Investor Charter in respect of Investment Adviser (IA)

A. Vision and Mission Statements for investors
  • Vision
    Invest with knowledge & safety.

  • Mission
    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
  • Sharing of agreement copy
  • Completing KYC of clients
  Disclosure to Clients
  • To provide full disclosure about its business, affiliations, compensation in the agreement.
  • To not access client’s accounts or holdings for offering advice.
  • 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
  1. 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.

  2. 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.

  3. 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 the investors (Responsibilities of investors)

Do’s

  1. Always deal with SEBI registered Investment Advisers.
  2. Ensure that the Investment Adviser has a valid registration certificate.
  3. Check for SEBI registration number.
    Please refer to the list of all SEBI registered Investment Advisers which is available on SEBI website in the following link:  SEBI Registerd Advisers
  4. 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.
  5. Always ask for your risk profiling before accepting investment advice. Insist that Investment Adviser provides advisory strictly on the basis of your risk profiling and take into account available investment alternatives.
  6. Ask all relevant questions and clear your doubts with your Investment Adviser before acting on advice.
  7. Assess the riskreturn profile of the investment as well as the liquidity and safety aspects before making investments.
  8. Insist on getting the terms and conditions in writing 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.
  9. Be vigilant in your transactions.
  10. Approach the appropriate authorities for redressal of your doubts / grievances.
  11. Inform SEBI about Investment Advisers offering assured or guaranteed returns.

Dont’s

  1. Don’t fall for stock tips offered under the pretext of investment advice.
  2. Do not provide funds for investment to the Investment Adviser.
  3. 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.
  4. Don’t fall prey to luring advertisements or market rumors.
  5. Avoid doing transactions only on the basis of phone calls or messages from any Investment adviser or its representatives.
  6. Don’t take decisions just because of repeated messages and calls by
    Investment Advisers.
  7. Do not fall prey to limited period discount or other incentive, gifts, etc. offered by Investment advisers.
  8. Don’t rush into making investments that do not match your risk taking appetite and investment goals.
  9. Do not share login credential and password of your trading and demat accounts with the Investment Adviser.

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 21G Investment Advisers 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. INA000017231. The firm got its registration on Oct 07, 2022 and is engaged in advisory services.

    The focus of Investment Advisor is to provide investment advice to the clients. Advisor aligns its interests with those of the client and seeks to provide the best suited advice based on clients risk profile. Investment Advisor first tries to understand the client’s return expectations, risk taking ability & goals, which in turn helps to arrive at an asset allocation suitable for the client. Investment Advisor conducts frequent portfolio reviews and suggests any corrective action/s if required.

  • 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
    Terms and conditions of advisory services are detailed in the client agreement. Please refer to the same for details.

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.Terms and conditions of advisory services are detailed in the client agreement. Please refer to the same for details.

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.

F.

The advisor or her associates or relatives have a holding or position in the securities
advised herein. In the case, when the advisor ‘possesses’ the holding or position of the security/securities advised herein, either in his/her account or with a person associated with the advisor (family member), he/she will not take a contra/reverse trade on the advised security/securities for a period of 30 days from the day of the advice.

G.

The advisor has no connection or association of any sort with any issuer of products/securities advised herein.

H.

The advisor has 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.

I.

Investment in securities market are subject to market risks. Read all the related documents carefully before investing.

J.

Registration granted by SEBI, membership of BASL (in case of IAs) and certification from NISM in no way guarantee performance of the intermediary or provide any assurance of returns to investors.

