for resolution of disputes between the investors and AIF or Manager or Sponsor through arbitration or any such mechanism as mutually decided between the investors and the Alternative Investment Fund.
  3. Investors can also approach SEBI for redressal of their complaints through SEBI SCORES platform. On receipt of complaints, SEBI takes up the matter with the concerned AIF.
  4. 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.

F. Responsibilities of investors

  1. Responsibility to inform and educate yourself
    1.1. Read thoroughly all fund documents including Private Placement Memorandum, Contribution Agreement, sales literature, newsletters and understand the product.
    1.2. Carefully consider all investment risks, fees, and/or other factors detailed in these documents.
    1.3. Ensure and make certain that the proposed investment in the Fund meets your investment objective and is in alignment with your risk appetite.
    1.4. Review your portfolio holdings, account statements and transaction confirmation on regular basis to ensure that you aware of all transactions and securities where you are invested.
  2. Responsibility to timely update your KYC and information with the Intermediary
    2.1 Provide complete and accurate information in your KYC documents, including financial/ income status.
    2.2 Timely updation of KYC information.
  3. Responsibility to abide by the contribution agreement.
    3.1. The investor needs to read carefully and understand the agreement that he/she is entering into with the Alternative Investment Fund and abide by the terms thereof.
    3.2. The investor should be aware that investment terms are not guarantee of future performance or returns of the Fund/ Scheme.
  4. Responsibility to use right financial intermediaries, consultants and advisors.
    4.1. Carefully consider validity and reliability of investment information obtained from all sources, especially unsolicited information obtained over the Internet.
  5. Responsibility to maintain confidentiality of information.
    5.1. Investors shall not disclose any material non-public information that is received by virtue of being investors of the fund, except as may be guided by the terms of the fund documents.

Investor Complaints Data for the Quarter ending Dec 31 2023

Sr. No.Investor Complaints received fromPending as at the end of the last quarterReceivedResolvedTotal Pending at the end of the quarterPending Complaints >3 monthsAverage resolution time in days ^
1Directly from Investors00000
2SEBI (SCORES)00000
3Other Sources (if any)00000
Total00000
^ Average Resolution time is the sum total of time taken to resolve each complaint in days in the current quarter divided by total number of complaints resolved in the current quarter.

Investor Complaints Data for Last Three Financial Years (FY)

S.NoFYCarried forward from previous FYReceivedResolvedPending at the end of FY
12020-21NANANANA
22021-220000
32022-230000
Total0000

A. Details for filling Complaints

• Investors Grievances may be mailed to email id aifgrievance@pluswealth.com
• For any other query/assistance please email us at info@pluswealth.com
• For any other query/assistance please call us at 0120-6294400
• Register on SCORES Portal (SEBI) ( https://scores.gov.in )
• Mandatory details for filing complaints on SCORES:- i. Name, PAN, Address, Mobile Number, E-mail ID.
• Benefits :- i. Effective Communication ii. Speedy redressal of the grievances.

Procedure for filing complaint

Handling of all investor grievances for the AIF activities is centralized function and is being handled by Compliance department at corporate office.

Under the SEBI directive a designated e-mail id has been created namely aifgrievance@pluswealth.com and the same has been displayed on our website https://pluswealthassets.com/ This email id would be monitored by compliance department on daily basis.

All Investor Grievances (hard copy or soft copy) that are received at the branches and offices of the authorized persons (herein after referred as “associates”) should after incorporating their comments / remarks if any, forwarded within 2 working days of the receipt of the complaint to the Compliance Department at corporate office for further action.

All the Investor Grievances received at the aifgrievance@pluswealth.com and those complaints forwarded by the branches and or associates would be verified and scrutinize by the compliance department and it would initiate necessary steps to resolve the complaint within 1 -2 working days of the receipt of the complaint.

Any course of action which involves the concerned department at Head office it would be informed to the concerned head of the department and Business team. Likewise, if the course of action which involves branch and or associate, business team at the corporate office would be informed/updated.

If there is no response from concerned department or the branch and or associate within 3 working days of the complaint, the same would be escalated to Head Compliance for immediate action and if there is no response within 5 working days then the same would be reported to the Designated Partner as in the form of an MIS reporting

All investor grievances should be resolved within time period of 10 days of the receipt of the complaint to the department.

All the branches and associates would maintain an investor grievance register and the register would be subject to audit and inspection by the compliance officer of the LLP.

All the investor grievances would be handled in the following manner by the compliance department.

All the investor grievances (hard copy or softcopy) would be updated in an excel (soft copy) or/and register (hard copy) on the same day of the receipt of the complaint. This register would be monitored by the compliance officer on daily basis.

After verification and scrutiny, the appropriate steps would be initiated to resolve the complaint at the earliest. Therefore, compliance department will ensure that depending upon the type of the complaint, all the information i.e. from the receipt of the complaint till the status of being resolved would be updated in the register. The compliance officer would ensure that it gives its sign-off only after the complaint is resolved.

If not satisfied from the above investor can directly complaint to SEBI via SCORES by as follows steps:

• Register on SCORES Portal (SEBI) ( https://scores.gov.in ).
• Mandatory details for filing complaints on SCORES: Name, PAN, Address, Mobile Number, E-mail ID.
• Benefits: – Effective Communication ii. Speedy redressal of the grievances.

After exhausting all available options for resolution of the grievance, if the client is still not satisfied with the outcome, they can initiate dispute resolution through the ODR Portal ( https://smartodr.in/login ). Further dispute resolution through the ODR Portal can be initiated when the complaint/dispute is not under consideration in terms of the above or SCOREs guidelines as applicable or not pending before any arbitral process, court, tribunal or consumer forum or are non-arbitrable in terms of Indian law. Steps for access of ODR Portal:
• Register on SMART ODR Portal ( https://smartodr.in/login )
• File a New Dispute
• Select Intermediary
• Select Category
• Enter Dispute Details
• Track Resolution Progress

Escalation Matrix

Details ofContact PersonAddressContact NoEmail ID
Customer careDapinder KaurOffice No. 6A, Max Towers, Sector 16 B, Noida, Uttar Pradesh-2013010120-6294424aifcompliance@pluswealth.net
Head of Customer careReshma ShakeelOffice No. 6A, Max Towers, Sector 16 B, Noida, Uttar Pradesh-2013010120-6294425aifcompliance@pluswealth.net
Compliance Officer Komal GoyalOffice No. 6A, Max Towers, Sector 16 B, Noida, Uttar Pradesh-2013010120-6294424aifcompliance@pluswealth.net
CEOParmeet ChadhaOffice No. 6A, Max Towers, Sector 16 B, Noida, Uttar Pradesh-2013010120-6294400aifgrievance@pluswealth.com