Grievance Redressal & Dispute Settlement Mechanism

Seers Fund Management Private Limited shall endeavor to address and settle all queries, complaints, and grievances arising out of service deficiencies during the Agreement's subsistence between the Portfolio Manager and the Client.

Seers Fund Management Private Limited has established a suitable mechanism for receiving and addressing customer complaints, specifically focusing on resolving them fairly and expeditiously.

For the timely and proper redressal of the Client's complaints and grievances, the Portfolio Manager has decided to treat all Investors' Grievances as a centralized function and handle them at the Corporate Level, by Mr. Jitender Sharma, Compliance Officer.

The Client can approach him at the following address: Mr. Jitender Sharma, Compliance Officer, SEERS FUND MANAGEMENT PRIVATE LIMITED, 812, 8th Floor, Wave Silver Tower, Sector 18, NOIDA 201301. Tel: +91-120-4566172, +91 9999646222 Email address: compliance@seerspms.com

All the Investors' grievances (hard copy or soft copy) received by the Compliance Officer, as above, will be incorporated in the Register of Grievances.

All such grievances thus received and recorded should be addressed within ten working days from receipt of the grievance or complaint.

If the Client / Investor continues to be dissatisfied with any of the issues consequent to the Portfolio Management Services and the Agreement, both parties shall follow the mechanism stated below:

a) All disputes, differences, claims, and questions whatsoever will, in the first place, be tried to be settled by mutual discussions.

b) In the event of a failure to settle through mutual discussions between the Client, the Portfolio Manager, and their representatives, the matter shall be referred to a sole arbitrator (who shall be a person nominated by the Portfolio Manager). Such arbitration shall follow and be subject to the provisions of The Arbitration and Conciliation Act, 1996, or any Statutory modification or re-enactment thereof currently in force.

c) The arbitration shall be held in Delhi and conducted in English.

d) The Agreement with the Client shall be governed by, construed, and enforced per the laws of India, and all legal actions and proceedings are subject to the jurisdiction of the Court in Delhi only.

e) The Portfolio Manager may appoint a new arbitrator in the event of the person so appointee’s death, refusal, neglect, inability, or to act as arbitrator.

f) The arbitral award shall be in writing and state the reasons it is based. The award shall be final and binding on the Parties.

g) The award may include an award of costs, including reasonable attorneys' fees and disbursements.

h) The Agreement shall always take effect as having been made, entered, and to be performed in Delhi. The Portfolio Manager and Client shall be deemed to have submitted to the exclusive jurisdiction of the competent courts/appropriate forums of Delhi regarding all matters relating to or arising out of the arbitration proceedings, including the Application for interim or interlocutory relief.

i) Investors may also register/lodge complaints to SEBI through its online portal SCORES (SEBI COMPLAINTS REDRESS SYSTEM). The link to access SCORES is https://scores.sebi.gov.in/.

j) Investors can also file complaints by clicking "Complaint Registration" under "Investor Corner." SCORES facilitates investors' lodgement of complaints online with SEBI and subsequently views their status.

k) Seers Fund Management Private Limited shall endeavor to address and settle all queries, complaints, and grievances arising out of service deficiencies during the Agreement's subsistence between the Portfolio Manager and the Client.

l) ODR Portal could be accessed, if unsatisfied with the response. Your attention is drawn to the SEBI circular no. SEBI/HO/OIAE/OIAE_IAD- 1/P/CIR/2023/131 dated July 31, 2023, on “Online Resolution of Disputes in the Indian Securities Market”.

m) A common Online Dispute Resolution Portal (“ODR Portal”) has been established, which harnesses conciliation and online arbitration to resolve disputes arising in the Indian Securities Market.

n) ODR Portal can be accessed via the following link - https://smartodr.in/

o) Investors can approach the Online Dispute Resolution mechanism or other appropriate civil remedies at any point of time. In case the complainant opts for the Online Dispute Resolution mechanism or other appropriate civil remedies while the complaint is pending on SCORES, the complaint shall be treated as disposed of on SCORES

Investor Charter in Respect of Portfolio Management Services

A. Vision and Mission Statements for investors. Vision: To implement diligently researched customized investment strategies that help investors meet their long-term financial goals in a risk-appropriate manner.

Mission: To ensure that the PMS industry provides a viable investment avenue for wealth creation by adopting high levels of skill, integrity, transparency, and accountability.

