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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”
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.
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.
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.
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:
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 https://scores.sebi.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