Formats for investors complaints data to be disclosed monthly by IAs on their website/mobile application:
Data for the month ending Jun 2024
Sr. No.
Received from
Pending at the end of last month
Received
Resolved*
Total Pending#
Pending complaints > 3months
Average Resolution time^ (in days)
1
Directly from Investors
0
0
0
0
0
0
2
SEBI (SCORES)
3
0
3
0
0
0
3
Other Sources (if any)
0
0
0
0
0
0
Grand Total
3
0
3
0
0
0
Sr. No.
1
Received from
Directly from Investors
Pending at the end of last month
0
Received
0
Resolved*
0
Total Pending#
0
Pending complaints > 3months
0
Average Resolution time^ (in days)
0
Sr. No.
2
Received from
SEBI (SCORES)
Pending at the end of last month
0
Received
1
Resolved*
1
Total Pending#
0
Pending complaints > 3months
0
Average Resolution time^ (in days)
0
Sr. No.
3
Received from
Other Sources (if any)
Pending at the end of last month
0
Received
0
Resolved*
0
Total Pending#
0
Pending complaints > 3months
0
Average Resolution time^ (in days)
0
Received from
Grand Total
Pending at the end of last month
0
Received
1
Resolved*
1
Total Pending#
0
Pending complaints > 3months
0
Average Resolution time^ (in days)
0
^ Average Resolution time is the sum total of time taken to resolve each complaint in days, in the current month divided by total number of complaints resolved in the current month.
Trend of monthly disposal of complaints
Sr. No.
Month
Carried forward from previous month
Received
Resolved*
Pending#
1
Jul-23
0
1
0
1
2
Aug-23
1
0
1
0
3
Sep-23
0
0
0
0
4
Oct-23
0
0
0
0
5
Nov-23
0
0
0
0
6
Dec-23
0
0
0
0
7
Jan-24
0
0
0
0
8
Feb-24
0
0
0
0
9
Mar-24
0
1
1
0
10
Apr-24
0
1
1
0
11
May-24
0
3
0
3
12
Jun-24
3
0
3
0
Grand Total
4
6
6
4
Sr. No.
1
Month
May-23
Carried forward from previous month
0
Received
0
Resolved*
0
Pending#
0
Sr. No.
2
Month
Jun-23
Carried forward from previous month
0
Received
1
Resolved*
1
Pending#
0
Sr. No.
3
Month
Jul-23
Carried forward from previous month
0
Received
1
Resolved*
0
Pending#
0
Sr. No.
4
Month
Aug-23
Carried forward from previous month
0
Received
0
Resolved*
1
Pending#
0
Sr. No.
6
Month
Sep-23
Carried forward from previous month
0
Received
0
Resolved*
0
Pending#
0
Sr. No.
7
Month
Oct-23
Carried forward from previous month
0
Received
0
Resolved*
0
Pending#
0
Sr. No.
8
Month
Nov-23
Carried forward from previous month
0
Received
0
Resolved*
0
Pending#
0
Sr. No.
9
Month
Dec-23
Carried forward from previous month
0
Received
0
Resolved*
0
Pending#
0
Sr. No.
10
Month
Jan-24
Carried forward from previous month
0
Received
0
Resolved*
0
Pending#
0
Sr. No.
10
Month
Feb-24
Carried forward from previous month
0
Received
0
Resolved*
0
Pending#
0
Sr. No.
11
Month
Mar-24
Carried forward from previous month
0
Received
1
Resolved*
1
Pending#
0
Sr. No.
12
Month
Apr-24
Carried forward from previous month
0
Received
1
Resolved*
1
Pending#
0
Month
Grand Total
Carried forward from previous month
0
Received
4
Resolved*
4
Pending#
0
*Inclusive of complaints of previous months resolved in the current month.
#Inclusive of complaints pending as on the last day of the month.
Trend of annual disposal of complaints
Sr. No.
Year
Carried forward from previous year
Received
Resolved*
Pending#
1
2022 - 2023
0
0
0
0
2
2023 - 2024
0
3
3
0
3
2024 - 2025
0
4
4
0
Grand Total
0
7
7
0
Sr. No.
1
Year
2022 - 2023
Carried forward from previous year
0
Received
0
Resolved*
0
Pending#
0
Sr. No.
2
Year
2023 - 2024
Carried forward from previous year
0
Received
3
Resolved*
3
Pending#
0
Sr. No.
3
Year
2024 - 2025
Carried forward from previous year
0
Received
1
Resolved*
1
Pending#
0
Year
Grand Total
Carried forward from previous year
0
Received
4
Resolved*
4
Pending#
0
*Inclusive of complaints of previous months resolved in the current month.
#Inclusive of complaints pending as on the last day of the month.