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

a. appropriate risk profiling of investors

b. to provide Disclosure Document to investors

c. executing the PMS agreement

d. Making investment decisions on behalf of investors (discretionary) or investment decisions taken at the discretion of the Investor (non-discretionary) or advising investors regarding their investment decisions (advisory), as the case may be.

C. Details of services provided to investors and estimated timelines:-

i. Discretionary & Non-Discretionary Portfolio Management Services (PMS):-Under these services, all an investor has to do is to give his portfolio in any form, i.e., in stocks or cash or a combination of both. The minimum size of the portfolio under the Discretionary and/ or Non-Discretionary Funds Management Service

should be Rs.50 lakhs as per the current SEBI Regulations. However, the PMS provider reserves the right to prescribe a higher threshold product-wise or in any other manner at its sole discretion. The PMS provider will ascertain the investor’s investment objectives to achieve optimal returns based on his risk profile. Under the Discretionary Portfolio Management service, investment decisions are at the sole discretion of the PMS provider if they are in sync with the investor’s investment objectives. Under the Non-Discretionary Portfolio Management service, investment decisions are taken at the discretion of the Investor.

ii. Investment Advisory Services: - Under these services, the Client is advised on buy/sell decision within the overall profile without any back-office responsibility for trade execution, custody of securities or accounting functions. The PMS provider shall be solely acting as an Advisor to the Client and shall not be responsible for the investment/divestment of securities and/or administrative activities on the client’s portfolio. The PMS provider shall act in a fiduciary capacity towards its Client and shall maintain arm’s length relationship with its other activities. The PMS provider shall provide advisory services in accordance with guidelines and/or directives issued by the regulatory authorities and/or the Client from time to time in this regard.

iii. Client On-boarding

a. Ensuring compliance with KYC and AML guidelines.

b. franking & signing the Power of Attorney to make investment decisions on behalf of the investor.

c. opening demat account and funding of the same from the investor’s verified bank account and/or transfer of securities from verified demat account of the investor and

d. Mapping the said demat account with Custodian.

iv. Ongoing activities

a. To provide periodic statements to investors as provided under the PMS Regulations 2020 and other SEBI notifications and circulars (“PMS Regulations”) and

b. Providing each client an annual audited account statement that includes all the details as required under the PMS Regulations.

v. Fees and Expenses Charging and disclosure of appropriate fees & expenses in accordance with the PMS Regulations.

vi. Closure and Termination Upon termination of the PMS Agreement by either party, the securities and the funds lying in the account of the investor shall be transferred to the verified bank account/ demat account of the investor.

vii. Grievance Redressal Addressing in a time-bound manner investor queries, service requests, and grievances, if any, on an ongoing basis.

The number of days in the above timelines indicates clear working days.

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

1. It is mandatory for every PMS provider to register itself on SEBI SCORES (SEBI Complaint Redress System). SCORES is a centralised online complaint resolution system through which the complainant can take up his grievance against the PMS provider and subsequently view its status. (https://scores.sebi.gov.in/ )

2. The details such as the name, address and telephone number of the investor relations officer of the PMS provider who attends to the investor queries and complaint should be provided in the PMS Disclosure document.

3. The grievance redressal and dispute mechanism should be mentioned in the Disclosure Document.

4. Investors can approach SEBI for redressal of their complaints. On receipt of complaints, SEBI takes up the matter with the concerned PMS provider and follows up with them.

5. 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)

1. Check registration status of the intermediary from SEBI website before availing services.

2. Submission of KYC documents and application form in a timely manner with signatures in appropriate places and with requisite supporting documents.

3. Read carefully terms and conditions of the agreement before signing the same.

4. Thorough study of the Disclosure Documents of the PMS to accurately understand the risks entailed by the said investment in PMS.

5. Accurate and sincere answers given to the questions asked in the ‘Risk Questionnaire’ shall help the PMS provider properly assess the risk profile of the investor.

6. Thorough study of the quarterly statements sent by the PMS provider to the investor intimating him about the portfolio’s absolute and relative performance, its constituents and its risk profile.

7. Ensure providing complete details of negative list of securities as part of freeze instructions at the time of entering into PMS agreement and every time thereafter for changes, if any, in a timely manner.

8. To update the PMS provider in case of any change in the KYC documents and personal details and to provide the updated KYC along with the required proof.