Advisory Guidelines

1.MISSION:
As an Investment Adviser, we are passionate about making a difference to the society and help them enrich through our expertise in capital markets.
2.VISION:
Our vision is to build an exemplary Investment advisory practice that can be trusted and unbiased, that is driven by strong values and ethics, providing outstanding investment solutions. To truly partner with our clients in theirinvestment journey and help them realize their financial goals through long term, conservative and responsible non-speculative financial instruments.
3.VALUES:
All our actions as an investment adviser are governed by 3 core values: · Being transparent, · Putting clients first, · Doing the right thing. The objective will be to help clients make informed decisions regarding their personal finance and enhance theirchances of achieving their financial goals in a disciplined way.
4.CODE OF CONDUCT

a) Honesty and Good Faith
Investment Adviser, its employees and associates shall act honestly and in good faith.

b) Diligence
Investment Adviser, its employees and associates shall act with due skill, care and diligence and shall ensure that the advice is offered after thorough analysis.

c) Conflict of Interest
Investment Adviser, its employees and associates shall effectively address conflict of interest which may affect the impartiality of its advisory shall make appropriate disclosures to address the same.

d) Insider Trading or front running
Investment Adviser, its employees and associates shall not engage in insider trading or front running of our own advice.

e) Confidentiality
Investment Adviser, its employees and associates shall maintain confidentiality of information.

f) Professional Standard
Investment Adviser, its employees and associates engaged in advisory shall observe high professional standard while offering advice.

g) Compliance
Investment Adviser, its employees and associates shall comply with all regulatory requirements applicable to the conduct of its business activities.

h) Responsibility of senior management
The senior management of Investment Adviser, its employees and associates engaged in advisory shall bear primary responsibility for ensuring the maintenance of appropriate standards of conduct and adherence to proper procedures by the body corporate.

5.NO FRONT-RUNNING

Front-running is prohibited. There are two ways in which front-running can arise:

a) Through use ofclient order information, i.e. utilizing the advantage of advance knowledge of
pending orders of clients; or

b) Through information about the timing or contents of advice prior to offering it to the clients.

We, 21G Investment Advisers Private Limited (“Investment Advisor”), a registered investment advisor, with SEBI Registration No. INA000017231, are implementing below guidelines as a guiding principle for our investment advisory activities. The guidelines would be applicable to us along with our employees and associates.

We believe that Investor service is a vital element for sustained business growth and we want to ensure that our Investors receive exemplary service across different touch points. Prompt and efficient service is essential for retaining existing relationships and therefore Investor satisfaction becomes critical to us, especially since we follow the Direct‐to‐Investor model. Investor queries and complaints constitute an important voice of Investor, and this policy details grievance handling through a structured grievance redressal framework. Grievance
redressal is supported by a review mechanism, to minimize the recurrence of similar issues in future.

The Grievance Redressal policy follows the following principles:

  • Investors will be treated fairly at all times
  • Complaints raised by Investors will be dealt with courtesy and in a timely manner
  • Queries and Complaints will be treated efficiently and fairly.

The Investment advisor and employees work in good faith and without prejudice, towards the interests of the Investors.
The Investment Advisor has a dedicated Client Servicing Team which is responsible for timely and prompt communication with our clients, while having an open attitude towards service recovery, and providing alternate solutions to investors, thus ensuring healthy relationships with our clients. The Client Servicing Team is headed by Mr Gaurav Sharma (info@21ginvestments.com).

Grievance Redressal Mechanism
Client’s queries / complaints may arise due to lack of understanding or a deficiency of service experienced by clients. Deficiency of service may include lack of explanation, clarifications, understanding which escalates into shortfalls in the expected delivery standards, either due to inadequacy of facilities available or through the attitude of staff towards client.

1. Clients can seek clarification to their query and are further entitled to make a complaint in writing, orally or telephonically. An email may be sent to the Client Servicing Team. Alternatively, the Investor may call on +91 9815714200.

2. A letter may also be written with their query/complaint and posted at the below mentioned address:

Office address :2455 Gr, Dn Arjan Nagar, R S Road, Ludhiana, Punjab, 141003

3. Clients can write to the Investment Manager at info@21ginvestments.com. If the Investor does not receive a response within 10 business days of writing to the Client Servicing Team. The client can expect a reply within 10 business days of approaching the Investment Advisor.
In case you are not satisfied with our response you can lodge your grievance with SEBI at http://scores.gov.in or you may also write to any of the offices of SEBI. SCORES may be accessed thorough SCORES mobile application as well, same can be downloaded from below link:
https://play.google.com/store/apps/details?id=com.ionicframework.sebi236330

4. Smart ODR